This policy applies to information collected by Dalton Street Capital Pty Ltd (“Dalton St” or “we” or “us”). It outlines how we collect and use personal information that we hold about you in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act) and the subsequent 2012 and 2016 amendments (Mandatory Data Breach Notification), Privacy Regulations 2013 and the General Data Protection Regulation (GDPR).
This policy has been developed in accordance with the Australian Privacy Principles (APP).
What personal information is collected?
We only collect personal information that is reasonably necessary for us to provide our products and/or services. If you do not provide the information that we ask for, we may not be able to provide the products or services you have requested. We may collect information such as your name, address, phone number, email address, tax ﬁle number, bank account details, other information that may be required for identiﬁcation purposes, information about your investments and transactions and other information related to the services we provide.
Sensitive information is not collected from you because it is not reasonable for us in providing our services to you. Sensitive information includes health information, racial information, genetic information, and information about religious beliefs.
Why we collect personal information
We collect personal information about you which is reasonably necessary to:
How personal information is collected?
By using Dalton St services you consent to Dalton St collecting your information from you or from a person who is acting as your agent. We may collect information directly from you or your agent, such as when you or your agents provide information by phone, email or in an application form.
Use and disclosure of your personal information
Dalton St may use your personal information for the primary purpose of providing ﬁnancial services to you, as well as for related purposes such as:
For the purposes we have described, we may disclose your personal information:
Do we disclose personal information for marketing?
We may use your personal information to offer products and services that we believe may interest you. We may also disclose your personal information to external service providers who assist us to market our products or services.
We are permitted to use personal information for marketing if the client would reasonably expect us to do so and when the client has been provided with a simple means of opting out of the marketing service.
If you do not wish to receive marketing offers from us please inform us by sending an email to firstname.lastname@example.org.
Government related identifiers
Although in certain circumstances we are required to collect government identiﬁers such as your tax ﬁle number, Medicare number or pension card number, we do not use or disclose this information other than when authorised by law or unless you have voluntarily consented to disclose this information to a third party.
Access and correction and updating personal information
Generally, we will provide you with access to your personal information that we hold within a reasonable time of a request unless an exception applies under the Privacy Act. Where we provide you with access to such information, we may charge you a reasonable fee to cover our costs.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, up to date, complete and relevant. In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate or incomplete, you should contact us to correct the information.
If we disagree about the correction you have supplied, and refuse to correct the personal information, or if we believe that we are unable to comply with your request, we will give you a written notice to that effect. You have the right to make a complaint if you disagree with our decisions in relation to these matters.
Your Rights under the GDPR
If you are an individual residing in the European Union (EU), you have certain rights as to how your personal information is obtained and used. Dalton St complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.
Except as otherwise provided in the GDPR, you have the following rights:
a) To be informed how your personal information is being used;
b) Access to your personal information (we will provide with a free copy of it);
c) To correct your personal information if it is inaccurate or incomplete;
d) To delete your personal information (also known as ‘the right to be forgotten’);
e) To restrict processing of your personal information;
f) To retain and reuse your personal information for your own purposes;
g) To object to your personal information being used; and
h) To object against automated decision making and profiling.
We may ask you to verify your identity before we act on any of your requests.
Storage and security of information
Dalton Street Capital Pty Ltd stores personal information in a combination of computer storage facilities, paper-based ﬁles and other records. We will take reasonable steps to protect personal information from loss, misuse, unauthorised access, modiﬁcation or disclosure.
Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the Australian Privacy Act and GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
We may also keep records of our interactions with you (including by telephone, e-mail and online) and of your transaction history.
Overseas disclosure of personal information
We do not currently disclose your personal information to overseas recipients. However, some third party providers that we may engage with from time to time may have overseas locations. In the event that we do disclose your personal information overseas, Dalton St will make reasonable steps to ensure that the foreign recipient will not breach the APPs and to ensure that they are subject to similar privacy laws that will afford protection in the same manner as the APPs.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Contacting us and complaints
If you wish to contact us for any purpose regarding this policy including making a complaint about the way we have handled your personal information (including if you think we have breached the Privacy Act) you may do so to our compliance and risk team in writing, by mail to the address set out in this policy. When you contact us, include your email address, name, address and telephone number and clearly describe your complaint. Any complaints will investigated and you will receive a response promptly.
Please mark any written requests or complaints: ‘Attention: Privacy Officer’
Dalton Street Capital Pty Ltd
Level 40, 161 Castlereagh St,
Sydney NSW 2000
If you are not satisfied with our response to your complaint, and you are an individual located in Australia, you may be able to lodge a complaint with an external dispute resolution scheme. The external dispute resolution body, Australian Financial Complaints Authority (AFCA) is established to assist you in resolving your complaint where you have been unable to do so with us. Should you be unhappy with the outcome from the external dispute resolution scheme, you have the option to refer your privacy complaint to the Office of the Australian Privacy Commissioner (OAIC).