Section A – Introduction
1. Summary
1.1
Protecting your privacy and keeping your personal information confidential is very important to us. This Privacy Policy (“Policy”) sets out how we collect and manage your personal and sensitive information, in compliance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”).
1.2
In this Policy, we use the terms “we” “us” “our” or “Arconomy” to refer to Arconomy Ventures Pty Limited and its related companies.
1.3
Personal information is any information or opinion about you that is capable (or reasonably capable) of identifying you, whether the information or opinion is true or not, and regardless of whether the information is recorded in a material form.
1.4
Sensitive information includes things like your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or criminal record. Your health, genetic and biometric information and biometric templates are also sensitive information. Sensitive information is also personal information for the purposes of the Privacy Act.
1.5
We collect personal and/or sensitive information to provide you with the products and
services that you ask for, as well as information about products and services offered by us
or third parties.
1.6
We may use your personal and/or sensitive information to administer our products and
services, for prudential and risk management purposes and, unless you tell us otherwise, to
provide you with related marketing information. We also use the information we hold to help
detect and prevent illegal activity. We cooperate with police and other enforcement bodies
as required by law.
1.7
We disclose relevant personal information to external organisations that help us provide
services. These organisations are bound by confidentiality arrangements. They may include
overseas organisations.
1.8
You can seek access to the personal information we hold about you. If the information we
hold about you is inaccurate, incomplete, or outdated, please let us know so that we can
correct it. If we deny access to your personal information, we’ll let you know the reason why.
For example, we may give an explanation of a commercially sensitive decision, or give you
access to the information through a mutually agreed intermediary, rather than provide you
with direct access to evaluative information connected with the decision.
Section B – Collection of Personal Information
2. We collect your personal information
2.1
We only collect personal information when it’s reasonably necessary for us to do business
with you.
2.2
We use your personal information to:
(a) verify your identity;
(b) provide you with the products and services that you’ve asked for;
(c) help us monitor, evaluate and develop our products and services;
(d) enable secure access to our client area;
(e) unless you tell us otherwise, keep you informed about our products and services and
those of our relevant business and initiative partners, and tailor this information to your
needs and interests;
(f) respond to any feedback, queries or complaints;
(g) provide you with technical support;
(h) participate in any third party acquisition or potential acquisition of an interest in us or
our assets;
(i) comply with our legal obligations under the applicable laws; and
(j) take measures to detect and prevent fraud, crime or other activity which may cause harm to our business or our products and services.
3. Information we may collect
Due to the nature of the financial products and services provided, government regulations and taxation laws, we ask for personal information from our clients.
3.1
The personal information we may collect can include (but may not be limited to):
(a) name;
(b) date of birth;
(c) postal or email address; or
(d) phone numbers, including home, mobile and work;
(e) fax number;
(f) information relating to an individual’s source of wealth;
(g) occupation;
(h) credit card details;4
(i) bank account details, including institution name, branch, account name, bank identifier,
and account number or IBAN;
(j) information relating to your trading experience;
(k) identification documentation, as required under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (“AML/CTF Act”), including: passport, driver’s licence, national identity card; utility bills, trust deed, a Veda Check or other credit or bankruptcy check; and/or other information we consider necessary to our functions and activities.
3.2
Where necessary, we also collect information on the following individuals:
(a) trustees;
(b) partners;
(c) company directors and officers;
(d) officers of co-operatives and associations;
(e) client’s agents;
(f) beneficial owners of the client; and
(g) persons dealing with us on a “one-off” basis.
3.4
We may take steps to verify the information we collect. For example, a birth certificate
provided as identification may be verified with records held by the Registry of Births, Deaths
and Marriages to protect against impersonation, or we may verify with an employer that
employment and remuneration information provided in a credit application is accurate.
4. How we collect personal information
4.1
We may either collect personal information about you directly from you or from sources
other than you when permitted under the AML/CTF Act. “Sources other than you” may
include your agents, family members, friends, related entities, affiliates or divisions.
4.2
We may also collect information from you electronically, for instance, when you visit our website.
