I-Deal Financial Group is
committed to implementing and promoting a privacy
policy which will ensure the privacy and security of
your Personal Information. The following Privacy
Policy expresses our policies on the management of
your Personal Information.
1. National Privacy Principles
The I-Deal Group abides by the National Privacy
Principles established under the Privacy Amendment
(Private Sector) Act 2001.
2. Collection of Personal Information
2.1a
As a Newlsetter Subscriber we simply hold your information on a computer database to send you news and occasional information. You may unsubscribe at anytime using the Newletter DSelivery features.
2.1b
Trading Clients
As a CAR of a licensed securities dealer and as a futures broker
we are subject to certain legislative and regulatory
requirements which necessitate us obtaining and
holding detailed information which personally
identifies you and/or contains information or an
opinion about you (“Personal Information”).
In order
to provide you with a comprehensive advisory and
dealing service in securities and/or futures
(“Financial Products”) and to have a reasonable
basis for recommendations we make, we require
certain Personal Information about you, including:
a. employment details;
b. details of your
financial needs and objectives;
c. details of your
current financial circumstances, including your
income, assets and liabilities;
d. details of your investment history and
preferences, and
e. your aversion or tolerance to risk.
2.2 We will
not collect any Personal Information about you
except when you have knowingly provided that
information to us or authorised a third party to
provide that information to us.
2.3 Generally
collection of your Personal Information will be
effected in either face to face interviews, over the
telephone or by way of a Client Account Application
form. From time to time additional and/or updated
Personal Information may be collected through one or
more of those methods.
2.4 We will
only collect, maintain and use Personal Information
about you if it is necessary for us to adequately
provide to you the services you have requested
including:
a. making Financial Products recommendations;
b. executing Financial
Products transactions on your behalf
c. clearing and settling
Financial Products transactions on your behalf
- and all things necessary or
incidental to the above.
3. Use and Disclosure of Personal Information
3.1 We will
not use or disclose Personal Information collected
by us for any purpose other than:
a. the purposes for which
it was provided or secondary related purposes in
circumstances where you would reasonably expect
such use or disclosure; or
b. where you have
consented to such disclosure; or
c. where the National
Privacy Principles authorise use or disclosure
where required or authorised under law, in
circumstances relating to public health and
safety and in connection with certain operations
by or on behalf of an enforcement body.
3.2 We are
required under the Corporations Act and the Rules of
the Australian Stock Exchange and/or the Sydney
Futures Exchange to make certain information
available for inspection by the Australian
Securities and Investments Commission, ASX and/or
SFE on request to ensure ongoing compliance with
licensing and regulatory requirements. This may
involve the disclosure of your Personal Information.
3.3 We may
use the Personal Information collected from you for
the purpose of providing you with investment product
and services information and marketing material for
any member of the I-Deal Group such as research that
may be of interest to you, however you may, by
contacting us by any of the methods detailed below,
request not to receive such information and we will
give effect to that request. Please allow 2 weeks
for your request to be actioned.
3.4 We may
disclose your Personal Information to market
operators, clearers and product issuers for the
purpose of giving effect to your instructions and
the recommendations made by us.
3.5 We may
disclose your Personal Information to external
contractors for the following purposes:
a. execution, clearing
and settlement of Financial Products
transactions
b. registration and/or
changes to shareholder detail
c. accounting for
Financial Products transactions
d. causing statutory
audits to be conducted as required by law
e. maintenance and
service of our information technology systems
f. in the course of
reviews by external consultants
It is a condition of our agreement with each of our
external contractors that they adopt and adhere to
this privacy policy. You can be assured that your
information will be maintained by any contractor to
whom it is disclosed in accordance with this policy.
If you have any concerns in this regard, you should
contact us by any of the methods detailed below.
4. Document storage and security
4.1 Your
Personal Information is generally held in your
client file. Information may also be held in a
computer database.
4.2 We will
at all times seek to ensure that the Personal
Information collected and held by us is protected
from misuse, loss, unauthorised access, modification
or disclosure. At all times your Personal
Information is treated as confidential and any
sensitive information is treated as highly
confidential and stored securely. Access to our
premises is controlled by allowing only personnel
with security passes to access the premises.
