Privacy Policy

Your personal information will be collected and used by Oli in accordance with its Privacy Policy. Oli Capital Pty Ltd (hereinafter “We”) has instituted this Privacy Policy (hereinafter “this Policy/this Privacy Policy”) and hereby reminded you of:

 

This policy applies to products or services provided by Oli Capital Pty Ltd. If our affiliates use products or services provided by Oli Capital Pty Ltd without an independent legal declaration or privacy policy, this policy shall also apply to such products or services. We understand your concerns about privacy and the security of your personal information. Your privacy is important to us and we are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”). We are committed to protecting the personal information that we hold about you.

1. What personal information is collected?

We only collect personal information that is reasonably necessary to provide financial services and management to our customers, which may include individuals ("you" or "your") related to these customers (for example, company directors). The types of personal information we collect and hold will depend on the types of services our customers request from us, which may include:

  • Your name, date of birth, address, contact information and relevant identification documents;

  • Communication between our asset advisors, custodians, legal or other advisors (including their brokers or other agents);

  • Transaction information about the use of the service; and

  • We collect sensitive information where required by law (for example, to verify your identity).

2. How do we use your personal information?

Your personal information may be processed, used or transferred for purposes related to our business, including:

  • Manage service provision between us, including but not limited to billing, internal reporting and analysis, and any other auxiliary matters;

  • Comply with the information required by or disclosed to regulatory agencies, governments, agencies or organizations;

  • Get advice, accept services or provide information to third parties about matters that may affect Oli Capital;

  • Provide you with information about products and services that we think will be of interest;

  • Comply with any requirements or good practices of laws, regulations, associations, voluntary codes we decide to adopt anywhere in the world;

  • Confirm and verify your identity (this may involve the use of credit consulting agencies or other third parties as our agents) and conduct due diligence, including "know your customer" checks and other procedures we take before you become us customers . We may also block public government and/or law enforcement agency sanctions lists;

  • Discover, investigate and prevent fraud and other crimes or malfeasance. To obtain legal opinions or establish, exercise or defend legal rights for the purpose of or related to any legal process (including future legal process); and

  • In the course of our legal financial services business activities, any other purpose incidental to or directly related to the above purpose.

If you do not wish to provide personal information for any of the purposes listed above (except for the purpose of providing you with marketing information), we will not be able to provide you with financial services.

In order to provide you with marketing information related to our products or services in the investment management business, you voluntarily provide us with personal information.

3. What if you do not provide certain information?

If the application you provide to us is incomplete, we may not be able to serve our customers until the application is complete.

 

If you do not provide us with all relevant identity verification documents, or do not fully meet the electronic identity verification requirements, we may not be able to provide services to our customers, or continue to provide services to them.

If you choose not to disclose your details or answer the verification question correctly, we may not be able to process the transaction requested by the customer.

4. Use and disclosure of your personal information

We may collect, use and disclose your personal information for the main purpose of providing services requested by customers and related purposes, including:

  • Verify your identity or transactions that our customers may enter into with us;

  • Process customer service applications;

  • Manage and manage the services we provide;

  • Respond to inquiries, complaints or provide our general customer service to you or our customers;

  • Provide your asset advisors, custodians, legal or other advisors with detailed information about your investment;

  • Provide you with quotations for our other services, and improve and personalize our services;

  • Compliance with legal and regulatory requirements, including anti-money laundering, financial services and tax laws, or compliance with any requirements of government agencies in legal procedures or prevention or detection of fraud and crime;

  • Comply with our risk management policies and procedures;

  • Conduct product and market research;

  • Train our employees; or

  • If you attend our office in person, to help us provide a safe environment for employees and visitors.

We may disclose your personal information to:

  • Your asset advisor, custodian, legal or other advisor, including your broker or other agent;

  • Professional service companies that provide services to us, such as legal and audit services or data or information services;

  • Our affiliates; or

  • Otherwise follow this policy.

5. Will your personal information be given to anyone else?

We will not sell, rent or trade personal information to or with others. Personal information collected by us may be disclosed within the Oli Capital and third parties to whom we outsource specialised functions (such as our registry, mailing houses or printing companies), and if so, we take steps to ensure that those parties:

  • do not breach the APPs when they handle personal information (regardless of whether they are a small business, and would otherwise be exempt from the APPs); and

  • are authorised only to use personal information in order to provide the services or to perform the functions required by us.

The only other time we would make disclosures of personal information is to your representative, if we are required to do so by law, or if the disclosure is permitted under the Privacy Act. We are unlikely to disclose information to any overseas entity, however if we do, we will comply with the requirements set out above.

6. How will we protect your personal information?

Whether your personal information is collected through face-to-face meetings or interacted with us via phone, mail, Internet or other means, we will take steps to store your information securely. We store your personal information in a combination of secure computer systems, storage devices, paper documents and other formats. We have taken many measures to protect personal information from misuse, loss, unauthorised access, modification or improper disclosure. This includes instructing staff handling personal information to respect the confidentiality and privacy of personal information.

7. Access and correction

Generally, unless there are special exceptions, we will provide you with access to personal information that you have, such as:

  • Providing information is illegal;

  • Providing access may prejudice the investigation of possible illegal activities;

  • This information is related to legal proceedings and will not be accessible during the normal discovery process;

  • Providing access rights will have an unreasonable impact on the privacy of other individuals;

  • This will pose a serious and imminent threat to anyone’s life or health; or

  • Request boring or unreasonable trouble.

If the access request reveals a commercially sensitive decision-making process, then we may provide an explanation instead of directly accessing the information.

If we find that the personal information we hold about you is inaccurate, incomplete, misleading or irrelevant, then we will take reasonable steps to modify it. If we receive your request to correct your information, then we will seek correction within 30 days. If you and we disagree with the accuracy, completeness or timeliness of our records, then you have the right to ask us to record your disagreement with these records.

If you want to request an update or seek access to the personal information we hold about you, please see the Contact Us information.

8. Trans-border data flows

We do not disclose personal information to recipients in foreign countries.

9. Direct marketing

We will not use your personal information for direct marketing purposes unless:

  • We have obtained your consent, or you reasonably expect us to use your personal information for direct marketing purposes;

  • We provide you with an easy way to "quit" to accept direct marketing; and

  • We have not received your "opt-out" request.

We will not use any sensitive information collected from you for direct marketing purposes.

10. Complaints about your privacy

If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following:

  • Your complaint should be made in writing to the Privacy Officer (via post or email)

  • We will attempt to respond within 30 days from receipt of your request

  • The complaint may also be taken to the Office of the Australian Information Commissioner (OAIC)

For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email enquiries@oaic.gov.au.  

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ABN: 88 627 780 590

AFSL Rep Number: ​001281917

© 2020 Oli Capital