5. Incomplete or inaccurate information
5.1
If you provide us with incomplete or inaccurate information, we may not be able to provide
you with the products or services that you ask for.
6. Incomplete or inaccurate information
6.1
In most cases, we’ll obtain your consent to use and disclose your personal information for
our intended purposes either before or at the time that we collect it.
6.2
If you don’t give us your consent or withdraw your consent, we may not be able to provide
you with the products or services you ask for.
7. Withdrawing Consent
7.1
You can withdraw your consent at any time. To withdraw your consent, please email
contact@arconomy.digital.
8. Sensitive information
8.1
We’ll only collect sensitive information about you if we have your consent, or if we’re
required or authorised by law.
9. Aggregated Data
9.1
Aggregated data is general data about groups of people which doesn’t identify anyone personally, for example the number of people in a particular industry that engage in forex trading. We use aggregated data to:
(a) help us to understand how you use our products and services and improve your experience with us; and
(b) customise the way that we communicate with you about our products and services so that we can interact with you more effectively.
9.2
We may share aggregated data with our business or industry partners
10. Anonymity and pseudonymity
10.1
In certain situations we may be able to give you the option of using a pseudonym or remain
anonymous when you deal with us. We’re only able to provide you with this option when it’s
practical for us to do so, and if we’re not required by law to identify you.
11. Dealing with unsolicited personal information
11.1
If we receive personal information about you that we haven’t ask for, we’ll only retain it if we determine that:
(a) the information received is reasonably necessary for us to do business with you; and
(b) you’ve either consented to the information being collected, or it wasn’t practical or reasonable for us to obtain your consent in the circumstances.
Section C – Integrity of Your personal information
12. Quality of personal information
12.1
We ensure that the personal information we collect and handle is accurate, up to date,
complete and relevant.
12.2
Please contact us if any of the details you have provided to us change or if you believe that
the information we have about you isn’t accurate or up to date.
12.3
We may also take steps to update the personal information we hold, for example, an
address, by collecting personal information from publicly available sources such as
telephone directories or electoral rolls.
13. Security of personal information
13.1
We’re committed to protecting the personal information we hold about you from misuse,
unauthorised access and disclosure.
13.2
We’ve implemented a range of practices and policies to provide a robust security
environment. We ensure the on-going adequacy of these measures by regularly reviewing
them.
13.3
Our security measures include:
(a) educating our employees about their obligations when they collect and handle personal information;
(b) requiring our employees to use passwords when accessing our systems;
(c) encrypting data sent from your computer to our systems during internet transactions and client access codes transmitted across networks;
(d) employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
(e) using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
(f) practising a clean desk policy for all premises and providing secure storage for physical records; and
(g) employing physical and electronic security measures such as swipe cards, alarms, cameras and guards (as required) to protect against unauthorised access to buildings.
13.4
Where we identify that we no longer need certain personal information, we ensure that it’s
effectively and securely destroyed. For example, we may shred paper records or use other
means such as degaussing (de-magnetism of a device) and deletion in the case of
electronic equipment and records.
Section D – Use or Disclosure of personal information
14. Who we disclose personal information to
14.1
We may share your information with our related entities and third parties that we outsource
functions to or partner with, in certain limited situations where it’s necessary for us to
provide our products and services or perform associated business activities.
14.2
These entities and third parties include:
(a) brokers and agents who refer your business to us;
(b) our third party business partners or joint initiative providers;
(c) auditors we appoint to ensure the integrity of our operations;
(d) any person acting on your behalf, including your financial adviser, solicitor, settlement agent, accountant, executor, administrator, trustee, guardian or attorney;
(e) your employment referee (to confirm details about you);
(f) if required or authorised to do so, regulatory bodies and government agencies;
(g) credit reporting agencies;
(h) other financial institutions and organisations that you seek credit from them (at their request, so that they may assess whether to offer you credit); and
(i) other organisations who assist us to provide products and services by performing functions such as client contact, banking, payments, data processing, debt recovery, marketing and advertising, data analysis, business intelligence, website and technology services. They may also provide products and services that integrate with or complement our products and services.