Unauthorised persons are strictly prohibited from
entering our dealing rooms. All computer based
information is protected through the use of access
passwords on each computer and screen saver
passwords. Data is backed up each evening.
4.3 In the
event you cease to be a client of this organization,
any Personal Information which we hold about you
will be maintained in a secure off site storage
facility for a period of 7 years in order to comply
with legislative and regulatory requirements,
following which time the information will be
destroyed.
4.4 When
permitted by your agreement with us, telephone
recordings of your conversations with us may be
kept, used and deleted earlier than the 7 years for
other personal information.
5. Access to your Personal Information
5.1 You may
at any time, by contacting us by any of the methods
detailed below, request access to your Personal
Information and we will (subject to the following
exceptions) provide you with access to that
information either by providing you with copies of
the information requested, allowing you to inspect
the information requested or providing you with an
accurate summary of the information held. We will,
prior to providing access in accordance with this
policy, require you to provide evidence of your
identity.
5.2 We will
not provide you with access to your Personal
Information if:
a. providing access would
pose a serious threat to the life or health of a
person;
b. providing access would
have an unreasonable impact on the privacy of
others;
c. the request for access
is frivolous or vexatious;
d. the information
related to existing or anticipated legal
proceedings between us and would not be
discoverable in those proceedings;
e. providing access would
reveal our intentions in relation to
negotiations with you in such a way as to
prejudice our position in those negotiations;
f. providing access would
be unlawful;
g. denying access is
required or authorised by or under law;
h. providing access would
be likely to prejudice certain operations by or
on behalf of an enforcement body or an
enforcement body requests that access not be
provided on the grounds of national security,
enforcement or prosecution reasons.
5.3 In the
event we refuse you access to your Personal
Information, we will provide reasons, if permitted.
6. Correction of Personal Information
6.1 We will
endeavour to ensure that, at all times, the Personal
Information about you which we hold is up to date
and accurate. In the event that you become aware, or
believe, that any Personal Information which we hold
about you is inaccurate, incomplete or outdated, you
may contact us by any of the methods detailed below
and provide to us evidence of the inaccuracy or
incompleteness or outdatedness and we will, if we
agree that the information requires correcting, take
all reasonable steps to correct the information.
6.2 If we do
not agree that your Personal Information requires
correcting, we must, if you request, take reasonable
steps to ensure that whenever your Personal
Information is accessed or handled in the future, it
is apparent that you are not satisfied as to the
accuracy or completeness of that information.
6.3 We will
endeavour to respond to any request for access
within 14-30 days depending on the complexity of the
information and/or the request. If your request is
urgent please indicate this clearly.
7. Internet Privacy
7.1 I-Deal’s
Web site contains links to other Web sites whose
operator may or may not adhere to a privacy policy
or be governed by the National Privacy Principles.
7.2 While it
is not necessary to register your personal details
to use our Web site, we do offer a registration
service which will enable you to receive additional
services and information. In the event you do
register with us, we will collect Personal
Information from you including your name and e-mail
address.
7.3 If you
have registered with us and decide, at any time,
that you do not wish to receive any further
information from us, you can send an e-mail to the
e-mail address noted below requesting to be removed
from our online registration database. Please allow
2 weeks for your request to be actioned.
7.4 You may
amend or update your registration details by sending
an e-mail to the e-mail address noted below
providing your amended details. Please allow 2 weeks
for your request to be actioned.
7.5 Cookies:
our Web site uses cookies which allows us to
identify your browser while you are using our site.
Cookies do not identify you, they simply allow us to
track usage patterns so that we can measure the
level of interest in various areas of our site. All
browsers allow you to be notified when you receive a
cookie and elect to either accept it or not. Your
Internet service provider should be able to assist
you to set your preferences.
8. Complaints
8.1 If you
wish to complain about any breach or potential
breach of this privacy policy or the National
Privacy Principles, you should direct your complaint
to the Privacy Officer whose details appear below.
Your complaint will be considered within 7 days and
responded to. It is our intention to use our best
endeavours to resolve any complaint to your
satisfaction, however, if you are unhappy with our
response, you are entitled to contact the Office of
the Privacy Commissioner who may investigate your
complaint further.
PRIVACY OFFICER:
John Robertson
Address:
I-Deal Group
Level 5, ,
PO BOX 3794
MOSMAN NSW 2088