Privacy Policy

Introduction and Preliminary Provisions

This Privacy Policy elucidates the obligations of Financial Portfolio Pty Ltd (operating as FinancialPortfolio.com.au, hereinafter referred to as “the Company”, “we”, “us”, or “our”) concerning the collection, retention, utilisation, and dissemination of personal and financial information. The Company is inexorably bound by the Australian Privacy Principles (APPs) as enshrined within the Privacy Act 1988 (Cth). Given the inherently sensitive nature of private wealth tracking, asset aggregation, and financial analytics, we enforce superlative standards of data governance and cryptographic security to safeguard your proprietary information.

Taxonomy of Information Collected

To facilitate comprehensive wealth tracking and portfolio optimisation, we collect specific categories of personal and financial data, restricted to what is strictly necessary for our platform’s functionality:

• Biographical and Identity Data: Legal nomenclature, dates of birth, residential and postal coordinates, telephonic contact details, and electronic mail addresses.
• Financial and Asset Data: Bank account nomenclature, transaction histories, superannuation balances, equity portfolios, cryptographic asset holdings, real property valuations, and associated liability structures (e.g., mortgage facilities and margin loans).
• Technical and Telemetry Data: Internet Protocol (IP) addresses, cryptographic session tokens, browser typologies, device identifiers, and granular navigational behaviour within our software architecture, collated via cookies and analogous tracking technologies.

Methodologies of Data Acquisition

The Company adheres to unambiguous and consent-driven collection modalities. We acquire your data through:

• Direct Provision: Information explicitly inputted by you during account conceptualisation, profile configuration, and manual asset ledger updates.
• Automated Aggregation and Open Banking: With your explicit, revocable authorisation, we utilise Application Programming Interfaces (APIs), third-party data aggregators, and mechanisms facilitated under the Consumer Data Right (CDR) to programmatically harvest read-only transaction feeds from your nominated financial institutions, brokerages, and wealth management platforms.
• Ancillary Verification: Data sourced from public registries or anti-money laundering (AML) identity verification agencies, where statutory compliance necessitates such corroboration.

Purposes of Utilisation and Dissemination

Your information is harnessed strictly to deliver our proprietary wealth tracking software as a service (SaaS). Specifically, we deploy your data to:

• Synthesise, visualise, and render your consolidated financial portfolio and net worth trajectory.
• Execute analytical algorithms to furnish you with retrospective and prospective insights regarding asset allocation and performance.
• Authenticate your identity and fortify the platform against fraudulent incursions.
• Administer our commercial relationship with you, including subscription billing and technical support.

Third-Party Disclosures and Sub-Processors

We categorically abstain from monetising, renting, or selling your personal or financial data. Disclosures to third parties are strictly circumscribed to the following scenarios:

• Infrastructure Partners: Disclosures to enterprise-grade cloud service providers (e.g., AWS or Microsoft Azure) and security auditors who facilitate our operational architecture and are contractually bound by rigorous confidentiality covenants.
• Financial Aggregators: Entities that operate as intermediaries to facilitate secure data feeds from your banking institutions, provided such entities maintain compliance with Australian banking and privacy standards.
• Statutory Mandates: Disclosures compelled by a subpoena, warrant, or an unambiguous directive from regulatory authorities such as the Australian Securities and Investments Commission (ASIC) or the Australian Taxation Office (ATO).

While our primary data repositories reside within Australian territorial borders, ancillary sub-processors may utilise offshore infrastructure. In such instances, we implement robust contractual mechanisms to ensure these extraterritorial entities conform to data protection standards commensurate with the APPs.

Cryptographic Security and Data Sovereignty

The Company deploys an uncompromising matrix of physical, electronic, and procedural safeguards. This encompasses AES-256 encryption for data at rest, TLS 1.3 cryptographic protocols for data in transit, and mandatory multi-factor authentication (MFA) for platform access. We enforce the principle of least privilege amongst our personnel, ensuring access to raw financial data is strictly compartmentalised. Upon the cessation of your subscription, or upon your explicit instruction, your financial data is subjected to cryptographic erasure or irrevocable de-identification, save for any information we are statutorily obliged to retain.

Access, Rectification, and Grievance Resolution

You hold a statutory entitlement to request access to, and the rectification of, the personal information we domicile. Should you identify anomalies or wish to interrogate our privacy practices, you are directed to correspond with our Privacy Officer. We undertake to formally acknowledge and adjudicate any grievance within thirty (30) days. Should our internal remediation prove inadequate, you retain the prerogative to escalate your dispute to the Office of the Australian Information Commissioner (OAIC).

Contact Coordinates

Financial Portfolio Pty Ltd

Attention: The Chief Privacy Officer

Address: 133 Toorack Road, South Yarra, Victoria, 3141

Email: admin@financialportfolio.com.au

Effective Date: 4 September 2026