2. What information do we collect and how do we use it?
a) We only collect personal information that is necessary for us to carry out our obligations arising from any contracts entered into between you and us. The personal information Henslow has collected from you as a client is necessary for one or more of our services or activities provided to you. This can include a broad range of information ranging from but not limited to:
- your name
- contact details
- date of birth
- your email address
- your tax file number
- details of your annual income, expenditure and employment
- details of your assets and liabilities
- details of any securities or investments you have given us
- details of your associated bank accounts
- details of specific transactions
- details of your investment objectives and risk profile
- any other information we require to satisfy our obligations under relevant legislation
b) We may provide the information that you provide to us to:
- related companies of Henslow for the purpose of marketing new investment opportunities to you;
- the Australian Stock Exchange, Broking House, Options clearing House, Fund Managers, Insurers, Share Registries and other product providers to establish accounts on your behalf or to process transactions;
- our bank, when depositing funds to your account;
- outsourcing organisations contracted by Henslow to provide administrative functions on our behalf, for example IT contractors providing maintenance of our data systems.
c) We also use your information to enable us to manage your ongoing requirements and our relationship with you. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
d) We may also use your information internally to help us improve our services and help resolve any problems.
3. What if you don’t provide some information to us?
If you choose not to provide us with some or all of the information that we ask for, we may not be able to offer particular services to you.
4. How do we hold and protect your information?
We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We hold the information we collect from you electronically on our Office 365 management system and in hard copy files. In some cases, your file is archived and sent to an external data storage provider for a period of time. We only use storage providers in Australia who are also regulated by the Privacy Act.
We ensure that your information is safe by restricting access to only our staff members that require the relevant access to your information. We maintain physical security over our paper and electronic data and premises, by using locks and security systems.
5. Web Data
5.1 Anonymous data
We use technology to collect anonymous information about the use of our website, for example when you browse our website our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes and to improve the content and functionality of our website, to better understand our clients and markets and to improve our services.
In order to collect this anonymous data we may use “cookies”. Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. Sometimes they identify users where the website requires information to be retained from one page to the next. This is purely to increase the functionality of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your computer and you can set your browser to notify you when you receive a cookie so that you can decide if you want to accept it. If you use only temporary cookies, insert “Once you leave the site, the cookie is destroyed and no personal or other information about you is stored.” If you use permanent cookies, insert “They allow the website to recognise your computer when you return in the future”.
6. Will we disclose the information we collect to anyone?
Henslow does not sell, trade, or rent your personal information to others or disclose it to overseas recipients. We may also disclose your information to governmental agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request, or under any and for the purposes of any guidelines issued by regulatory or other authorities, or similar processes as either required or permitted by applicable law.
We may also need to disclose your information to contractors who supply services to us, e.g. to handle mailings on our behalf, external data storage providers, auditors, lawyers, accountants or to other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event. However, we will take all reasonable steps to ensure that they protect your information in the same way that we do.
We may provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.
7. How can you check, update or change the information we are holding?
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete.
If you wish to access or correct your personal information please write to email@example.com
We do not charge for receiving a request for access to personal information or for complying with a correction request.
In some limited cases, we may need to refuse access to your information or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal.
8. What happens if you want to complain?
Your complaint will be considered by us through our internal complaints resolution process and we will try to respond with a decision within 45 days of you making the complaint.
9. Your consent
By asking us to assist with your matters in relation to any contracts entered into between you and us, you consent to the collection and use of the information you have provided to us for the purposes described above.
10. Tell us what you think
We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact us at firstname.lastname@example.org.