Your privacy is important
Morningstar recognises that maintaining the privacy of your Personal Information matters to you, and is committed to protecting your Personal Information.
Australian (formerly, 'National') Privacy Principles ("APPs") are part of the Privacy Act 1988 and regulate the way in which organisations may collect, use or disclose an individual's Personal Information.
Personal Information means information or an opinion (whether or not true, and whether nor not recorded) about an identified individual, or about an individual who is reasonably identifiable.
Personal information that relates to an individual's own characteristics, beliefs or affiliations is known as 'sensitive information' and will only be collected with your consent or when it is required by law.
Collection of your personal information
Morningstar's main business activities are as a provider of general investment information and research services and tools to individuals and businesses.
We collect Personal Information necessary for us to perform functions associated with our business activities. These functions include administering your account, answering your inquiries, authenticating you when you use our online services to protect your account from unauthorised access, helping diagnose website or server problems, administering our website, including checking most popular web pages and peak usage times, and gathering broad demographic information. We may also use your Personal Information for direct marketing of research services and products.
While some contacts with us such as general enquiries may be made anonymously or by using a pseudonym, if the relationship is to progress any further (by you becoming a client or having a business relationship with us) it will be necessary for us to know who you are. Similarly, we cannot deal with complaints made anonymously or by pseudonym.
Information collected from you and your use of our services
We will collect Personal Information directly from you, unless it is unreasonable or impracticable to do so. Collection of Personal Information is conducted in the following ways:
- emails sent by you to our employees;
- information that you give us when you register with us online;
- event registration and feedback forms;
- face- to- face meetings;
- business cards;
- telephone conversations; and
- cookies when you use our website.
The types of Personal Information we collect depend on the product or service you receive from us. We may ask you for the following information, depending on the products or services you use:
- Your name, phone number, street and email address
- Your credit card number or bank account details
- If you are acting on behalf of your employer, your job title, employer's name and contact information
- Demographic information, such age bracket, investor type and how you heard about us
- a password (when you establish an online subscription).
Where clients are corporations, they may provide us with Personal Information about different contact persons within that corporation including name, job title, and contact information.
We do not adopt Commonwealth Government identifiers, such as a tax file number or a Medicare number, as a means of identifying individuals.
Where a third party gives us information about you
Should a third party give us unsolicited Personal Information about you, we will within a reasonable period determine whether or not we could have collected the information directly from you or it is in a Commonwealth record and, if not, we will take reasonable steps to destroy or de-identify that information unless the law otherwise requires.
You have the right to ask us to let you know the source of your Personal Information. So long as a response is not impracticable or unreasonable, we will reply to you within a reasonable period without cost to you.
Use and disclosure of your personal information
We understand the importance of protecting your privacy. Any information that we collect about you will be used to perform the functions associated with our business activities, including to provide you (or a business with which you are associated) with investment information services or tools that have been requested or subscribed to.
We may use your Personal Information to provide you with information about other products and services that we or our related companies offer from time to time (direct marketing).
If you do not want to receive direct marketing from us or our related companies, contact us on 1800 03 44 55 or by email: firstname.lastname@example.org.
Related entities and outsourcing
We will not make the Personal Information gathered using our products and services available to anyone outside of Morningstar or its related companies except as instructed by you or where required by or permitted by Law.
We may disclose your Personal Information to our related companies, but only so those related companies can assist us with functions relating to our business activities.
Morningstar's related companies include our parent company Morningstar, Inc. in the United States and related companies worldwide. These related companies are located in: Belgium, Brazil, Canada, Chile, China, Denmark, Finland, France, Germany, Hong Kong, India, Italy, Japan, Korea, Luxembourg, Mexico, The Netherlands, New Zealand, Norway, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Thailand and the United Kingdom.
If we use third-party service providers, these service providers may have access to your Personal Information to perform contractually specified services on our behalf. Morningstar contractually requires that all Personal Information accessed by such providers be kept confidential and in accordance with the Australian Privacy Principles.
Links to other websites
Our website may contain links to other websites for you to access. You should be aware that the privacy policies of the operators of those other sites may not be the same as ours and you should refer to their own privacy policies.
