This statement sets out the Carthona policies on dealing with personal information. We recognise the importance of your privacy and understand your concerns about the security of your personal information. We are committed to protecting any personal information about you that we hold.
Application of privacy laws
From 12 March 2014, most private sector organisations in Australia must by law comply with the Australian Privacy Principles (APPs) arising from the Privacy Amendment (Enhancing Privacy Protection) Act 2012. We are bound by the APPs.
Collecting personal information
We only collect personal information that is necessary for us to perform our functions, to develop and promote our services and to assist us with complying with our legal and regulatory obligations.
We collect personal information from our clients such as your name, address, contact details and other information we think is necessary to provide the service that has been requested by you. We may also collect financial details such as tax file numbers and credit related information. We do not collect sensitive information.
We may also collect personal information about individuals seeking employment with Carthona.
This may include name, address, contact details, curriculum vitae and tax file numbers. If you are unsuccessful in your application, your personal information provided in conjunction with your job application interest will be destroyed immediately. However, interview notes of unsuccessful candidates are held for 12 months and then subsequently destroyed.
Methods of collecting personal information
We may collect your personal information when you fill out a form with us, when you’ve given us a call or used our websites. Your use of the website will determine the amount and type of information which we collect about you. Some of this information will not be personal because it will not reveal your identity. The only personal information which we collect about you when you use our website is what you provide voluntarily, for example, by sending a curriculum vitae if you are applying for employment with us or by sending us an email or by requesting to become an investor.
We will record your email address if you send us an email.
While we take great care to protect your personal information on our website or sent via email, unfortunately no data transmission over the Internet can be guaranteed to be 100 per cent secure.
Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of guaranteeing that information is protected in transit. Once we receive your information, we make our best effort to ensure its security in our possession. If you are concerned about providing sensitive or confidential information online, you may prefer to contact us by telephone or mail.
We may also collect your personal information indirectly from third parties for the purposes of providing our services to you. These third parties may include:
- Financial planners;
- Lawyers; and
- Other AFSL holders
Like many websites, when you visit our website our server may attach a small data file known as a “cookie” to your hard drive.
Use of personal information
We may use the personal information we collect:
- To meet your or your company’s requests;
- To provide our services;
- To obtain your products and services;
- To maintain our relationships with you;
- For research, planning, service development, security or risk management;
- To the extent that we are required or authorised by law to do so; and
- For purposes related to the above.
Disclosure of Personal Information
To make sure we can meet your specific needs and for the purposes described in ‘Use of your personal information’, we may need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.
We may disclose your personal information to third parties, including:
- Other AFSL holders that act as a trustee or custodian, or responsible entity in respect of our transactions; and
- Fund accounting, tax and legal consultants as required, to complete compliance reporting, to the extent that a client is an investor.
We may disclose your personal information to our database provider which may host our information in the US. In those circumstances we will take reasonable steps to ensure that they are committed to protecting your privacy and comply with a law or scheme which has the same or similar effect as the Australian Privacy Principles.
Security, accuracy and storage of your personal information
Irrespective of whether personal information is stored electronically or in hard copy form, we take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorized access, modification or disclosure.
It is important that we use only your correct information, as such we would ask that if you find our information to be out-of-date or inaccurate could you please advise us, using the “contact details” set out below, so that corrections can be made.
Other websites linked to our site
From time to time our website may provide links to third party websites or third party websites may link to our website. These linked sites are not under our control and we are not responsible for the conduct of companies linked to our website. Before disclosing your personal information to any other website, you should examine the terms and conditions for using these websites and the privacy policies applicable.
Feedback, Queries and Complaints
Carthona has established an internal process for handling customer feedback, queries and complaints (including matters involving compliance with privacy laws). This resolution mechanism is designed to be fair and timely to all parties and is free of charge. If you have a query about
Carthona’s handling of your personal information, you should submit it in writing to the address specified below. You will typically receive a letter from us within seven days which sets out an overview of how your query will be responded to. We aim to resolve your query within 28 days of receipt.
If you have any questions or feedback about privacy, or the way in which we handle your personal information or if you wish to access any personal information you may contact us in the following way:
Carthona Capital FS Pty Ltd
Suite 1 Level 15
1 Alfred St
Sydney NSW 2000
Telephone: +61 2 8072 0621
Carthona Capital FS Pty Ltd ABN: 78 600 937 933