Public Privacy Policy
Westbridge Property Securities Limited AFSL 238386
Westbridge Funds Pty Ltd AFSL 533936
Momentum Wealth Finance Pty Ltd ACL 384632
Momentum Wealth Property Advisory Pty Ltd RA82976
1. Privacy Policy
Westbridge Property Securities Ltd, Westbridge Funds Pty Ltd (AFSLs) and Momentum Wealth Finance Pty Ltd (ACL) regard Privacy as a pertinent issue and understands that it is important for you to know how we handle your personal information.
This policy has been developed for use across the MW Group of companies (“The MW Group”) including: Momentum Wealth Property Pty Ltd, Momentum Wealth Finance Pty Ltd, Momentum Wealth Property Advisory Pty Ltd, Momentum Wealth Investment Planning Pty Ltd, Momentum Wealth Projects Pty Ltd, Westbridge Commercial Pty Ltd, MW Group Business Services Pty Ltd, Westbridge Funds Pty Ltd, Westbridge Property Securities Limited and Westbridge Asset Management Pty Ltd.
Privacy Laws apply to how we collect, hold, use and disclose your personal information. The MW Group complies with its obligations under the Privacy Act 1988 and the associated Australian Privacy Principles (“APPs”) and is committed to protecting the privacy of your personal information.
You can obtain further details of our obligations as an organisation under Australia’s privacy laws from the Office of the Australian Information Commissioner (Commissioner) or by reference to the APPs and the Commissioner’s associated guidelines at www.oaic.gov.au.
The following Privacy Policy has been published to provide you with an outline of the following:
- What information we collect about you;
- How we collect personal information;
- What we do with your personal information;
- Who we disclose personal information to;
- How we protect your personal information;
- How to keep your personal information accurate and up to date;
- How you can access your personal information; and
- Who to contact if you have any questions about this Policy or wish to make a complaint
2. Types of personal information that we collect, use and hold
We may collect and hold a range of personal information about you to provide you with our services, including:
- identification information including your full name, residential address, and date of birth;
- gender;
- marital status;
- occupation;
- driver’s licence and/or passport details;
- contact details (including telephone and email addresses);
- information about your financial position including details of assets, liabilities, income and expenses; and
- any other information we may need to provide you with our services.
We may collect sensitive information from you. Sensitive information (for example) may include information relating to a person’s health. We will only collect sensitive information that is reasonably necessary for us to provide you with our services.
3. Why we collect your personal information
We may use and disclose the information we collect about you for the following purposes:
- establishing your identity;
- checking whether you are eligible for our services;
- providing you with our services;
- managing and administering our services;
- responding or dealing with a complaint;
- providing information we believe may be relevant or of interest to you;
- direct marketing;
- data analytics and statistical analysis;
- to notify you of other products, services, special offers or events;
- where you otherwise expressly consent to the use or disclosure;
- complying with legislative and regulatory requirements in any jurisdiction; and
- to assist The MW Group in the running of its business.
We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act; these include:
- Contacting you as part of a survey, or for feedback on content, or to enquire about your interest in other similar content or our services.
- To provide other companies with statistical information about our users – but this information will not be used to identify any individual user.
- We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
Some laws require or authorise our collection of your personal information including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006(Cth).
Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise, or an exemption in the Privacy Act applies.
We will retain the information we collect from you for a period of at least 7 years, as required by law.
4. Providing the personal information of another person
If at any time a person provides the personal information of another person, they must ensure that the other person has read and understood this Privacy Policy and separately consents to that personal information being used and disclosed by us in accordance with this Privacy Policy.
5. What if you don’t provide some information to us?
We can only fully advise you about your financial affairs if we have all the relevant information. If you do not provide us with some or all of the information that we ask for, we may not be able to advise or assist you.
You can contact us without using your name or by using a pseudonym. However, we may need your name or contact details to respond to you.
6. How we collect your personal information
We generally collect personal information directly from you. For example, personal information will be collected through our application processes, forms and other interactions with you in the course of providing you with our services.
We may also collect your information from your representatives or professional advisers.
We will not collect sensitive information about you without your consent unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law, or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If the personal information we request is not provided by you, we may not be able to provide you with the benefit of our services, or meet your needs appropriately.
We don’t usually collect unsolicited personal information. Where we receive unsolicited personal information that is not relevant, we will destroy or de-identify that personal information as soon as practicable.
