Privacy Policy
Last updated: August 2026
1. Our commitment to your privacy
At The Updated Investor Pty Ltd ("The Updated Investor", "we", "us" or "our"), we understand that the information you share with us can be personal, sensitive and important.
As a financial planning business, understanding your circumstances is an important part of helping you make informed financial decisions and achieve greater Financial Certainty.
We are committed to protecting your privacy and handling your personal information responsibly.
This Privacy Policy explains how we collect, hold, use and disclose personal information, how we seek to protect that information, and how you can access or correct information we hold about you or raise a concern about your privacy.
We manage personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
2. The information we collect
The information we collect depends on your relationship with us.
There is an important distinction between the limited information we collect from people who interact with our website, surveys and marketing communications, and the more detailed information we need to collect from people who become financial planning clients.
Website visitors and prospective clients
When you interact with our website, complete one of our Financial Certainty Surveys, subscribe to our communications or make an enquiry, the personally identifiable information we collect is generally limited to basic contact information such as your:
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name; and
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email address.
We do not use our website, Financial Certainty Surveys or marketing database to collect or store confidential client financial information.
Financial planning clients
If you become a financial planning client, we need to collect more detailed information so that we can understand your circumstances and provide appropriate financial advice and services.
Depending on the advice and services you require, this information may include:
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your name, date of birth and contact details;
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identification information;
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family and relationship information;
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employment and business information;
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financial goals, priorities and objectives;
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income and expenditure;
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assets and liabilities;
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investments and savings;
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superannuation and retirement arrangements;
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taxation information;
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personal insurance arrangements;
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estate planning information;
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Centrelink and other government benefit information;
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information about companies, trusts, self-managed superannuation funds or other entities associated with you;
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information about your financial knowledge, preferences and attitude towards investment risk;
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correspondence and records of our communications with you; and
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other information reasonably required to provide financial planning and related services.
In some circumstances, we may also need to collect sensitive information, including health or medical information, particularly where this is relevant to personal insurance, retirement planning or other financial advice.
We will generally only collect sensitive information with your consent or where otherwise permitted or required by law.
3. How we collect your information
Where practical, we collect personal information directly from you.
This may occur when you:
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contact us by telephone, email or through our website;
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meet with one of our advisers or team members;
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complete a Financial Certainty Survey, questionnaire, fact find or other form;
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book a meeting or Strategy Session;
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subscribe to our newsletter or other communications;
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provide documents or information as part of the financial planning process;
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use our client services; or
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otherwise communicate with us.
With your consent, or where permitted by law, we may also collect information from other people and organisations.
These may include your accountant, solicitor, superannuation fund, insurer, investment provider, bank, Centrelink, other professional advisers or members of your family.
We may also receive basic contact information from people who refer you to us.
4. Financial Certainty Surveys
Our website provides Financial Certainty Surveys for people at different stages of their financial lives. The surveys are designed to help you consider different aspects of your financial position and your level of Financial Certainty. Although the surveys ask you to consider and respond to statements about financial matters, we do not ask you to provide specific personal financial details or confidential financial information as part of these surveys.
The only personally identifiable information we collect through the survey process is your name and email address. For example, we do not ask you to enter account numbers, bank details, investment balances, superannuation balances, tax file numbers or other confidential client financial information as part of a Financial Certainty Survey.
Your survey responses may be used to provide your results, help us understand areas where you may be seeking assistance and, where appropriate, communicate with you about information or services that may be relevant to you.
Completing a Financial Certainty Survey does not, by itself, establish a financial adviser-client relationship or constitute the provision of personal financial advice.
5. Website and marketing information
Our website and marketing database are operated using Wix.
The personally identifiable information maintained through our marketing database is limited to basic information used for communication and marketing purposes, principally your name and email address.
We do not use Wix as a repository for confidential client financial information.
We may use your contact information to provide newsletters, articles, educational material, invitations and other communications that we believe may be relevant to you, where you have requested these communications or where we are otherwise permitted to do so.
You can ask us at any time not to send you marketing communications. You can also use the unsubscribe facility included in our electronic marketing communications.
6. Why we collect personal information
We collect, hold and use personal information so that we can operate our business and provide the services you have requested.
Depending on your relationship with us, this may include using your information to:
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respond to enquiries;
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provide Financial Certainty Survey results;
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arrange meetings and appointments;
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understand your financial position, objectives and priorities;
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provide financial planning and financial advice services;
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develop and review financial strategies;
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implement recommendations you have agreed to;
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assist with investments, superannuation, retirement planning, personal insurance and other financial matters;
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provide ongoing financial planning services;
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communicate with you;
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administer our relationship with you;
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maintain records required by law and professional standards;
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manage and improve our business and services;
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comply with our legal, regulatory and professional obligations; and
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provide information and communications that may be relevant to you.
7. Where confidential client information is held
We take a deliberate approach to where confidential client information is stored.
Confidential client information is held electronically within AdviserLogic, provided by Morningstar.
AdviserLogic is specialist financial planning software designed for use by financial advisers and financial planning businesses. An important function of the system is the secure management and protection of client information and financial planning records.
We use AdviserLogic as our principal system for maintaining confidential client information and financial planning records.
The Updated Investor does not maintain its own in-house servers for the storage of confidential client information.
Confidential client financial information is not stored on our website or marketing database as a substitute for our specialist client management and financial planning systems.
Our approach is to use specialist third-party systems appropriate to the nature and sensitivity of the information being handled.
8. Paper records and our digital approach
The Updated Investor operates on a digital basis and does not maintain permanent paper-based client files.
There may be occasions where information or documents are initially provided to us in paper form, including forms completed or signed by clients.
