In this Statement, all references to “E-TRANS” refer to E-TRANS associated companies or subsidiary companies.

When you trust E-Trans with your personal information, you expect us to protect it and keep it safe. We are bound by the Australian Privacy Act 1988 (Cth) (‘Privacy Act’) and will protect your personal information in accordance with the Australian Privacy Principles. These principles govern how we can collect, use, hold and disclose your personal information, as well as ensuring the quality and security of your personal information.

The Privacy Policy is published on our website in order to meet our obligation under Privacy Acts which requires us to set out our policies on the management of personal information in a clearly expressed document which is available to anyone who asks for it.

Without limiting the generality of the above statement, your use of this website constitutes an acknowledgement that you have been made aware of our privacy policies.

If you would like more information about how we protect your privacy, please contact us.

About this policy

This privacy policy explains how we manage your personal information.

What is personal information?

Personal information includes any information or opinion, about an identified individual or an individual who can be reasonably identified from their information. The information or opinion will still be personal information whether it is true or not and regardless of whether we have kept a record of it.

The information that we seek to collect about you will depend on the products or services that we provide. If you do not allow us to collect all of the information we request, we may not be able to deliver all of those services effectively.

What kinds of personal information do we collect and hold?

When you apply for our products or services we may ask for identification information. This could include your name, address, contact details and date of birth. We may collect information about your financial situation and circumstances, depending on the type of advice.

Throughout the life of your product or service, we may collect and hold additional personal information about you. This could include transaction information or making a record of queries or complaints you make.

The collection of sensitive information is restricted by the Privacy Act. This includes information about your religion, racial or ethnic origin, political opinions, criminal record, and sexual orientation. It also includes health information and biometric information.

Generally, we only collect this sort of information if it is necessary to provide you with a specific product or service and you have consented to that collection.

For what purposes do we collect, hold, use and disclose personal information?

The main reason we collect, use, hold and disclose personal information is to provide you with products and services. This includes:

checking whether you are eligible for the product or service; providing the product or service; and helping manage the product or service.

We may also use your information to comply with legislative or regulatory requirements in any jurisdiction, prevent fraud, crime or other activity that may cause harm in relation to our products or services and to help us run our business. We may also use your information to tell you about products or services we think may interest you.

How do we collect personal information?

We collect most personal information directly from you. For example, we will collect your personal information when you apply for or use a product or service or talk to us in person, on the phone or via other communication methods (e.g. email, fax or online chat).

We also collect information from you electronically. For instance, when you visit our website or complete our online request forms.

Sometimes we collect personal information about you from other people or organisations. This may happen without your direct involvement. For instance, we may collect personal information about you from:

l    Other E-Trans companies;

l    publicly available sources of information, such as public registers;

l    your representatives (including your legal adviser, mortgage broker, financial adviser, executor, administrator, guardian, trustee, or attorney);

l    other organisations, who jointly with us, provide products or services to you;

l    commercial information service providers, such as companies that provide fraud prevention reports; and

l    company registers.

What laws require or authorise us to collect personal information?

We are required or authorised to collect:

l    certain identification information about you by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1);

l    your Tax File Number, if you choose to provide it, by the Income Tax Assessment Act 1936 (Cth);

How do we hold personal information?

Much of the information we hold about you will be stored electronically in secure data servers located in Australia and owned by E-Trans. Some information we hold about you will be stored in paper files. We use a range of physical and electronic security measures to protect the security of the personal information we hold. For example:

l access to information systems is controlled through identity and access management;

l employees are bound by internal information security policies and are required to keep

information secure;

l all employees are required to complete training about information security; and

l we regularly monitor and review our compliance with internal policies and industry best practice.

l we take reasonable steps to destroy or permanently de-identify any personal information after it can no longer be used.

Who do we disclose your personal information to, and why?

We may share your personal information with other companies within the E-Trans Group Pty.Ltd..

We may also provide personal information about our clients to organisations outside the E-Trans group of companies such as executing brokers. To protect personal information, we enter into contracts with our service providers that require them to comply with the Privacy Act. These contracts oblige them to only use the personal information we disclose to them for the specific role we ask them to perform.

