Privacy Policy

This Privacy Policy outlines how Carollo Horton & Associates Pty Ltd manages your personal information. It describes the sorts of personal information held and for what purposes and how that information is collected, held, used and disclosed. It also details how you can resolve any privacy issues you may have with our Company.


Personal information is information about individuals where the individual can be identified or can reasonably be ascertained from the information. It may include points such as your name, address, age, insurance history or financial details.


Sensitive information is personal information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health disability, sexual orientation or criminal record. This type of information will not be collected nor disclosed without your consent, unless required by law or the collection is required for the establishment, exercise or defence of a legal or equitable claim.


We have adopted the Australian Privacy Principles (APPs) which set out standards for the collection, use, disclosure and handling of personal information. We are committed to respecting your right to privacy and protecting this information.


Our Privacy Policy applies to any personal information we collect, use or disclose and applies to all your dealings with us.


Principles of Our Privacy Policy:

  1. How and why we collect personal information
  2. How we use and disclose personal information
  3. What we expect of you and third parties we deal with
  4. Security of your personal information
  5. Access to your personal information
  6. Transfer of information overseas
  7. Complaints Procedure
  8. How to contact us


1. How and why we collect personal Information:

We will only collect personal information from or about you for the purpose of providing insurance services including your application and administering your insurance policy, including any claims made by you.


2. How we use and disclose personal information

We will not use or disclose personal information for any purpose that is unrelated to our services and that you would not reasonably expect (except with your consent).


We may need to disclose personal information to insurers and those involved in the claims handling process (including assessors, investigators and other insurers), for the purposes of assisting it and them in providing relevant services and products, or for the purposes of recovery or litigation. We may disclose personal information to people listed as co-insured on your Policy and to family members or agents authorised by you.


We will take reasonable steps to ensure that your personal information is accurate, complete and up-todate.


If the required personal information is not provided, we or any involved third parties may not be able to provide appropriate services.


3. What we expect of you and third parties we deal with

When you provide personal information about other individuals, we rely on you to have made them aware that you will or may provide their information to us, the purposes we use it for, the types of third parties we disclose it to and how they can access it (as described in this document).


4. Security of your personal information

We may store your personal information electronically or in hard copy. We endeavour to protect it from misuse and loss and from unauthorised access, modification and disclosure.


We maintain computer and network security, e.g. the use of fire walls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to computer systems.


5. Access to your personal information

You may access your personal information held by us and you may let us know if you think it inaccurate, incomplete or out of date. No fee will be charged by us for an access request. However, we may charge the reasonable cost of complying with the access request. There are some limited situations that are set out in the Australian Privacy Principles where a request for access may not be allowed.


6. Disclosure of information overseas

Where it becomes necessary to transfer or disclose information overseas our privacy policy continues to apply. We may transfer your personal information overseas where it is necessary to provide our service. However, this will not occur without your permission unless the country is subject to a comparable privacy scheme. Our authorising insurers also operate offshore processing areas, details of which can be found in the privacy statements we provide you with on behalf of those insurers.


7. Privacy Complaints

Any privacy complaints should first be referred to the relevant staff member and their manager. Any unresolved complaints should be referred to the Office of the Australian Information Commissioner whose contact details appear below:


Post: GPO Box 5218 Sydney NSW 2001


Phone: 1300 363 992



8. How to contact us

Please contact us if you would like to:

  • Find out more about the way we manage personal information.
  • Access your personal information held by our office.
  • Provide details for us to correct or update your personal information we hold.
  • Complain about a breach of privacy.
  • Discontinue receiving information about our products or services; or
  • If you do not want us to disclose your personal information to other organisations.


Contact: Susan Carollo

Carollo Horton & Associates Pty Ltd

Ph: 1300 227 655

Fax: 03 9560 6224


The financial services referred to in this financial services guide (FSG) are offered by:


Carollo Horton and Associates Pty Ltd ABN 85 235 271 160

54 Henderson Rd, Rowville, VIC 3178

03 9562 0032 | 1300 227 655


This FSG sets out the services that we can offer you. It is designed to assist you in deciding whether to use any of those services and contains important information about:

  • the services we offer you.
  • how we and others are paid.
  • any potential conflict of interest we may have.
  • our internal and external dispute resolution procedures and how you can access them.
  • arrangements that are in place to compensate clients for losses.