Where this occurs, the relevant information or document is digitised and stored electronically in the appropriate client record.
Once we are satisfied that the electronic record has been properly captured and retained, the original paper document is securely destroyed, subject to any legal or regulatory requirement that requires an original document to be retained.
As a general practice, confidential client information is therefore not retained in physical client files.
9. How we protect your information
Protecting personal information is particularly important to us because of the sensitive nature of financial planning information.
We seek to minimise the amount of confidential information held across different systems and locations.
In particular:
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our Financial Certainty Surveys do not require you to provide specific confidential financial information;
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our Wix marketing database is used for basic contact and marketing information rather than confidential client financial records;
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confidential client information and financial planning records are maintained electronically using AdviserLogic, provided by Morningstar;
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we do not maintain in-house servers for the storage of confidential client information; and
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we do not maintain permanent paper-based client files.
We also take reasonable administrative, technical and procedural steps to protect personal information against misuse, interference, loss, unauthorised access, modification and disclosure.
While we take the protection of personal information seriously, no method of electronic transmission or storage can be guaranteed to be completely secure.
If we become aware of an eligible data breach involving personal information, we will respond in accordance with our obligations under the Privacy Act and the Notifiable Data Breaches scheme.
10. Who we may disclose information to
We do not sell your personal information.
In providing financial planning and related services, we may disclose personal information where reasonably necessary to organisations and people involved in providing or supporting those services.
Depending on your circumstances, these may include:
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our Australian Financial Services Licensee, where applicable;
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superannuation funds;
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investment and platform providers;
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insurers;
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banks and other financial institutions;
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accountants, solicitors and other professional advisers;
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financial planning software and technology providers;
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administration and service providers;
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information technology, cloud storage and cybersecurity providers;
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auditors, compliance consultants and other professional service providers;
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government agencies and regulators;
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external dispute resolution bodies; and
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other parties where you have authorised us to disclose information.
We may also disclose information where we are required or authorised to do so by law.
Where third-party service providers handle personal information on our behalf, we seek to use providers appropriate to the nature and sensitivity of the information involved.
11. Overseas storage and disclosure
Some technology, cloud, communication and other service providers may operate infrastructure or process information outside Australia.
Where personal information is likely to be disclosed to an overseas recipient, we will take reasonable steps to ensure that the information is handled appropriately and in accordance with applicable Australian privacy requirements.
Where practicable and required by the Australian Privacy Principles, we will identify the countries in which overseas recipients of personal information are likely to be located.
12. Website information and cookies
When you visit our website, certain technical information may be collected automatically.
This may include information such as your IP address, browser type, device information, pages visited, the date and time of your visit and information about how you interact with our website.
Our website and its service providers may use cookies and similar technologies to help the website operate, understand how visitors use the site and improve the website experience.
You can generally configure your browser to refuse or delete cookies, although doing so may affect the operation of some website features.
13. Third-party websites and services
Our website may use or provide links to third-party services for functions such as appointment scheduling, surveys, client access and other services.
Our website may also contain links to websites operated by third parties.
These third parties may have their own privacy policies and practices. Where you leave our website or provide information directly to a third-party service, we encourage you to review that provider's privacy policy.
14. How long we keep personal information
We retain personal information for as long as reasonably necessary to provide our services and meet our legal, regulatory, professional and business obligations.
Financial advisers and financial services businesses may be required to retain certain client and advice records for prescribed periods.
When personal information is no longer required and we are not legally or professionally required to retain it, we will take reasonable steps to securely destroy or permanently de-identify it.
15. Can you deal with us anonymously?
Where practical and lawful, you may deal with us anonymously or using a pseudonym, particularly when making a general enquiry.
However, because of the nature of financial planning and our legal and regulatory obligations, we will generally need to know and verify your identity before we can provide personal financial advice or establish an ongoing client relationship.
16. Accessing your personal information
You may ask us for access to the personal information we hold about you.
In most circumstances, we will provide access within a reasonable period. There may be limited circumstances where we are permitted or required by law to refuse access to some information.
We may need to verify your identity before providing access to personal information.
If we are unable to provide access, we will generally explain the reason, subject to any legal restrictions that apply.
17. Correcting your information
We want the information we hold about you to be accurate, complete, relevant and up to date.
If you believe information we hold about you is incorrect, incomplete or out of date, please contact us and ask us to correct it.
We will take reasonable steps to correct information where appropriate.
18. Privacy complaints
If you have a concern about the way we have collected, held, used, disclosed or otherwise handled your personal information, please contact us.
Please provide sufficient information about your concern so that we can investigate it properly.
We will acknowledge your complaint and aim to investigate and respond within a reasonable period.
If you are not satisfied with our response, you may have the right to refer your privacy complaint to the Office of the Australian Information Commissioner (OAIC).
Information about privacy rights and making a privacy complaint is available from the OAIC at www.oaic.gov.au.
Depending on the nature of your complaint, other external dispute resolution arrangements may also be available.
19. Changes to this Privacy Policy
Privacy laws, technology and the way we provide our services may change over time.
We may update this Privacy Policy from time to time to reflect changes to our business, systems, service providers or legal obligations.
The current version will be available on our website, with the date of the most recent update shown at the beginning of the Policy.
20. Contact us
If you have a question about this Privacy Policy, would like to access or correct your personal information, or wish to make a privacy complaint, please contact:
Privacy Officer
The Updated Investor Pty Ltd
Suite 4, 81-85 Great North Road
Five Dock NSW 2046
Telephone: 02 9712 7313
Email: admin@theupdated.com.au
Website: www.theupdated.com.au
