1. What Personal Information is Collected?
Challenger Group collects personal information that is reasonably necessary for us to provide you with news and updates (if you are opted in to receive this information), financial products and services and to administer them. The kind of personal information we collect and hold will depend upon the type of information, products and services that you request from us and may include:
- information you give us when you request a product or service from us. This information may include your name, date of birth, address, bitcoin wallet address, contact details and relevant identification documents;
- communications between us and associations that you are a member of and with which we have an affiliation;
- transactional information about the use of a product if you have or had a product with us;
- financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks;
- your name, contact details and date of birth where a policy holder who has listed you as a beneficial owner or other related party in connection with that policy (i.e. a nominated beneficiary or a reversionary under a policy or as the policy holder's attorney);
- if you are a financial adviser or other authorised representative of a customer, your name, contact details and any other information you provide when communicating with us in relation to our products and services, or in connection with a mutual customer;
- information (including your name, email address, phone number, post code and any other information as specified at the point of collection) you give us when you agree to receive updates and marketing material from us; and
- information regarding your website interaction with us (i.e. the sections or features of our website that you have visited or used). Challenger will not be able to identify you unless you are a registered user of the relevant Login Site (AdviserOnline or InvestorOnline). See the 'Use of our website' section of this policy for further information.
2. How is personal information collected
What Personal Information is Collected?
- directly from you (including via your financial, legal, or other adviser, or your broker or agent), such as when you provide the information by phone, email or in an application form or an online form (i.e. using a quoting tool, signing up to newsletters or downloading educational material), or when you access a user account for one of our login sites (AdviserOnline or InvestorOnline), or when you participate in a survey, promotion or competition;
- from other Challenger group companies where permitted by law;
- from policy holders where they have listed you as a beneficial owner or other related person in connection with the investment (i.e. a nominated beneficiary, reversionary or an individual granted power of attorney) and have provided us with your name, date of birth and contact details);
- from third parties such as your financial adviser, platform provider, lawyer or other agents or credit reporting agencies, credit providers, or identity verification service providers, if you authorise us to do so; and
- from publically or commercially available sources for the purpose of complying with customer due diligence obligations under relevant legislation (e.g. anti-money laundering laws).
3. What if you do not provide certain information?
If you provide us with incomplete details on a contact form or application, we may not be able to provide you with the information, product, or service until you provide the details we require.
If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you, or continue to provide you with the product or service.
4. How do we use and disclose your personal information?
may collect, use and disclose your personal information for the primary purpose of providing the information, products and/or services requested, as well as for related purposes such as:
- to verify your identity or transactions which you may enter into with us (including the identities of third parties connected with your product/service application, such as beneficiaries and beneficial owners, where applicable);
- to process your applications for our products and services;
- to administer and manage the provision of our products and services;
- to respond to queries, complaints or to provide you with our general customer services;
- to provide your nominated financial adviser or other agent with details of your investment;
- to confirm your membership of an association with which we have an affiliation;
- to provide you with offers from organisations with whom we have an alliance;
- to comply with Challenger's risk management policies and procedures;
- to conduct product and market research;
- to train our staff;
We may disclose your personal information to:
- your financial, legal or other adviser, or your broker, agent or platform provider;
- a financial institution with whom we have a branding arrangement with;
- professional service firms that provide services to us, such as, legal, and audit, or data/information services;
- electronic identity verification service providers, in order for identity information (about you or related persons connected with your investment) to be verified against relevant government and other databases, for the purpose of complying with anti-money laundering laws;
- our related companies; or
- organisations with which we have an association and you are a member, and otherwise in accordance with this policy and the APPs.
5. Use of service providers
We may contract out some of our administrative and support functions such as mailing, settlement services, product administration services, document and data storage, background checking or identity verification services to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.
6. Keeping us up to date
Personal information such as your contact details may change from time-to-time and we ask that you keep us informed of any changes by notifying us. Where you have previously provided information about another person related to your investment (such as a beneficial owner, beneficiary or reversionary) and the information is no longer current, you must provide up-to-date information.
7. Storage and security of information
We store personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using trusted third parties. Some personal information may be held by data service providers located overseas (such as 'Cloud' service providers for data storage and management purposes) and Challenger maintains effective control of the information under contractual arrangements. We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure.
Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.
We do not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as its own identifier for individuals. Instead, Challenger issued numbers such as investor numbers and account numbers are used to identify individuals and the Challenger products and services they obtain.
Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Most web browsers are set to accept cookies. You can choose to disallow cookies by changing settings on your web
10. Employment opportunities
If you are seeking employment or contracting opportunities with Challenger, we will collect personal information from you and, where applicable, from any referees you have provided to us during the recruitment process. We may also collect sensitive information about you as part of our background checking process (with your consent). This information may be disclosed to (and obtained from) third party agencies that we engage to conduct screening checks on our behalf. Personal information gathered during the recruitment process will only be used to assess your suitability for the relevant role, and if you are not the preferred candidate, your information may be retained to assess your suitability for roles offered in the future.
12. Complaints about your privacy
Please send an email to email@example.com
We might make changes to this policy from time to time for any reason and we will update the website in a timely manner.