Privacy Policy

We may change this Privacy Policy from time to time by publishing it on our website. Please revisit the policy periodically to ensure you are familiar with the current version.

What is personal information?

Personal information is any information or opinion about you that is reasonably capable of identifying you, whether true or not, and however recorded.

Kinds of personal information we collect and hold

The personal information we may collect, either directly from you or from third parties, includes:

• name, residential or postal address, email address, date of birth, telephone numbers
• identification documents (e.g. passport, driver’s licence) for identity verification
• occupation, employment history, and education history
• tax file numbers, tax residency status, and other government-issued identification numbers
• bank account details, shareholdings and investment details
• financial information you provide to us or authorise us to access
• Internet Protocol (IP) address when you use our website or electronic signing platforms (e.g. DocuSign)
• records of your interactions with us, and any other information you give us in the course of our dealings with you.

How we collect personal information

We may collect personal information directly from you when you:

• apply for a product or service
• submit electronic or hard-copy forms
• participate in a phone or video call with us
• email or otherwise correspond with us
• visit our website.
• We may also collect information about you from:
• your investment adviser
• our service providers
• regulator databases
• public sources such as websites.

Collection of sensitive information

Sensitive information includes details about racial or ethnic origin, political opinion, religious beliefs, trade union membership, sexual orientation, criminal record, or health information. We will not collect, use, or disclose sensitive information unless it is necessary for one of our functions or activities and we have your consent, or we are legally required to do so.

If you provide information about another person

If you provide us with personal information about another person, you must ensure that they have been notified and have consented to our collection, use and disclosure of that information as set out in this Privacy Policy.

Why we collect personal information

We collect personal information to provide our products and services, to meet our legal and regulatory obligations, and for purposes such as:

• compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act
• establishing tax residency status under international tax reporting obligations (e.g. FATCA and CRS)
• carrying out or facilitating client instructions and responding to client queries
• managing accounts, risk, systems testing, staff training, and market research
• managing complaints or disputes
• preventing or investigating fraud, unlawful activity or misconduct.

Who we disclose personal information to

We may disclose your personal information to:

• our service providers (on a confidential, use-restricted basis)
• your investment adviser
• our representatives and professional advisers, including lawyers and accountants
• auditors we appoint to ensure operational integrity
• financial institutions (for AML/CTF purposes)
• persons acting on your behalf (e.g. solicitor, trustee, executor, accountant, attorney)
• government agencies, regulators, and law enforcement bodies
• other organisations with whom we jointly provide products or services.

Direct marketing

We may use your personal details to send you newsletters and information about our products, services, or events. If you prefer not to receive such communications, you can opt-out at any time by contacting our Privacy Officer.

Overseas disclosures

Some of our technology and operational service providers may store or process information outside Australia. We will only engage such providers where we reasonably believe they are subject to legal or contractual obligations that provide protections equivalent to the Australian Privacy Principles.

Quality and retention of information

We will take reasonable steps to ensure your personal information is accurate, complete, and current. Where personal information is no longer required, we will take reasonable steps to securely destroy or de-identify it.

How we keep your information secure

We store personal information in both hardcopy and electronic form. Safeguards include:

• staff training on privacy obligations
• password protection and access restrictions
• firewalls, intrusion detection, and anti-virus systems
• use of secure networks and encryption for data transmission
• building security measures
• secure destruction and de-identification processes.

Accessing and correcting your information

You may request access to the personal information we hold about you, or ask for corrections, by contacting our Privacy Officer (details below). We will verify your identity and generally respond within 30 days. While no fee is charged for such requests, we may charge a reasonable cost for providing access.

Making a privacy complaint

If you have concerns about how we handle your personal information, please contact our Privacy Officer. Please include your name, email, and phone number and describe your complaint in detail. We aim to investigate and respond within 30 days. If you are unsatisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) via www.oaic.gov.au.

Contact – Privacy Officer

Foxglove Defence
Email: enquiry@foxglovedefence.com.au
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