Privacy Policy 

Why we need to collect your information

We collect your personal information to comply with the ‘Customer Due Diligence’
requirements in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
(AML/CTF Act). We have various AML/CTF obligations under that Act which may require us
to collect, hold, use and disclose your personal information. Our collection and use of
personal information for the purposes of AML/CTF only is subject to the Privacy Act 1988
(Cth) and the Australian Privacy Principles.

This includes obligations to:

• Establish and verify your identity before providing certain services to you or the

person you are acting on behalf of;

• Assess and manage potential money laundering, terrorism financing, proliferation

financing risks or related compliance risks associated with the provision of our
services;

• make reports required by law under the AML/CTF Act; and

• meet record keeping obligations under the AML/CTF Act.

What personal information we collect

We may collect the following types of information for Customer Due Diligence, for example:

• Your full name, date of birth, and residential address;

• photo identification and unique identifier, such as a passport or driver’s licence number; and 

• bank details including account name, BSB and account numbers and proof of transactions.

We also collect the following sensitive information:

• Whether you are a member of any political associations, professional or trade associations;

• criminal records; and

• other information including sanctions lists and media reports to determine whether you are a politically exposed person.

How we collect your information

The information collected is held on our systems and physically in our files and safe custody, where appropriate.

We will generally collect your personal information:

• When you interact with us, such as email address or phone number and other

information that you use to contact us;

• when we request it and you give it to us; and

• through third parties that supply information.

Who we may share your information with

We usually disclose information to third parties to assist with our AML/CTF obligations and Customer Due Diligence obligations including identity verification and storage. We may also share your personal information with AUSTRAC to meet our legal and regulatory obligations under the AML/CTF Act or the AML/CTF Rules and as otherwise permitted or required by law.

What happens if we cannot collect your information

If you do not provide us with your personal information, we may not be able to verify your identity and provide you (or the person you are acting on behalf of) with the services you have requested.

Your privacy rights

You may contact us to inquire about access to the personal information about you that we hold and you may ask us to correct such information. You may also contact us to complain about a breach of the Australian Privacy Principles and we will investigate that complaint as soon as reasonably possible.

We are not likely to disclose your personal information to overseas recipients. Whilst we endeavour to use Australian service providers and keep your information held in Australia, given the way online services and software may be distributed (such as cloud computing architecture and email service providers), we cannot guarantee that your information will stay solely in Australia.