This Privacy Policy (‘Policy’) explains how we collect, use, manage and disclose Personal Information and how you can contact us if you have queries about our management of your Personal Information.
It is intended to ensure that individuals outside of our organisation with whom we interact, including visitors to our website, clients, potential clients, personnel of service providers or other suppliers and others who interact with us are:
- aware of the types of Personal Information about them that Aequitas Holdings Pty Ltd ACN 156 672 294 and its subsidiaries (‘we’, ‘us’ or ‘our’) may collect, how we collect it, what we use it for and with whom we share it; and
- protected under Australian law in accordance with the Australian Privacy Principles (‘APPs’) in the Privacy Act 1988 (Cth) (‘Privacy Act’) and any other relevant laws.
Words defined in the Privacy Act have the same meaning when used in this policy.
Aequitas collects Personal Information
When we refer to Personal Information, we mean information from which your identity is reasonably apparent.
The kinds of Personal Information we collect about you will depend on how you interact with us:
When you use our website: We collect general site traffic data for the purpose of site maintenance and improvement and understanding which and how often certain pages are viewed. While this data is generally anonymous, we may collect your IP address, approximate geographic location and data sent to us by your web browser, such as your operating system. Please refer to the ‘Advertising and tracking’ and ‘Cookies’ sections below for further information.
If you engage with our products and services: In the course of providing products and services we may collect and hold information that is reasonably necessary for the performance of our functions and activities, including maintaining a registry of investor details and other functions. This information may include, but is not limited to:
- names, addresses and other contact details;
- date of birth;
- financial information;
- nationality and country of birth;
- data required for AML/CTF purposes; and
- government identifiers (such as TFN where necessary and relevant).
Where it is lawful and practicable to do so, you may remain anonymous in your dealings with us.
If you provide the Personal Information of another person in any correspondence with us, you warrant that that person has consented to the collection of their Personal Information for the reasons it is being collected.
You can always choose not to provide your Personal Information to Aequitas, but it may mean that we are unable to provide you with our products and services.
Aequitas may collect sensitive information
Sensitive Information is a sub-set of Personal Information that is given a higher level of protection under the APPs. “Sensitive information” is information that relates to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices and criminal records, health information or biometric information.
The types of Sensitive Information that we may collect or receive include health information, membership of a professional or trade association or trade union, religious beliefs or affiliations, information on philosophical beliefs, information on sexual orientation or practices and information regarding your criminal record, including police checks if applicable.
How we collect Personal Information
We collect Personal Information in a variety of ways. We mainly collect information from you when you knowingly provide it to us including via signing up or contacting us on our website or by completing an application form for one of our products.
We also collect Personal Information from our suppliers and resellers when they provide it to us as part of our commercial agreements.
We may also collect Personal Information about you from your representatives, including your spouse, business partner or professional adviser (where it is reasonable and practical to do so).
Aequitas collects, holds, and uses your Personal Information for limited purposes
We collect, hold, use and disclose Personal Information about individuals when it is necessary for us to carry on our business functions or to comply with laws.
Specifically, we may collect, hold, use and disclose your Personal Information to answer your enquiry or to provide the information or service that you have requested. We may also collect, hold, use or disclose your Personal Information to:
- enable us to develop, administer and manage our services and business;
- verify your identity,
- administer our services,
- customise service to better meet your needs and preferences;
- notify you of new or changed services offered in relation to those services,
- carry out marketing or training relating to our services,
- comply with laws and regulations in applicable jurisdictions, and
- communicate with you (including to deal with complaints, queries or feedback).
By providing us with your Personal Information, you consent to your Personal and/or Sensitive Information being collected, held and used in this way and for any other use you authorise. Aequitas will only use your Personal Information for the purposes described in this Policy or with your express permission.
Direct Marketing
We will not use or disclose Personal Information about you for direct marketing purposes unless you have consented to that kind of use or disclosure.
We may use your Personal Information for direct marketing purposes. Our emails will contain clear and obvious instructions describing how you can choose to be removed from any mailing list not essential to the services we provide to you. Aequitas will remove you at your request.
Advertising and tracking
Our website may contain links to the websites of non-affiliated third-parties (‘Third Party websites’).
