References to Azure, we or us in this policy are to Azure Capital Holdings, Azure Capital Pty Ltd and their subsidiaries.
Your privacy is important to us and we are committed to protecting your personal information in accordance with the standards required by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (the Privacy Act). Personal information that we collect about you will only be used for the purposes we have collected it or as allowed under the law.
Personal information we collect
When we refer to personal information we mean information or an opinion relating to an individual which can be used to identify that individual.
Personal information we collect about you may include:
- contact details
- date of birth
- identification document information
- employment details and employment history
- shareholdings and other ownership arrangements
- corporate and other officer details
- information on public, government or other registers
- criminal history information
- publicly available information
You have a right not to provide us with your personal information, but failure to provide information we request may affect the services we provide to you.
Why we collect your personal information
We may collect and use your personal information for any of the following purposes:
- deciding whether to provide services to you
- providing services to you
- identifying you
- considering an application for employment
- managing our relationship with you
- legal, regulatory, compliance or governance
- risk management or crime prevention
- operating and managing our business
- marketing, planning, product or service development
- research, analytics or business improvement
We may also collect, use and share your information for other reasons that the law allows or requires. If we need to disclose personal information to a third party, it will be done to the extent that it is permitted by law and in accordance with this policy.
How we collect your personal information
Where reasonable and practical we collect your personal information directly from you. We may collect information by way of face-to-face meetings, completed forms, business cards, telephone conversations, applications, interviews, emails, invitations and electronic interactions.
In some circumstances, we may collect personal information about you from a third party. Some examples of third party sources include referees, your authorised representatives, publicly available records and registers.
Cookies are small pieces of information stored on the web browser on your computer. Any web server (including our web server) may from time to time:
- store one or more cookies on your web browser;
- request your browser to send data back to our web server; and/ or
- request your browser to send a cookie which has been stored on your web browser by another website in the same internet domain.
How we disclose your personal information
We may disclose your personal information to:
- share registries
- related entities and their officers, employees, agents and contractors
- entities that provide financial services eg stockbrokers, fund administrators, custodians and responsible entities
- other organisations that are involved in managing or administering our financial services
- other organisations such as third party suppliers, printing and postal services
- our technology providers and administrators
- our service providers, including software as a service providers
- anyone, where you have provided your consent
- any person where we or our related entity is required to do so by law
- any person or entity considering acquiring an interest in our business or assets
When we disclose your personal information it may be to entities that are overseas including to our related entities in France and Hong Kong and to our Software as a Service Providers in the USA.
Emails you receive from us
We may use your email address to send you information about us or our events. We may also contact you to provide details of an offer that may be of interest to you or to seek your opinion or comment on our website or about our services.
You can unsubscribe from our emails at any time. You can also contact us by emailing email@example.com if you prefer not to receive such information. We will not charge you for giving effect to your request.
Updating your personal information
It is important to us that the personal information we hold about you is accurate and up to date. Please let us know if any of your personal information changes. If you are contacted and asked to update your information please contact our Compliance Officer to ensure that the request is genuine – see Contact us below.
Access to and correction of your personal information
You can contact us to ask for access to personal information that we hold about you, or to correct that personal information. We will aim to respond within 30 days. We will ask you to verify your identity before we give you access to information or correct it.
There may be situations where we are not required to provide you with access to your personal information or to make a correction that you have requested. For example, we may not give you access to information that involves other people.
If we refuse to give you access to, or correct, your personal information, we will notify you in writing setting out the reasons. If we refuse to correct your personal information, you can ask us to associate it with a statement that you believe the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We will do so unless there is a valid reason not to.
We may charge a fee for our costs of retrieving and supplying information to you, depending on its location and volume. We will not charge you for making a request, for correcting your personal information, or for associating a statement with your information.
We may need to contact other entities to properly investigate your request. Please tell us if your request is urgent.
Using government identifiers
We do not usually collect government identifiers, such as your tax file number. We will not collect government identifiers unless permitted by law.
Business without identifying you
Where possible, we will allow you to interact with us anonymously or using a pseudonym. However, we will need to identify you in order to do business with you in accordance with our legal obligations and our policies and procedures. Therefore, we will be unable to do business with you if you wish to remain anonymous or use a pseudonym.
In some circumstances (eg to meet our legal, regulatory, compliance or governance requirements or respond to a complaint) it may be necessary to collect “sensitive information”.
Sensitive information includes information relating to racial or ethnic origin, political opinions or associations, memberships in trade or professional associations or trade unions, sexual orientation and practices, criminal record, religious beliefs and affiliations, philosophical beliefs, biometric information and templates and health information.
For example, sensitive information may be collected during the recruitment process (including criminal history, identification documents, membership information and publicly available information) or as part of “know your client” checks (including identification documents and publicly available information).
Storage and security of personal information
Personal information that we collect may be securely held in paper or electronic form. Paper documents are stored in our offices or storage facilities and electronic documents are held on our cloud storage, on servers located in Australia. We use a range of physical, electronic and other security measures to protect the confidentiality and integrity of the information that we hold.
We hold information for the period reasonably necessary to provide our services to you, and satisfy our legal, regulatory, compliance, governance and business needs.
Destruction of personal information
If we no longer require your personal information for any of the purposes outlined in this policy, we will take reasonable steps to destroy it securely.
In certain circumstances, persons who are European Union residents may also have additional rights under the General Data Protection Regulation (GDPR) including the right to request the destruction of their personal information. To make a request, or exercise any of these rights, please contact our Compliance Officer – see Contact us below.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you can contact our Compliance Officer – see Contact us below.
We will acknowledge your complaint and will aim to resolve your complaint within 30 days.
If you believe Azure has not adequately dealt with your complaint and you are not satisfied, you can contact the Australian Financial Complaints Authority (AFCA). AFCA provides a free service that assists consumers and small businesses to make and resolve complaints about financial firms. Azure Capital Pty Ltd is a member of AFCA. You can contact AFCA at:
GPO Box 3
Melbourne VIC 3001
1800 931 678
You can also complain to the Office of the Australian Information Commissioner (OAIC) at:
GPO Box 5218
Sydney NSW 2001
You can contact us at:
Level 46, 108 St Georges Terrace
Perth WA 6000
+ 61 8 6263 0888
Updates and requests
We may amend or update this policy from time to time including when our information handling practices change. Updates will be published on our website.
A copy of our current policy is available on our website at www.azurecapital.com.au We will provide you with a copy of our current policy free of charge, upon request. You may also request a copy of our current policy in an alternative form.
Last updated: 9 August 2022