Further information when personal advice is given

We will provide you with further information whenever we provide you with advice which takes into account your objectives, financial situation and needs. This information may include the advice that we have given you, the basis of the advice and other information on our remuneration and any relevant associations or interests. This information may be contained in a statement of advice (SOA).


When you ask us to recommend an insurance policy for you, we will usually only consider the policies offered by the insurers or insurance providers that we deal with regularly. In giving you advice about the costs and terms of recommended policies, we have not compared those policies to all policies available.


Product disclosure statement

If we offer to arrange the issue of an insurance policy to you, we will also provide you with, or pass on to you, a product disclosure statement (PDS), unless you already have an up to date PDS from the insurer. The PDS will contain information about the particular policy, which will enable you to make an informed decision about purchasing that product.


From when does this FSG apply?

This FSG applies from 7 September, 2018 and remains valid unless a further FSG is issued to replace it. We may give you a supplementary FSG. It will not replace this FSG but will cover services not covered by this FSG.


How can I instruct you?

You can contact us to give us instructions by post, phone or email on the contact number or details mentioned on page 1 of this FSG.


Who is responsible for the financial services provided?

Carollo Horton & Associates Pty Ltd is responsible for the financial services that will be provided to you or through you to your family members, including the distribution of this FSG. Carollo Horton & Associates Pty Ltd holds a current Australian Financial Services Licensee no:503725 . The contact details for Carollo Horton & Associates Pty Ltd are on the front of this FSG.


What kinds of financial services are you authorised to provide to me and what kinds of financial product/s do those services relate to?

Carollo Horton and Associates Pty Ltd is authorised to advise and deal in general insurance products to wholesale and/or retail clients under its Australian Financial Service Licence. We will do this as your broker unless we tell you otherwise. Sometimes we will act under a binder or agency from the insurer. When we act under a binder or agency, we will be acting as the agent of the insurer. This means that we represent and act for the insurer, not for you. We will tell you when we act under a binder or agency to arrange your insurance or advise you about your insurance needs.


Will I receive tailored advice?

Maybe not in all cases. For example, if an insurer offers a renewal of a policy, we will automatically renew your insurance policy with the insurer, unless you have asked us to give you advice about your insurance needs for the next insurance term. This does not apply to some project specific, short term or non-renewable policies. We will tell you when this is case.


However, we may need information about your personal objectives, details of your current financial situation and any relevant information, so that we can arrange insurance policies for you, issue insurance policies to you or to give you advice about your insurance needs. We will ask you for the details that we need to know.


In some cases, we will not ask for any of this information. If we do not ask, or if you do not give us all of the information we ask for, any advice you receive may not be appropriate to your needs, objectives and financial situation.


You should read the warnings contained in any SOA, or any other warnings that I/we give you, carefully before making any decision about an insurance policy.


Where we provide you with advice about your insurance arrangements, that advice is current at the time that we give it. We will review your insurance arrangements when you inform us about changes in your circumstances.


Contractual Liability and your insurance cover

Many commercial or business contracts contain clauses dealing with your liability (including indemnities or hold harmless clauses). Such clauses may entitle your insurers to reduce cover, or in some cases, refuse to indemnify you at all. You should seek legal advice before signing and accepting contracts. You should inform us of any clauses of this nature before you enter into them.


What information do you maintain in my file and can I examine my file?

We maintain a record of your personal profile, including details of insurance policies that we arrange or issue for you. We may also maintain records of any recommendations or advice given to you. Carollo Horton & Associates Pty Ltd will retain this FSG and any other FSG given to you as well as any SOA or PDS that we give or pass on to you for the period required by law.


We are committed to implementing and promoting a privacy policy, which will ensure the privacy and security of your personal information. A copy of our privacy policy is available on request. A copy is also available on our website, If you wish to look at your file, please ask us. We will arrange for you to do so.


How will I pay for the services provided?

For each insurance product, the insurer will charge a premium that includes any relevant taxes, charges and levies. We often receive a payment based on a percentage of this premium (excluding relevant taxes, charges and levies) called commission, which is paid to us by the insurers. However, in some cases we will also charge you a fee. These will all be shown on the invoice that we send you. You can choose to pay by any of the payment methods set out in the invoice. You are required to pay us within the time set out on the invoice. If you pay by credit card, we will charge you a non-refundable credit card fee as shown on the Tax Invoice. This reimburses us for the bank interest and extra bank charges, and internal time generated for credit card use.