Where you access a Third Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
When you view our advertisements on a Third Party website, the advertising company may use ‘cookies’ and in some cases ‘web beacons’ to collect information on you such as:
- the server your computer is logged onto;
- your browser type;
- the date and time of your visit; and
- the performance of their marketing efforts.
When you access our website after viewing one of our advertisements on a Third Party website, the advertising company may collect information on how you utilise our website (e.g. which pages you view) and whether you complete an online application.
Cookies
We use ‘cookies’ to provide you with better and more customised service and with a more effective website. When you access our website, you consent to our use of cookies as described in this policy.
A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser.
We use cookies for different purposes such as:
- to allocate a unique number to your internet browsers;
- to customise our website for you;
- for statistical purposes;
- to identify if you have accessed a Third Party website; and
- for security purposes.
Security of information
Aequitas is committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. If we no longer require your information, and we are legally permitted to, we will take all reasonable steps to destroy or de-identify the information.
We take reasonable steps to preserve the security of cookie and Personal Information in accordance with this policy. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).
We will advise you at the first reasonable opportunity upon discovering or being advised of a security breach where your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner.
Do we disclose your Personal Information?
In the course of conducting our business we may provide your Personal Information to:
- our related companies;
- employees, contractors and subcontractors;
- government and regulatory authorities; and
- our professional advisers, including our lawyers, auditors and accountants.
We may disclose your Personal Information to third parties:
- to meet the purpose for which it was submitted;
- if we have your consent to do so or otherwise when we are authorised by law; or
- if we are required by law to disclose the information.
We may disclose your Personal Information to our subcontractors or consultants when we engage third party service providers to undertake works as part of our service delivery to our customers.
Overseas recipients
We do not generally disclose your Personal Information to overseas entities in the course of our activities. However, we may disclose your Personal Information to overseas recipients where the overseas recipient provides services to us, such as SaaS (software as a service) or cloud-based storage solutions.
The countries in which such recipients are located will depend on the nature of the services being provided by us and the particular matter involved. We will, where practicable, advise you of the countries in which overseas recipients are likely to be located.
Please note that the use of overseas service providers to store Personal Information will not always involve a disclosure of Personal Information to that overseas provider. However, by providing us with your Personal Information, you consent to the storage of such information on overseas servers and you acknowledge and agree that APP 8.1 will not apply to the extent that such storage constitutes a cross-border disclosure.
Updating your Personal Information
It is important to us that the Personal Information we hold about you is accurate and up to date and it is your responsibility to ensure that remains the case at all times. During the course of our relationship with you we may ask you to inform us if any of your Personal Information has changed.
If you wish to make any changes to your Personal Information, you can do so by contacting us using one of the methods set out below. We will generally rely on you to ensure the information we hold about you is accurate or complete.
We will correct your Personal Information at the time of your request if appropriate. Otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the Personal Information within 30 days.
Access and correction to your Personal Information
We will provide you with access to the Personal Information we hold about you. You may request access to any of the Personal Information we hold about you at any time. We may charge an administrative fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your Personal Information, for example, where the information is stored on another entity’s server and we do not have access to it, if the information relates to existing or anticipated legal proceedings, if your request is vexatious or if the information is commercially sensitive.
An explanation will be provided to you if we deny you access to the Personal Information we hold about you. If we refuse to correct Personal Information we will provide you with our reasons for not correcting the information.
We may require you to provide proof of or verify your identity if you want to access or correct your Personal Information that we hold. This verification of identity may occur over the phone, by email, video call or in person.
Complaints
We are committed to the protection of your privacy and Personal Information. Complaints you may have about your Personal Information can be lodged with us by using the contact details below.
We will attempt to resolve any complaints within 10 working days. If resolution is not possible within this timeframe we will contact you to discuss the matter further.
You also have the right under the Privacy Act to make a complaint to the Information Commissioner.
Changes to this policy
This policy is subject to change over time without prior notice. We may amend this policy by updating this posting.
Copies of this policy
You can ask us to provide you with a copy of this policy, including a hard copy, by contacting us using the contact details above.
Privacy Officer
Aequitas Holdings Pty Ltd
1/283 Elizabeth Street
Brisbane QLD 4000 Australia
E megan.macdonald@aequitasgroup.com.au