Private Portfolio Managers Pty Limited (PPM) is committed to protecting your privacy. We understand that the protection and confidentiality of your personal information is important to you. We treat all information you provide to us in confidence and will take all reasonable steps to ensure non-disclosure to anyone other than for the purposes of fulfilling your instructions.

This Privacy Policy sets out how we can collect, use, hold, manage and disclose your personal information. PPM in this policy refers to Private Portfolio Managers Pty Limited and its related bodies corporate.

PPM is bound by the Privacy Act 1988 (Commonwealth), as amended1, and will protect your information in accordance with the Australian Privacy Principles (APP’s).

For any questions in relation to this Privacy Policy please contact us.

What kinds of personal information do we collect and hold?

Personal information is any information or an opinion that identifies you. We primarily collect personal information from you through our standard forms and application processes. We may also collect personal information when you access the PPM website or when you meet, write to or speak to our staff.

The type of personal information that PPM collects from you may include: your name, contact details, job title(s), information in identification documents (such as your passport, driver’s licence), date of birth, bank account details, details of superannuation arrangements, your tax file number and may include individual investment and financial details such as details of your current assets and liabilities, income and expenses, your investment requirements and objectives, and your investment preferences and risk tolerances. We also keep records of our interactions with you (including by telephone, email and online) and of your transaction history.

PPM collects personal information from you so that we can provide you with products and services and comply with our legal obligations such as those under the Corporations Law, taxation laws and the Anti-Money Laundering and Counter-Terrorism Financing Act.

If you are an employee of PPM we may also collect sensitive personal information about you, examples of the types of sensitive information that may be collected include: professional memberships details, criminal record and health information.The privacy laws impose greater obligations on us regarding sensitive personal information. We will only collect sensitive information if: you have expressly consented to us doing so; or the information is reasonably necessary for or directly related to our business activities; or we are required by law to do so.

If you do not provide us with all the information that we request we may not be able to provide you with the services or information you require.

We will generally collect this information directly from you however in some cases we will seek your authority to collect it from other parties such as government authorities, your accountant, financial planner or your superannuation fund.

To enable us to keep accurate and up-to-date records, please notify us, as soon as possible of any changes to your personal information.

1Such as the Privacy Amendment (Notifiable Data Breaches) Act, 2017

How do we use your personal information?

PPM will hold and use your personal information so that we can provide our services, comply with relevant laws and communicate with you on an ongoing basis. We may use your personal information to verify your identity over the telephone.

PPM may also use personal information you provide for analysis to improve our products and services. Further, we may use your personal information to offer you products and services that we believe may interest you. You may contact us at any time and ask us not to send this information.

In some circumstances your personal information may be disclosed to PPM’s related entities or service providers that perform a range of services on our behalf, such as software providers, external custodians, registry providers and mailing houses. PPM may disclose your personal information to recipients located outside Australia such as financial institutions, custodians and other service providers in the following offshore locations: Canada and the United States of America. PPM takes steps to ensure that these related entities and service providers keep your personal information confidential, secure and use it only for the purposes for which they and PPM are authorized.

We will only disclose your personal information to other external parties where the law requires us to do so.

How do we keep your personal information secure?

PPM has a number of physical and electronic systems to protect your personal information.

PPM retains your personal information in paper and electronic formats at our premises and the premises of our service providers, which may include processing or storage in the cloud, which may mean in practice that this information is stored in Australia and/or overseas.

PPM takes all reasonable steps to protect your personal information from loss, misuse, unauthorized access or disclosure. Any paper files are stored in lockable cabinets which are locked out of hours. Access to our premises is restricted to authorised personnel, meeting rooms are separated from work areas, and access to work areas is restricted. All computer-based information is password protected. Laptops, tablets and mobile phones have both password protection and remote wipe protections. PPM has disaster recovery and back up procedures which are reviewed by the Board annually. We require all staff to maintain the confidentiality of customer information.

PPM will notify you as soon as we become aware of any data breach of your personal information and must mandatorily notify the Office of the Australian Information Commissioner of any ‘eligible data breach’ that affects or could affect you.

Accessing, updating and correcting your personal information

You can request access to the personal information that we hold about you. You can also ask for corrections to be made, please contact PPM.

In certain circumstances, PPM may not be able to provide you with access to your information. In these circumstances, we will write to you to explain and provide the reasons why.

To enable us to keep accurate and up-to-date records, please notify us, as soon as possible of any changes to your personal information.

PPM’s website and privacy

PPM has a website No personal data is stored on our public website. However, you can access your portfolio information directly via this website. Your portfolio information is hosted separately to PPM’s website. To access this secure separately hosted site via the PPM website you will need a Username and Password. You can only view your portfolio information.

You should be aware that the Internet is not a secure environment.

You should ensure that your Username and Password, are kept confidential. If you become aware that they are no longer confidential or there has been unauthorised access of your portfolio information, you should notify PPM immediately.

PPM uses Google Analytics to collect information about the use and effectiveness our website to enable us to improve the site. PPM does not combine the IP information collected via Google Analytics with any personal information.

For more information about data privacy, cookies and similar technologies please refer to the Google Privacy Policy at

You have choices regarding the information Google collects, how it’s used including and if you wish to restrict the identification of your IP address by Google Analytics please refer to Google Privacy Checkup at which provides an opportunity to review and adjust important privacy settings.

Privacy Protection if you are in the European Union or the United Kingdom<

As provided for in the General Data Protection Regulation (GDPR), you have the right to : access your data; correct or amend your data; delete your data subject to applicable law; have your data processed only in accordance with applicable law; have copies of your data moved to another controller; object to our processing your data otherwise than in accordance with the law; and withdraw any consent to our holding and or processing your data at any time. Please email to exercise any of those rights.

If you reside in the EU or UK and have any questions or complaints regarding privacy or information handling and you have raised your concerns with PPM and we have not resolved any issues to your satisfaction, you may be able to escalate your complaint to an external dispute resolution scheme or to a regulatory authority. For more information please refer to

Questions and Complaints

If you have any questions about PPM’s Privacy Policy or wish to make a complaint about how PPM has handled your personal information please contact the:

Privacy Officer
Private Portfolio Managers
Level 3, 2 Martin Place
Sydney, NSW, 2000

Telephone: +61 2 8256 3777
Facsimile +61 2 9235 1682

For more information about privacy in general or if you are not satisfied with PPM’s response or handling of your question or complaint, you can contact the Information Commissioner at

PPM reserves the right to amend or supplement this Privacy Policy from time to time. The updated version will be posted on our website and will be effective from the date of posting.

Updated 12 February 2020