What personal information do we collect?
We may, in addition to other information, collect the following personal information about you:
Information you provide to us when you register to use the Website via a password or similar identification procedure and when using our services;
Your name, email address, residential address, contact telephone numbers, date of birth and password;
Financial information, such as your bank account number;
Tax file number, as and when applicable;
Specific documents to verify your identity and other personal details;
Details of transactions you carry out through our Website; and
The extent of the personal information required will be dependent on your account application forms, engagement letters or other communication forms with THN.
We have statutory responsibilities to collect and disclose certain information. For example, under the Anti-Money Laundering and Counter-Terrorism Financing Act, 2006 (Cth) (‘AML Law’) we are obliged to verify the identity of, and run anti-money laundering checks on, persons who use our Website and services. To comply with the AML Law, we may use third parties who provide identity verification services to verify your personal information. If those services are not able to verify your identity to our satisfaction, we may request that you send us further identification information. While you hold an account with us, we may also need to run additional identity checks on you. By becoming an authorised user of this Website, you agree that we may run these identity checks on you, and that you will not be able to use the Website or our services unless we are able to complete those checks to our satisfaction.
How do we use and disclose your personal information?
We will only use your personal information for the purpose of providing you with the financial services or products you have sought from us or by referring to you services of our associate companies that we may reasonably believe are to your benefit.
Your personal information will be used for any of the following purposes:
Verifying any information that you give to us, or information that we collect from third parties and any third party databases;
Carrying out credit and identity checks;
Assessing your suitability to register with us and use our services;
Providing our services to you;
Satisfying any obligation arising from any agreement between you and us;
Complying with our legal and regulatory obligations or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;
Necessary in discharging our obligations (such as to foreign governments for the purpose of foreign taxation);
Providing information to our associates;
Contacting you with information about us, our services, our associates and new investment opportunities that we believe may be of interest to you;
Storing, accessing and making information available through the Website;
Monitoring, operating, maintaining and improving the Website; and
Any other purpose permitted under the Privacy Act 1988 or that we notify you of at the time personal information is collected.
You authorize any third party to provide your personal information to us for any of these purposes.
If we disclose your personal information to a credit reporting agency, that agency may hold your information on their credit reporting database and use it for providing credit reporting services and for any other lawful purpose and the agency may disclose your information to their subscribers for the purpose of credit checking or debt collection or for any other lawful purpose.
When do we disclose personal information?
We may disclose personal information to service providers and others working with us to help us provide, improve and promote our Website and our services.
We may also disclose any of the personal information we hold:
For the purposes for which the information was collected;
With your express consent;
For any purpose which is permitted under the Privacy Act 1988;
In relation to any proposed purchase or acquisition of our business or assets; or
Where required by applicable law or any court, or in response to a request by a law enforcement agency.
Security of collected information
We store your personal information in our electronic database and in print form. The information that we collect may be transferred to, and stored by our local and overseas associates. If any information is stored overseas, it may also be processed by staff operating outside Australia who work for us or for one of our associates or suppliers.
We use reasonable efforts to maintain physical, electronic and administrative safeguards to protect the personal information in our possession from misuse, interference, loss and unauthorised access, modification or disclosure. Simultaneously we restrict access to information about you to THN personnel on a need-to-know basis for the purposes of providing services to you.
However, there is no guarantee that the electronic information about you stored on the internet is totally secure due to the nature of the internet. In circumstances where we detect any unauthorised access or any kind of potential abuse, we will notify you and at the same time take the appropriate remedial measures as early as practicably possible.
Once our relationship with you comes to an end, services sought by you are completed and our mutual duties of care and obligations are finalised – and upon your request – we will physically and electronically destroy the requested material within your personal information. This may involve shredding and recycling, sanitizing hardware and, where your information is stored in cloud storage, we will notify our vendor promptly to destroy or de-identify your personal information in the same or significantly comparable manner.
Retention of your personal information is for as long as necessary to achieve the purposes for which we collected it, and in all cases for such periods as we are required to in order to comply with any relevant legislation and regulations.
Our services to you may require disclosure of your personal information to overseas associated entities, contractors and other service providers, as well as third parties approached specifically by us on your behalf. These parties may be located in overseas jurisdictions such as Europe, the Middle East, the Indian subcontinent, the United States and the Asia Pacific region (including, but not limited to, China, Hong Kong, Malaysia, Singapore, Vietnam and Indonesia). These overseas jurisdictions are subject to cross-border disclosure which may change from time to time.
Your rights to access to and correction of your personal information
If you have registered with us, you may access some of the personal information that we hold about you in the My Profile dropdown menu of the Website and this is editable in the Settings page.
You have the right to request correction of any of the personal information we hold about you. But please be aware that you are also responsible to notify us of any incorrect personal information we may hold, as promptly as possible. In such circumstances we will respond to your request within 30 calendar days after the request is made. Although no charge will apply for the making of the request and the corrections, we may refuse to correct your personal information we hold about you if we do not agree with the corrections you have supplied. When we refuse your request, you are entitled to request a written notice from us explaining the reason or reasons for such refusal.
You have the right to request confirmation of what personal information we hold about you and to access any personal information that we hold about you which is readily retrievable. If you would like to exercise these rights, please email us at firstname.lastname@example.org
If you are of the opinion that we have mishandled your personal information, you may seek to submit a written complaint with our Privacy Officer. You may do so by mail, email or fax to the contact details listed here under.
The Privacy Officer
THN Pty Limited
PO Box 1095
Sutherland NSW 1499
The Privacy Officer will acknowledge the receipt of your complaint as soon as possible after receipt. THN will attempt to investigate and resolve your complaint within 30 calendar days. If we are unable to resolve the matter, you may lodge your complaint with the Australian Information Commissioner by:
Submitting an online form through the information Commissioner’s website: www.oaic.gov.au
Submitting a hard copy form which can be obtained at: https://forms.business.gov.au/smartforms/landing.htm?formCode=APC_PC
Fax to +61 2 9284 9666
Email at email@example.com