If there is a refund or reduction of your premium as a result of a cancellation or alteration to a policy, or based on a term of your policy (such as a premium adjustment provision), we will retain any fee we have charged you. We will also retain commission depending on our arrangements with the insurer, or charge you a cancellation fee equal to the reduction in our commission.


When you pay us your premium, it will be banked into our trust account. We retain the commission from the premium you pay us and remit the balance to the insurer in accordance with our arrangements with the insurer. We will earn interest on the premium while it is in our trust account or we may invest the premium and earn a return. We will retain any interest or return on investment earned on the premium you pay us and remit the balance to the insurer in accordance with Carollo Horton & Associates Pty Ltd’s arrangements with the insurer.


How are any commissions, fees or other benefits calculated for providing the financial services?

Our commission will be calculated based on the following formula:

X = Y% x P

In this formula:

X = Our commission

Y% = the percentage commission paid to us by the insurer. Our commission varies between 0 and 30%.

P = the amount you pay for any insurance policy (less any government fees or charges included in that amount).


Any fees that we charge you will be disclosed on the Tax Invoice. We do not often pay any commissions, fees or benefits to others who refer you to us or refer us to an insurer. If we do, we will pay commissions to those people out of its commission or fees (not in addition to those amounts), in the range of 0 to 50% of its commission or fees.


Our employees that will assist you with your insurance needs will be paid a market salary, performance bonus or share of the commission and fees from 0 – 50%.


If we give you personal advice, we will inform you of any fees, commission or other payments we, my/our associates or anyone referring you to us (or me/us to any insurer) will receive in relation to the policies that are the subject of the advice.


See below for information on our association and commission.


Do you have any relationships or associations with the insurers who issue the insurance policies or any other material relationships?

Carollo Horton & Associates Pty Ltd is a Steadfast Group Limited (Steadfast) Network Broker. Steadfast has exclusive arrangements with some insurers and premium funders (Partners) under which Steadfast will receive between 0 – 1.5% commission for each product arranged by Steadfast Group Ltd’s network members with those Partners.


We may receive a proportion of that commission from Steadfast at the end of each financial year (or other agreed period). As a Steadfast Network Broker we have access to member services including model operating and compliance tools, procedures, manuals and training, legal, technical, banking and recruitment advice and assistance, group insurance arrangements, product comparison and placement support, claims support and group purchasing arrangements. These member services are either funded by Steadfast, subsidised by Steadfast or available exclusively to Steadfast Network Brokers for a fee.


You can obtain a copy of Steadfast’s FSG at


If we arrange premium funding for you we may be paid a commission by the premium funder. We may also charge you a fee (or both). The commission that we are paid by the premium funder is usually calculated as a percentage of your insurance premium (including government fees or changes). If you instruct us to arrange or issue a product, this is when we become entitled to the commission.


Our commission rates for premium funding are in the range of NIL to 5% of funded premium. When we arrange premium funding for you, you can ask us what commission rates we are paid for that funding arrangement compared to the other arrangements that were available to you. The amount of our commission and any fee that we charge will be set out in the premium funding contract.


What should I do if I have a complaint?

1. Contact Carollo Horton and Associates Pty Ltd at the address noted at the beginning of this FSG and tell us about your complaint. We will do our best to resolve it quickly.


2. Carollo Horton & Associates Pty Ltd is a member of the Australian Financial Complaints Authority (AFCA). If your complaint cannot be resolved to your satisfaction by us, you have the right to refer the matter to the AFCA. AFCA can be contacted at:

Mailing address – Australian Financial Complaints Authority, GPO Box 3, Melbourne, VIC 3001

Ph – 1800 931 678

Fax – 03 9613 6399

Email –

Website –


What arrangements are in place to compensate clients for losses?

Carollo Horton and Associates Pty Ltd has a professional indemnity insurance policy (PI policy) in place.


The PI policy in place covers us (and our employees) for claims made against us (or our employees) as a result of conduct in the provision of financial services. The PI policy cover us for claims relating to the conduct of former representatives/employees who no longer work for us.


Any questions?

If you have any further questions about the financial services Carollo Horton and Associates Pty Ltd, please contact us. Please retain this document for your reference and any future dealings with Carollo Horton and Associates Pty Ltd.