14.3
We take our obligations to protect your information extremely seriously and make every
effort to deal only with parties who share and demonstrate the same attitude. Each of the
third parties that we contract with is carefully selected and is only authorised to use your
personal information in a secure way, that’s necessary for them to perform their services to
us.
15. Disclosure required by law
15.1
We’ll also disclose your personal information if we’re required by law or permitted to do so
under the Privacy Act.
Section E – Direct Marketing
16. Direct Marketing
16.1
Unless you’ve asked us not to, we may use your personal information to let you know about
new or improved products and services and special offers that may be of interest to you.
16.2
If you don’t want us to use your personal information for marketing purposes, please send an email to contact@arconomy.digital
Section F – Cookies
17. What is a cookie
17.1
A cookie is a small file which asks permission to be placed on your computer’s hard drive. If
your computer settings allow cookies, then the file is added and the cookie helps analyse
web traffic or lets the site owner know when you visit a particular site.
18. Why we use cookies
18.1
Cookies help us provide you with a better website by enabling us to monitor the pages that
you find useful and tailor our website to your needs, likes and dislikes by gathering and
remembering information about your preferences.
18.2
We may collect information about your computer, including where available your IP address,
operating system and browser type, for system administration. This is statistical data about
your browsing actions and patterns, and doesn’t identify you or anyone else as an individual.
18.3
We may disclose the data we collect through cookies to our related companies.
19. How to block cookies
19.1
Most web browsers allow you to adjust settings to erase cookies, disallow cookies, or
receive a warning before a cookie is set. Please note that some parts of our websites may
not function fully if you disallow cookies.
Section G – Adoption, use or disclosure of government related identifiers
21.1
We won’t adopt a government related identifier (such as your Medicare or driver’s license
number) as our own identifier unless required or authorised to do so under an Australian
law, regulation or court/tribunal order.
21.2
Before using or disclosing a government related identifier, we’ll ensure that such use or disclosure is:
(a) reasonably necessary for us to verify your identity for the purposes of doing business with you; or
(b) reasonably necessary for us to fulfil our obligations to a government agency or a State or Territory authority; or
(c) required by or authorised under an Australian law, regulation or a court/tribunal order; or
(d) within a permitted general situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) of the Privacy Act; or
(e) reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
Section H – Access to, correction and erasure of personal information
22 Access, correction and erasure
If you’ve provided us with personal information, you have the right to request to access or
correct it.
22.1
You may also at any time contact us to request erasure of your personal data. Please
note that for legal reasons we might not always be able to comply with these requests.
We’ll let you know if this is the case when you make your request. Please write to Head of Compliance using contact@arconomy.digital.
22.2
Requests for access to or correct limited amounts of personal information, such as
checking to see what address or telephone number we have recorded, can generally be
handled over the phone.
22.3
We’ll respond to your request as soon as we’re able to. In some cases we may ask you to
pay an administrative fee to cover costs associated with your request. We’ll confirm the cost
with you and confirm that you want to proceed before actioning your request.
22.4
We’ll endeavour to comply with your request within 30 days of hearing from you. To help us
respond, please include as much detail as possible about the information that you want to
access or correct and, if relevant, how you’d like to access the information.
22.5
We’ll always confirm your identity before providing you with access to your personal
information.
23 Exceptions and refusal to give access, correct or erasure
23.1
In some circumstances we might have to deny your request for access correction, or erasure, or limit the access we provide. In either of these situations, we’ll let you know the reasons for our decision in writing. If you disagree with our decision, you can make a complaint following the process set out in section I of this Policy.
Section J – Complaints
24 Contact Us
24. 1
If you have any questions or would like further information about our privacy and information handling practices, please contact us in writing via email: contact@arconomy.digital
24.2
Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information. The Commissioner can
be contacted at:
(a) Postal address: GPO Box 5218, Sydney New South Wales 2001
(b) Phone: 1300 363 992
(c) Email: enquiries@oaic.gov.au
(d) Website: www.oaic.gov.au