PRIVACY POLICY
XTON Investments Pty Ltd
ACN 642 977 482
AFSL 526479
1. Protection of Privacy
XTON Investments Pty Ltd ACN 642 977 482 (XTON Investments) considers you an important person and has implemented this policy about how it manages your personal information in compliance with section 15 of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (Privacy Policy).
2. Purpose
a. XTON Investments collects personal information to:
i.conduct business;
ii.provide and market our services;
iii. purchase goods and services;
iv. improve your experience with XTON Investments;
v. meet XTON Investments’s obligations to its clients;
vii. meet legislative requirements; and inform or sell to third parties, including telemarketers and data entry companies, for any purpose.
2. Personal Information
Types
a. XTON Investments collects the following types of personal information:
i. your name and details of your family members, friends, colleagues or associates;
ii. related contact details (street address, postal address, phone, fax, email);
iii. personal information such as nationalities, citizenship, dates of birth, tax file numbers, Australian Company Numbers and Australian Business Numbers;
iv. your employment status and related employment information such as your salary and employer;
v. your bank details such as your credit card number or account details;
vi. information relevant to the carriage of a matter you or another entity may have with XTON Investments; and
vii. any other information you may consider sensitive such as your race, religion, political memberships, sexual orientation, health information or criminal record).
Collection
b.XTON Investments only collects personal information through lawful and fair means for purposes that are reasonably necessary for one or more of XTON Investments’s functions or activities.
c. XTON Investments collects all information you provide to it when you communicate with XTON Investments, use XTON Investments’s website, use XTON Investments marketing material or enter into contracts with XTON Investments through email, post, phone, fax, in person or via our website (including through cookies).
d. XTON Investments will procure you to provide personal information to comply with legal requirements and may advise you of the risk of non-compliance if you do not disclose certain personal information for particular types of dealings associated with XTON Investments.
e. XTON Investments relies on you to ensure that the personal information you have provided about yourself or another person is accurate, up to date and complete as at the date you provide the information.
f. XTON Investments collects personal information from its related entities and uses that information for the same purpose that entity collected the personal information.
g. XTON Investments collects personal information that you made available to third parties, where you have consented to that information being shared.
h. XTON Investments collects personal information about you that you have made available publicly.
i. If XTON Investments receives personal information that it did not solicit, it will use the personal information for the purpose of determining if it can lawfully hold, use and disclose the personal information. If it determines that it is not lawfully able to do so, XTON Investments will de-identify or destroy the personal information.
Pseudonyms
j. You can use pseudonyms or fake names for making general, non-matter related enquiries.
k. If you are a client of XTON Investments, you must not use a pseudonym or fake name.
Third party information
l. Where you provide personal information about another person, XTON Investments will rely on you to seek the prior consent of that person to the disclosure being made in accordance with this Privacy Policy and to promptly notify that person about the disclosure. XTON Investments can use the contact details provided by you or reasonably available to XTON Investments to notify that person of the disclosure.
m. Where XTON Investments receives your personal information from a third party, it does so under the understanding that you have consented to the disclosure. If you do not consent to the disclosure, you may lodge a complaint with XTON Investments or seek to vary or delete the personal information from XTON Investments’s records.
Use and disclosure
n. XTON Investments can retain personal information for an indefinite period of time using any manner of internal and external storage facilities.
o. XTON Investments can disclose personal information to any person or entity within Australia or overseas:
i. for purposes consistent with this Privacy Policy and as reasonably necessary for one or more of XTON Investments’s functions or activities;
ii. as required by law, including government agencies or departments;
iii. for enforcement related activities;
iv. for direct marketing purposes (although you may opt out at any time);
v. to its related entities to use for the same purpose for which it was collected;
vi. if a permitted health situation arises; or
vii. if XTON Investments reasonably believes the use or disclosure is necessary to prevent or mitigate injury, loss or damage to person or property in the case of an emergency.
p. XTON Investments can disclose government related identifiers such as passport numbers or driver’s licence numbers if lawfully able to do so and if reasonably necessary for one or more of XTON Investments’s functions or activities.
q. XTON Investments will take appropriate measures to ensure that prior to disclosing personal information to an overseas entity, that the overseas entity complies with the Australian Privacy Principles.
4. Security
a. XTON Investments will take reasonable steps to protect the personal information from misuse and interference.
b. XTON Investments will not authorise the access, modification or disclosure of personal information in any manner that is inconsistent with this Privacy Policy.
c. Personal information that XTON Investments no longer requires, will be deidentified or destroyed.
5. Access and corrections
a. You may obtain further details or copies of your personal information held by XTON Investments upon payment of an administrative fee, which will be determined by XTON Investments having regard to the nature of the request. To do this you will need to send a written request to XTON Investments’s Privacy Department together with original certified copies of 100 points of your ID.
b. You may request corrections to your personal information, without charge. XTON Investments will process your request in accordance with the Australian Privacy Principles.
6. Privacy policy, complaints and contact details
a. You can access an up to date version of this Privacy Policy on our website (www.xtonwealth.com.au) or by making a request to XTON Investments.
b. If you are unhappy with XTON Investments’s use of your personal information you may lodge a complaint to XTON Investments’s Privacy Department and XTON Investments will respond as promptly as possible.
c. The contact details for XTON Investments’s Privacy Department are:
Pieter Eksteen
Director / Responsible Manager
PO Box 2050
Brisbane QLD 4000
(E) pete@xtonwealth.com
(P) 0423 409 135