Privacy Policy

Boutique Advisers Pty Ltd (“Boutique”), the Australian Financial Services Licensee for Lumion Private Wealth Pty Ltd, recognises the sensitive nature of personal information and we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). As an Australian Financial Services Licensee (“AFSL”), Boutique is subject to certain legislative and regulatory requirements. This necessitates us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“personal information”). This Privacy Policy describes the current policies and practices of Boutique and Lumion Private Wealth Pty Ltd (“Lumion”) in relation to the collection, handling, use and disclosure of personal information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected. This policy is subject to change from time to time.

Our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you. This can include a broad range of information ranging from your name, address, contact details and age to other information about your personal affairs including: - details of your overall circumstances, financial needs and objectives; - details of your financial circumstances, including but not limited to, your assets and liabilities (both actual and potential), income, expenditure, insurance cover, superannuation and investments; - details of your investment preferences and capacity for and tolerance to risk; and - information about your employment history, employment circumstances, family commitments and social security eligibility. We use your information to enable us to manage your ongoing requirements and our relationship with you. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications. From time to time we will use your contact details to send you updates, events, articles, newsletters or other information about products and services that we believe will be of interest to you. We may also send you regular updates by email or by post. We will always give you the option of electing not to receive these communications and you can unsubscribe at any time by notifying us that you wish to do so. We may also use your information internally to help us improve our services and resolve any problems.

Appropriate advice may not be able to be given without complete, accurate and thorough information relating to your financial circumstances, needs and objectives. By providing insufficient or incomplete information, you risk making a financial commitment that may not be appropriate to your needs. If any of the personal information in this advice is incorrect you need to notify us immediately.

Where you have provided us with an ‘identifier’ such as a Tax File Number (“TFN”) or Driver’s Licence number in the course of implementing product recommendations we will record this ‘identifier’ in a secure manner where you have authorised us to do so. We will not adopt this ‘identifier’ as our own and ensure that it is removed from all paper records. An Australian Business Number is not considered to be an ‘identifier’ and may be retained for our records.

We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. We hold the information we collect from you within our electronic computer database but we may also retain some paper-based records. In some cases, your file is archived and sent to an external data storage provider for a period of time. We only use storage providers in Australia who are also regulated by the Privacy Act. Your personal information is generally held in your client file. We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. We ensure that your information is safe by: - Protecting all computer based information through the use of access passwords on each computer and on each program; and - Backing up data regularly and storing it securely off site. - We maintain physical security over our paper and electronic data and premises, by using locks and security systems.

We do not sell, trade, or rent your personal information to others. We may disclose your information to recipients in the Philippines for the purpose of providing administration services only. If they are not regulated by laws which protect your information in a way that is similar to the Privacy Act, we will seek your consent before disclosing your information to them. We may disclose your information to superannuation fund trustees, insurance providers, and product issuers for the purpose of implementing the recommendations made by us. In the course of servicing your needs, we may also disclose your personal information to external advisers such as accountants, solicitors and other industry professionals. We may also need to provide your information to contractors who supply services to us, e.g. to handle mailings on our behalf, external data storage providers, secretarial services or IT contractors or to other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event. However, we will take all reasonable steps to ensure that they protect your information in the same way that we do. We may also provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits. We are obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission.

Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete. If you wish to access or correct your personal information please write to: Privacy Officer Lumion Private Wealth Pty Ltd Level 3, 1 Outridge Crescent Subiaco WA 6008 We do not charge for providing access to personal information. In some limited cases, we may need to refuse access to your information or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal.

We endeavour to provide you with the best advice and service at all times. If you are not satisfied with our services, then we encourage you to contact us. Please call us, send us an email, or place your complaint in writing to our office. You can direct your complaint to your financial adviser or to one of our directors. We aim to resolve complaints immediately. Where this is not possible, we will acknowledge the receipt of your complaint within 48 hours. We will then explain our process to resolve your complaint and tell you who will handle your complaint. If you are not satisfied with our response after 30 days, you can lodge your complaint with the Australian Financial Complaints Authority. You can contact AFCA on 1800 931 678 or via their website www.afca.org.au. AFCA provides fair and independent financial services complaint resolution which is free to consumers. To contact Lumion about a privacy concern, write to [email protected] or to the Privacy Officer at Level 3, 1 Outridge Crescent, Subiaco WA 6008. Boutique Advisers Pty Ltd remains the licensee responsible for the financial services provided by its authorised representatives.

Anonymous data We use technology to collect anonymous information about the use of our website, for example when you browse our website our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes and to improve the content and functionality of our website, to better understand our clients and markets and to improve our services. Cookies In order to collect this anonymous data we may use “cookies”. Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. Sometimes they identify users where the website requires information to be retained from one page to the next. This is purely to increase the functionality of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your computer and you can set your browser to notify you when you receive a cookie so that you can decide if you want to accept it. We use an essential authentication cookie for authorised administrators who sign in to the website. This cookie maintains their signed-in session for up to 12 hours and is cleared on sign-out. Blocking this cookie may prevent access to the administration area.

By asking us to assist with your comprehensive financial planning, insurance and advice needs, you consent to the collection and use of the information you have provided to us for the purposes described above.

Privacy Officer: Lumion Private Wealth Pty Ltd Address: Level 3, 1 Outridge Crescent, Subiaco WA 6008 E-mail: [email protected] Licensee: Boutique Advisers Pty Ltd (AFSL 554650) Licensee telephone: (08) 9381 8779