Our Commitment

Finexia Securities Ltd ABN 61 608 667 778 and its affiliates (collectively known as "Finexia Securities" or "Finexia" and referred to in this Policy as "us," "we" and "our") seeks to provide the best possible services to its customers by providing a range of financial products and services. We understand how important it is to protect your personal information. This document sets out our Privacy Policy commitment in respect of personal information that you may provide to us. We recognise that any personal information we collect about you will only be used for the purposes indicated in our policy, where we have your consent to do so, or as otherwise required or authorised by law. It is important to us that you are confident any personal information we collect from you or that is received by us will be treated with the appropriate respect ensuring protection of your personal information. Our commitment in respect of personal information is to abide by the Privacy Act 1988 (Cth), the Australian Privacy Principles and any other relevant law.

Personal Information

When we refer to personal information we mean information or an opinion about you, that is capable, or reasonably capable, of identifying you, whether the information or opinion is true or not and is recorded in material form or not. This information may include (but is not limited to) your name, date of birth, driver's licence number, marital status, phone number, email address, address, nationality, employment history, income, assets and liabilities.

Sensitive information includes such things as your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or criminal record, that is also personal information. Your health, genetic and biometric information and biometric templates are also sensitive information.

We protect your personal and sensitive information in accordance with the Australian Privacy Principles and the Privacy Act 1988 (Cth).

It is not common practice for us to collect other sensitive information about you (such as information about your religion, trade union membership, political opinion, sexual preference or criminal record). We will only collect sensitive information about you with your consent.

We collect personal and/or sensitive information to provide you with the products and services you request as well as information on other products and services offered by or through us. The law requires us to collect personal and/or sensitive information.

Your personal and/or sensitive information may be used by us to administer our products and services, for prudential and risk management purposes and, unless you tell us otherwise, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We cooperate with police and other enforcement bodies as required or allowed by law.

We disclose relevant personal information to external organisations that help us provide services. These organisations are bound by confidentiality arrangements. They may include overseas organisations.

You can seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will let you know why. For example, we may give an explanation of a commercially sensitive decision, or give you access to the information through a mutually agreed intermediary, rather than direct access to evaluative information connected with it.

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Why we collect your information?

We collect and receive personal information about you in order to conduct our business, including assessing and obtaining approval for Finexia Securities including equities, Exchange Traded Options, CFDs and other financial products. From time to time we may offer other products and services.

We collect personal information when it is reasonably necessary for one or more of our functions or activities. These include:

• Providing customers with the products and services they request and, unless they tell us otherwise, to provide information on products and services offered by us and external product and service providers for whom we act as agent. (if you have provided us with your email or mobile phone details, we may provide information to you electronically with respect to those products and services);
• Complying with our legal obligations;
• Monitoring and evaluating products and services;
• Gathering and aggregating information for statistical, prudential, actuarial and research purposes;
• Assisting customers with queries; and
• Taking measures to detect and prevent frauds.

Information we may collect

The personal and sensitive information we collect generally consists of name, address, date of birth, gender, marital status, occupation, account details, contact details (including telephone, facsimile and e-mail) and financial information.

We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. Anti-money laundering laws require us to sight and record details of certain documents (i.e. photographic and non-photographic documents) in order to meet the standards set under those laws.

Where it is necessary to do so, we also collect information on individuals such as:

• Trustees;
• Partners;
• Company directors and officers;
• Officers of co-operatives and associations;
• Customer’s agents;
• Beneficial owners of a client;
• And persons dealing with us on a “one-off” basis.

We may take steps to verify the information we collect; for example, a birth certificate provided as identification may be verified with records held by the Registry of Births, Deaths and Marriages to protect against impersonation, or we may verify with an employer that employment and remuneration information provided in an application for credit is accurate.

How do we collect your information?

Personal information may be collected by us in a number of circumstances, including when an individual:

• Makes an enquiry with us via email or telephone;
• Lodges an enquiry or requests a quote through our website
• Applies to invest in a financial product offered by us
• Attends an event hosted by us; or
• Applies to work with us.

Where reasonable and practical we will collect your personal information only directly from you. However,we will also collect information about you from third parties such as contractors who supply services to us, authorised representatives of Finexia, referrers (such as financial advisers), from a publicly maintained record or from other individuals or companies as authorised by you. From time to time we may also purchase lists containing personal information about individuals from organisations offering such lists for marketing purposes.

The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) require us to collect certain identification information about you. We will collect personal information from third parties in respect of AML/CTF checks which are required to be carried out, under AML/CTF Legislation.

If you do not provide the personal information requested by us, we may not be able to provide you with our services.

If you provide personal information to us about someone else, you must ensure you are entitled to disclose the information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy. The individual must also provide the consents set out in this Privacy Policy in respect of how we will deal with their personal information.

Sensitive Information

In addition to the above conditions of collecting personal information, we will only collect sensitive information about you if we obtain prior consent to the collection of the information or if the collection is required or authorised by law.

Dealing with unsolicited personal information

If we receive personal information that is not solicited by us, we will only retain it, if we determine that it is reasonably necessary for one or more of our functions or activities and that you have consented to the information being collected or given the absence of your consent that it was impracticable or unreasonable for us to obtain it under the circumstances.

If these conditions are not met, we will destroy or de-identify the information.

If such unsolicited information is sensitive information we will obtain your consent to retain it regardless of what the circumstances are.