1. Privacy Policy

This Privacy Policy is designed to tell you what will happen to the personal information you provide to us, Hale Capital Group Pty Ltd and our wholly owned subsidiaries.

By using our website or otherwise providing us directly, or through others, with your personal information, you agree with the terms of this Privacy Policy and consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy, the Privacy Act 1988 (Privacy Act) as amended (including the Australian Privacy Principles) and other applicable privacy laws.

2. What kinds of personal information is collected and held?

This Privacy Policy concerns any personal information or sensitive information of yours which is provided to us.

Personal information is any information or opinion about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not.

We generally do not collect a person’s sensitive information. We, in any event, will collect, use or disclose sensitive information about you only as allowed by law, for example where we have received your consent to do so or the collection is required by law. Sensitive information is any personal information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetics, biometrics or biometric templates.

The kinds of personal information we collect may include;

• If you are our client’s personnel, officers, directors, investment committee members or representatives – your name, organisation, job title, address (work or home), email address, telephone number (work or personal) and signature.

• If you apply for a job with us or are appointed as a contractor – your name, contact details, date of birth, citizenship, employment references, civil credit and criminal records, regulatory accreditation (such as RG 146 accreditation for advisers) and driver’s licence information, education and employment history. Once appointed, we will also collect and hold TFNs, financial information relating to the appointment and banking details for payments.

If we are not provided with the personal information that we request, we may not be able to meet your request or provide our relevant products or services.

3. How is personal information collected?

We collect personal information in a number of ways, including;

• directly from you or third parties such as the client, including via meetings, telephone, email or correspondence and online forms;
• from publicly available resources; or
• by analysing our own records of your use of our products or services and website.

Passive information collection

As you navigate through our website, certain information can be passively collected (that is, gathered without you actively providing the information) through various technologies, such as cookies, internet tags or web beacons and navigational data collection.

This website may use and combine such passively collected anonymous information to provide better services to website visitors, customise the website based on your preferences, compile and analyse statistics and trends and otherwise administer and improve the website for your use. Such information is not combined with personally identifiable information collected elsewhere on the website unless you have consented.

4. Why we collect, hold, use and disclose personal information?

The personal information provided to us may be used for a number of purposes connected with our business operations, which include to;

• verify your identity;
• provide clients with financial products or services;
• inform clients of existing and proposed products and services which we provide;
• better understand a client’s needs in the area of financial products or services;
• develop and improve the quality and scope of the products and services we provide, and seek your feedback;
• address or respond to any requests from you;
• assessing your application if you have applied to work with us;
• manage our relationship with contractors in the course of operating our business; and
• comply with our regulatory or legal requirements, including:
• the Anti-Money Laundering & Counter-Terrorism Act 2006;
• the Corporations Act 2001;
• the Australian Securities and Investments Commission Act 2001
• the Bankruptcy Act 1966;
• the Tax Laws Amendment (Implementation of the FATCA Agreement) Act 2014;
• the Tax Laws Amendment (Implementation of the Common Reporting Standard) Act 2016; and
• applicable taxation law.

We may also use your personal information for purposes related to those described above which would reasonably be expected by you.

We will not use your information for purposes other than those described above unless we have your consent or as permitted by law (including for law enforcement or public health and safety reasons).

5. How is your personal information held?

We respect the personal information you have entrusted to us and we have a responsibility to manage and protect that information. We will take all reasonable precautions to safeguard your information from loss, interference, misuse, unauthorised access, modification, disclosure or destruction. We will store your files;

• in a secure environment in hard copy, electronically or both; and
• using a third party data storage provider.

We implement a range of physical and electronic security measures to protect the personal information that we hold.

With the exceptions detailed within this Privacy Policy, your personal information will only be available to our employees or those of our service providers on a need-to-know basis in order to perform their obligations and duties.

6. To whom might your personal information be disclosed?

Generally, we will only disclose your personal information for the purposes of providing our financial products or services to our clients. This may include disclosing your personal information to;

• others in accordance with a request made by you or the client;
• our related companies and business partners; and
• third parties where necessary to provide the client with our financial products or services. These third parties may include government departments and regulatory authorities. This may also include third parties providing us with professional, business, technology and corporate services, when reasonably required, such as our auditors, insurers, custodians, IT providers, third party data storage providers and third party administrators.

When making such a disclosure we will take reasonable steps to ensure that the recipient is bound by privacy obligations.

Unless you consent, we otherwise will not disclose your personal information to third parties.

7. Does my personal information leave Australia?

We may disclose personal information to overseas recipients outside Australia in order to provide our financial products or services. Before disclosing any personal information to an overseas recipient outside Australia, we will take reasonable steps to ensure the overseas recipient complies with the Australian Privacy Principles or you otherwise consent to the overseas disclosure or the disclosure is required or authorised by law.

8. How do you access your personal information and seek correction of it?

Should you wish to know what personal information holds on you, you may request to view this information by contacting our compliance team:

Address: Level 14, 88 Philip Street, SYDNEY 2000 NSW

Email: info@halecp.com

We will promptly investigate your privacy enquiry and provide you with appropriate answers where required. Should you discover that any information is outdated, incorrect or incomplete you may request to have the personal information corrected and we will promptly update our records. To ensure your personal information is accurate, please notify us of any errors or changes to your personal information and we will take appropriate steps to update or correct such information in our possession.

9. Notifiable Data Breaches scheme

In the event of any loss or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you that we have been unable to prevent with remedial action, we will;

• investigate; and
• notify you and the Office of the Australian Information Commissioner as soon as practicable, in accordance with the Privacy Act.

10. How can I complain about a breach of my privacy?

If you wish to make a complaint about our handling of your personal information, you should contact us as referred to above in section 8.

We will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days.

We expect that our procedures will deal fairly and promptly with your complaint. However, if we cannot resolve your complaint then you may raise your issue with the Office of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia).

11. Additional information and changes to this Privacy Policy

If you have any questions or concerns about this Privacy Policy or our information practices, please contact us as referred to above in section 8.

Our Privacy Policy may change from time to time. Before providing us with personal information, please check the Privacy Policy on our website for any changes.

This Privacy Policy was last updated November 2024.

Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner at www.oaic.gov.au