Security and quality of personal information
We will take all reasonable steps to ensure that any Personal Information about you which we hold is:
- Secure: protected from misuse, interference and loss and from unauthorised access, modification or disclosure; and
- Appropriate: accurate, complete, up-to-date, relevant and not misleading having regard to the purpose for which it is held.
Your Personal Information may be kept in both hard and soft copy at our Sydney and Melbourne offices and offices of relevant third party providers and may be accessible in soft copy at our related company offices.
We and our related company offices operate secure data networks protected by industry standard firewalls and have password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary.
We restrict access to Personal Information to our employees, and contracted third party providers who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations. Our access to your Personal Information is limited to the following departments for their respective purposes: Finance, Customer Services, IT, Sales, Marketing Services, and Compliance (including the Privacy Officer). The Finance and IT Departments at our related company offices may also have access to your Personal Information.
We will take reasonable steps to destroy or de-identify Personal Information if we no longer need it for any authorised purpose and are not required by law to retain it.
A cookie is a small file which can be downloaded on a device when you access our website and is then sent back to our website each time you access our website. Cookies are useful because they allow us to recognise your device and your user preferences, gather basic tracking information (such as login and password, date, time of visit and preferences), and monitor the presentation of our site. This information allows us to personalise the user experience and improve the quality of our site navigation.
We also use analytical cookies, which allow us to recognise and count the number of users on our website and how users move around the site when they are using it. This helps us improve the way the website works, for example by making sure users can easily find what they need.
Please note that advertisers on the Morningstar.com.au website may also deploy cookies and web beacon technology to measure and improve the effectiveness of advertising for their clients.
If you do not want us to collect cookies, you may set your browser to block cookies associated with our services, or to indicate when a cookie is being set by us. However, many of our services may not function properly if your cookies are disabled.
Access to your personal information
We will handle all requests for access in accordance with the APPs. In most cases, we will give you access to any Personal Information that we hold about you within a reasonable period and in the manner you request, if that is reasonable. In some cases, we may refuse access where refusal is required or permitted by law. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, information that is only available on older back up tapes, or would involve developing a new system or significantly changing an existing practice), or which risk the privacy of others. We will provide you with reasons for any refusal. We may charge a reasonable fee for giving you access to your Personal Information, however at present we do not propose to make any charge.
To request access to your Personal Information please contact our Privacy Officer – contact details are below.
Correction of your personal information
We appreciate any assistance you might give us to keep any Personal Information that we hold up-to-date, complete and accurate. If you want to update any Personal Information, you may do so by accessing the personal account information on our website or by contacting us:
Tel: 1800 03 44 55
Tel: +61 2 9276 4446
Fax: +61 2 9276 4545
We will, on request, normally amend any of your Personal Information which is inaccurate, incomplete, out-of-date, irrelevant or misleading (without cost to you) where:
- we are satisfied that the information needs to be corrected; and/or
- we agree with your request that the information be corrected.
If we disagree with your request, we will write to inform you of our concerns about making the change you have requested, giving reasons for our refusal and notifying you of available complaint mechanisms. If you wish, we will then (at no cost to you and within a reasonable period), take reasonable steps to associate with the appropriate records of your Personal Information a statement that you claim the information is inaccurate, incomplete or out-of-date (whichever is relevant) and that you have requested a particular change.
If you have a complaint about how we handle your Personal Information, please contact our Privacy Officer as described below.
The Privacy Officer will acknowledge your complaint within three business days of receipt and will seek to resolve your complaint within 20 business days of receipt.
Morningstar Privacy Officer Contact Details
Level 36, Australia Square
264 George Street
Sydney, NSW 2000, Australia
Phone: +61 2 9276 4532
Facsimile +61 2 9276 4545
If your complaint is not resolved to your satisfaction you have the right to contact the Financial Ombudsman Service (FOS). FOS is an external dispute resolution scheme authorised to deal with complaints in relation to the financial services industry including privacy.
The Financial Ombudsman Service
GPO Box 3
Melbourne VIC 3001
If you are still not satisfied with the outcome you can contact:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Facsimile: +61 2 9284 9666
Copies of this policy and further information
As the Federal Government introduces new privacy legislation, this Policy will be reviewed and updated accordingly. We will also regularly review this Policy and may change it from time to time. The date at which this Policy was most recently updated is given above.
More information on privacy legislation is available from the Office of the Australian Information Commissioner at www.oaic.gov.au