We use information collected over the phone and in-person to contact clients and prospective clients with information and promotional material about the MW Group or their products and services. Clients and prospective clients who do not register to receive marketing material may still be contacted by a consultant about their enquiry. If a client or prospective client no longer wishes to receive contact from their MW Group consultant, they can advise us using the contact details in the first section of this Privacy Policy.
The MW Group may engage with customers through review platforms such as Google Review. We aggregate reviews that have been posted publicly and willingly by users on the review platforms. The use of this information sent via review platforms is governed by the individual platform’s security and privacy regulations. From time to time, we may use this posted data for marketing materials and promotions.
7. Disclosure of your personal information
In order to provide you with services, we may need to disclose your personal information to third parties. The organisations that we are likely to disclose information about you to include:
- to any of The MW Group’s related companies;
- our agents, contractors and external service providers;
- to our professional advisers, auditors and insurers;
- your representatives;
- the Australian Financial Complaints Authority or Office of the Australian Information Commissioner;
- organisations involved in a transfer or sale of our assets or business;
- anyone to whom the disclosure is required or permitted under the Privacy Act, other Australian Law, Regulation or Court/Tribunal Order; and
- anyone else where you have provided your consent.
We may disclose your personal information to overseas entities that we deal with in the course of our business. These recipients may be located in the following countries:
- United States of America
- United Kingdom
- Philippines
- India
- New Zealand
- European Union
We will not disclose personal information to recipients outside of Australia unless:
- we have taken reasonable steps to ensure that the recipient does not breach the Act and the APPs; or
- the recipient is subject to an information privacy scheme similar to the Privacy Act.
8. Use of Artificial Intelligence (AI) technology
We utilise artificial intelligence (AI) technologies within our business, including Microsoft Copilot and Microsoft Teams to enhance productivity, assist with record keeping and streamline workflows. AI may assist in summarising meetings, generating insights, and automating routine tasks. All personal information processed through AI tools and the AI-driven processes we use comply with the Australian Privacy Principles (APPs) and our commitment to data security and the protection of your personal information. Should you wish to opt out of the use AI-driven tools in your interactions with The MW Group, such as automated meeting summaries and transcriptions, please contact us at [email protected]
9. Keeping your personal information accurate and up-to-date
We are committed to ensuring that the personal information we collect, use and disclose is relevant, accurate, complete and up-to-date.
We encourage you to contact us to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.
10. How we hold your personal information
We recognise the importance of securing the personal information of our customers.
The MW Group will primarily hold information about you electronically on secure servers located in Australia. Where information is held electronically, The MW Group utilises technological safeguards including passwords and multifactor authentication. Whilst we do not share your data outside of Australia, we utilise globally recognised software providers, such as Microsoft, that may operate data storage centres in various jurisdictions.
11. Direct marketing
Information collected on any MW Group website, or through any marketing activities or from existing client, employee, contractor and subcontractor databases will belong to the MW Group and may be utilised for direct marketing activities by any other MW Group companies.
We may only use personal information we collect from you for the purposes of direct marketing without your consent if:
- the personal information does not include sensitive information;
- you would reasonably expect us to use or disclose the information for the purpose of direct marketing;
- we provide a simple way of opting out of direct marketing; and
- you have not requested to opt out of receiving direct marketing from us.
If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.
You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.
12. Gaining access to your personal information
You can gain access to your personal information (subject to some exceptions allowed by law) by contacting the Privacy Officer. We will need to verify your identity first. We will provide you access within 30 days if it is reasonable and practicable to do so, but in some circumstances, it may take longer (for example, if we need to contact other entities to properly investigate your request).
We may refuse to provide you with access in certain circumstances. If access is refused, we will give you a notice explaining the reasons for our decision and your options to make a complaint.
We do not usually charge you for access to your personal information. However, if the request is complex, we may charge you the marginal cost of providing the access, such as staff costs of locating and collating information or copying costs. If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.
13. To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the “update preferences” link located on the bottom of our e-mails to update your communication preferences, or by sending us an email us at [email protected]. Customers may not opt out of receiving transactional emails related to their account with us. If a person is included on multiple MW Group databases, they will need to specify that they want to opt-out of all MW Group databases, otherwise they may only be opted-out of one company’s database. Opt-out requests exclude any non-marketing communications that we deliver (by email, post, phone, or other means) that are related to a contract you have signed with us.
