OUR PRIVACY POLICY

This policy outlines Eticore’s procedures and guiding principles in protecting your privacy, and safely collecting, using, disclosing and maintaining your Personal Information. Your privacy is important to Eticore, and we are committed to managing your Personal Information responsibly and in accordance with our legal obligations.

Throughout this policy, Eticore refers to Eticore Pty Limited (ABN 14 613 341 996) and its related entities. The policy applies to Eticore in our capacity as trustee, manager, accountant or service provider of the various trusts, vehicles and investments to which we provide services, as well as in our personal capacity.

Any Personal Information we collect about you will only be used for the purposes indicated in our policy. Our commitment in respect of Personal Information is to abide by the Australian Privacy Principles for the protection of Personal Information, as set out in the Privacy Act 1988 and any other relevant law.

What is Personal Information?

Personal Information is information from which your identity is apparent. This information may include information or an opinion about you, from which your identity can reasonably be ascertained.

Types of Personal Information Eticore Collects

The Personal Information Eticore may collect about you will depend on the circumstances of collection, including whether we collect the information from you as a client, supplier, contractor, stakeholder, job applicant or in some other capacity.
Eticore collects Personal Information so that we can provide you with our products and services, prospectively employ you, purchase products and services from you, and comply with our legal obligations such as those under taxation laws and the Anti-Money Laundering and Counter-Terrorism Financing Act. If Eticore does not collect your Personal Information, we may not be able to provide you with a product or service, employ you, or purchase services from you.
The reason we are collecting the information (for example, to provide a service to you, employ you, or purchase a service from you) will generally determine what information we will collect about you. The kinds of Personal Information that Eticore may collect and hold about you may include:

• Name;
• Address;
• Gender;
• Contact details;
• Date of birth;
• Citizenship status;
• Tax file number;
• Bank account details;
• Employment references;
• Criminal and civil records; and
• Education and employment history.

In addition, we may collect Personal Information about individuals who are not customers of Eticore (e.g. business contact details of a company representative with whom we deal).

Where sensitive information is collected, stored, used or transferred about you, we will only use this information if you have consented, or in the exercise or defence of a legal claim. Sensitive information is information relating to your racial or ethnic origin, political persuasion, memberships of trade or professional associations or trade unions, sexual preferences, or health.

Collection and Storage of Your Personal Information

We may collect your Personal Information when you:

• contact us by telephone, by email, or through our web site; or
• complete a form; or
• when you meet one of our representatives face to face.

Eticore may also collect information about you from third parties such as:

• Your authorised representatives and advisor(s);
• Our service providers;
• Your employer;
• Our corporate clients, where we are providing services to them;
• Referees, in the case of prospective employees.

Eticore stores your Personal Information in a secure environment which is verified to meet the requirements specified in ISO 27001 (the International standard which governs the management of the security of financial information, intellectual property, employee details or information entrusted to you by third parties). The environment is based in Australia and complies with the Australian Privacy Act and Data Sovereignty law.

Certain information may also be maintained as hard copy files at Eticore’s corporate office, which is attended or secured at all times. Eticore takes reasonable steps to protect your Personal Information, including security measures such as password controls, firewalls and anti-virus technology to prevent unauthorised access to your Personal Information.
When the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.

You should note that when you visit Eticore’s website, we collect certain information by automated means, using technologies such as cookies and web server logs. Cookies are small files that our website will send to your computer or other Internet-connected devices when you complete certain tasks on our website. The cookie enables Eticore to uniquely identify the browser. Cookies allow Eticore to recognise the computer when it is used to return. They also help us provide a customised experience and enable us to detect certain kinds of fraud. Your Internet-connected device browser can be configured so that your device does not accept cookies.

Use and Disclosure of Your Personal Information

Eticore may collect, hold, use or disclose your Personal Information in order to provide financial and fiduciary services to trusts and funds. We may also collect, hold, use or disclose your Personal Information to:

• Consider any concern or complaint that you raise against Eticore and/or to manage any legal action between you and Eticore;
• Prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
• Identify you or establish your tax status under any Australian or foreign legislation;
• Comply with any relevant laws, regulations, codes of practice and court orders;
• Comply with record-keeping, reporting and tax obligations;
• Communicate via surveys or questionnaires;
• Consider job applicants for employment;
• Meet other purposes required or authorised by or under law (including purposes for which you have provided your consent)

Eticore does not sell, rent or trade Personal Information to, or with, third parties. In some circumstances your Personal Information may be disclosed to Eticore’ related entities or service providers that perform a range of services on our behalf.

Examples include:

• Organisations involved in providing, managing or administering our products and services such as custodians, fund and investment administrators/managers, or external dispute resolution services;
• Professional service firms that provide services to us such as lawyers and auditors;
• Software and information technology providers;
• Mailing houses and printing companies;
• Other consultants or advisers appointed by us.

Where we disclose Personal Information to our service providers, we will take steps to ensure that they are authorised to only use that information in order to perform the functions required by Eticore.

We may also disclose your Personal Information to law enforcement agencies, courts or government agencies where required to comply with specific legal requirements. In addition, we may disclose your Personal Information to other third parties and for other purposes with your consent. That consent may be written, verbal or implied from your conduct.

By providing us with your Personal Information, you consent to us disclosing your information to such entities without obtaining your consent on a case-by-case basis. Prior to disclosing any of your Personal Information to another organisation, we will take all reasonable steps to satisfy ourselves that disclosure is:

• for a purpose known to you;
• for a purpose you would reasonably expect;
• for a purpose required or permitted by law (for example. in response to a request or in response to a subpoena to a court or tribunal or to the Australian Taxation Office);
• otherwise for a purpose authorised by you, and
• to an organisation that has a commitment to protecting your Personal Information at least equal to our commitment.

We will endeavour not to transfer your Personal Information outside Australia however there may be circumstances where it is necessary to do so. In such cases we will take all reasonable steps to satisfy ourselves that the other country has privacy laws substantially similar to those of Australia, unless the disclosure is required by law.

Accessing and Updating Your Personal Information

You may contact us at any time to request access to the Personal Information we hold about you. You may also ask us to correct information about you that you believe to be inaccurate, incorrect or out of date. We will need to verify your identity before giving you access or correcting your information.

There may be some situations where we are not able to correct or provide you with access to your Personal Information. In these circumstances we will provide you with a written an explanation of those reasons

Further Information and Complaints

You may request further information about the way we manage your Personal Information by emailing, writing or telephoning Eticore. You may also make a complaint or detail a privacy concern by emailing or writing to us. We will acknowledge any complaint in writing within 5 calendar days and make every effort to resolve your issue within a reasonable time of us being notified (generally within 30 days).

Contact details are:
Email: privacy@eticore.com.au
Post: Privacy Officer, Eticore
Suite 501, 15 Castlereagh Street
Sydney NSW 2000
Telephone: 02 8278 9520

If the complaint you made via the process outlined above remains unresolved, you may apply to the Office of the Australian Information Commissioner (OAIC) or access an external dispute resolution service to have your complaint heard and determined. The Commissioner may be contacted on the privacy hotline 1300 363 992.

Related Legislation / Regulations

• Australian Privacy Principles
• Privacy Act 1988