14. Using our website and cookies
We collect personal information about you when you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use first-party cookies to track a user’s experience through our website so we can analyse trends and patterns to provide better and more relevant user experiences. We also use Advertising Features such as Google Signals through our Web Analytics Provider. These enable us to associate visitation information with Google information for users who have enabled Ads Personalisation through their Google Account, helping us to better understand the user journey across devices and deliver relevant content and offers to users. You can manage or opt-out of these Advertising Features by updating your Ad Settings.
Some of our business partners, such as our Google Advertising provider, also use cookies on our Website (e.g. third-party cookies). These cookies are used to track visitor behaviour and enable us to deliver relevant offers to users who have previously visited our Website across other third-party sites across the Internet. This Privacy Policy covers the use of cookies the MW Group only and does not cover the use of cookies by any third parties. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.
A web beacon is a clear picture file used to keep track of your navigation through a website. Along with cookies, web beacons help us gain an understanding of how users navigate through and process the content contained in those websites. On occasion we will advertise on third-party websites, including through the use of Google AdWords or display advertising. As part of the tracking process for advertising campaigns we may at times use web beacons to count visitors who have come to the website after being exposed to advertising on a third-party site.
The MW Group uses pixel tags and other methods to gather information about the emails it sends to registered website visitors and recipients of emails sent by MW Group visitors to others. Pixel tags are small graphic files that are included in HTML-encoded email messages. When these messages are opened in an HTML-capable email program, the recipient’s computer will access MW Group’s servers to retrieve the pixel tag file, allowing MW Group to record and store information such as an email address, date and time the recipient viewed the email message if the recipient’s email program is capable of receiving HTML and other logging information. MW Group uses this information to optimize delivery of future messages to specific recipients and to provide information to registered users with respect to emails they send through the MW Group systems.
Log Files
When you use our website we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by MW Group to provide statistics regarding use of MW Group Websites to determine how engaging our content is. The systems we use may link this data automatically to Personal Information collected such as name, email address, address, and phone number. However, you can choose to also browse our website anonymously via browser settings.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
Links
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites we may request that you provide Personal Information about yourself to enable you to access or receive some of our content. The registration and contact forms enable visitors to opt into the MW Group’s mailing lists and require visitors to give contact information. If available, we also collect acquisition data (such as site referrals, campaign tracking, and search data), behavioural data (such as pages visited, time spent on our website and numbers of visits), and technical data (such as browser and devices used to access our website). This data is collected and associated with your personal information when website forms are completed, or if logged into a website. Notice is given at the point of collection to enable visitors to choose whether or not they consent to the terms of collection and use. Those who have registered and subsequently wish to withdraw may opt out of receiving future direct marketing communications at any time (refer to Unsubscribe section of this policy).
Our website may contain links to websites operated by other people. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in any linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so please read them before using those websites.
Use of Navigational Information
We use Navigational Information to operate and improve the website. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalised information about the MW Group.
Customer Testimonials and Comments
We post customer testimonials and comments on our websites, which may contain Personal Information. We obtain each customer’s consent prior to posting the customer’s name and testimonial and will remove any comment should the customer request so.
Use of Credit Card Information
We use a third-party service provider to manage credit card processing. We do not manage this service nor do we have access to the credit card information provided to this service.
Social Media Features
Our websites include Social Media Features, such as the Facebook Like button and Widgets, the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
15. Resolving your privacy concerns
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us on the details below. We are committed to resolving your complaint and doing the right thing by our customers. We will investigate your complaint and provide you with our response within 30 days. Please see our Complaints Policy available on our website at https://westbridgefunds.com.au and https://momentumwealth.dctest.com.au/ for full details of how we deal with complaints.
If you are not satisfied with the outcome of your complaint, depending on the nature of the complaint and the business entity within the MW Group that it applies to; you may be entitled to lodge a complaint with the Australian Financial Complaints Authority (AFCA):
Online: www.afca.org.au
Email: [email protected]
Phone: 1800 931 678
Mail: Australian Financial Complaints Authority GPO Box 3 Melbourne VIC 3001
You may also contact the Office of the Australian Information Commissioner by:
Online: www.oaic.gov.au
Email: [email protected]
Phone: 1300 363 992
Mail: Director of Complaints, Office of the Australian Information Commissioner GPO Box 5218, Sydney NSW
2001
16. Contact Us:
The MW Group
Telephone: 08 9321 5566
Email: [email protected]
Address: Level 1, 38 Station St, Subiaco, WA 6008