Generally, we disclose personal information to organisations that help us with our business. These may include:

l    our agents, contractors and external service providers (for example, mailing houses and technology service providers);

l    authorised representatives who sell products and services on our behalf;

l    payment systems operators

l    other organisations, who jointly with us, provide products or services to you;

l    other financial services organisations, including banks, superannuation funds, stockbrokers, custodians, funds managers and portfolio service providers;

l    debt collectors;

l    our financial advisers, legal advisers or auditors;

l  your representatives (including your legal adviser, accountant, mortgage broker, financial adviser, executor, administrator, guardian, trustee, or attorney);

l   fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;

l    external dispute resolution schemes; and

l    regulatory bodies, government agencies and law enforcement bodies in any jurisdiction.

We may also disclose your personal information to others outside the E-Trans where:

l  we are required or authorised by law or where we have a public duty to do so;

l              you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or

l  we are otherwise permitted to disclose the information under the Privacy Act.

Do we disclose personal information overseas?

We may disclose your personal information to a recipient which is located outside Australia. This includes:

l    E-TRANS companies located in other country;

l    for international transactions, such as currency exchanges, we may need to disclose your information to the corresponding international party in order to process the transaction. The countries we disclose your information to will depend on the details of the transaction you ask us to carry out.

The personal information may be disclosed to the overseas recipient only when we reasonably believe that the overseas recipient of the information is subject to a law, or binding scheme. We may also disclose the personal information to overseas recipient if it is required or authorised by or under a law or a court/tribunal order, or if it is a permitted general situation described in the Privacy Act.

Do we use or disclose personal information for marketing?

l  We will use your personal information to offer you products and services we believe may interest you. These products and services only offered by one of E-TRANS companies. We may offer you products and services by various means, including wechat, mail, telephone, email, SMS or other electronic means , such as through social media or targeted advertising.

l   We may also disclose your personal information to companies outside the E-TRANS companies who assist us to market our products and services to you.

l   If you don’t want to receive marketing offers from us please contact us.

Do we collect personal information electronically?

We will collect information from you electronically, for instance through online accounts open application form. Any information that you enter on to an online application form will only be collected by us if you submit your online application. In other words, if you cancel your application or log out prior to submitting your application, any information which you had entered is automatically deleted.

Each time you visit our website, we collect information about your use of the website, which may include the following:

l  The date and time of visits;

l  Which pages are viewed;

l  How users navigate through the site and interact with pages (including fields completed in forms and applications completed);

l  Location information about users;

l  Information about the device used to visit our website; and

l  IP addresses.

We won’t ask you to supply personal information publicly over any social media platform that we use. Sometimes we may invite you to send your details to us via private messaging, for example, to answer a question about your account. You may also be invited to share your personal information through secure channels to participate in other activities, such as competitions.

We use technology called cookies when you visit our site. Cookies are small pieces of information stored on your hard drive or in memory. They can record information about your visit to the site, allowing it to remember you the next time you visit and provide a more meaningful experience.

One of the reasons for using cookies is to offer you increased security. The cookies we send to your computer cannot read your hard drive, obtain any information from your browser or command your computer to perform any action. A cookie only identifies your computer to a web server when you visit the site, they do not identify users.

Most web browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. You can refuse cookies by turning them off in your browser.

If your browser is configured to reject all cookies, you will be unable to use services on this web site that requires cookies in order to participate. You may still be able to use some information-only pages if you do not accept cookies.

Access to and correction of personal information

You can request access to the personal information we hold about you. You can also ask for corrections to be made. To do so, please contact us.

There is no fee for requesting that your personal information be corrected or for us to make corrections. In processing your request for access to your personal information, a reasonable cost may be charged. This charge covers such things as locating the information and supplying it to you.

There are some circumstances in which we are not required to give you access to your personal information.

If we refuse to give you access to or to correct your personal information we will give you a notice explaining our reasons except where it would be unreasonable to do so.

If we refuse your request to correct your personal information, you also have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.

If we refuse your request to access or correct your personal information, we will also provide you with information on how you can complain about the refusal.

Resolving your privacy concerns and complaints – your rights

If you are concerned about how your personal information is being handled or if you have a complaint about a breach by us of the Australian Privacy Principles, please contact us.

We will acknowledge your complaint as soon as we can after receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint.

We aim to resolve complaints as quickly as possible. We strive to resolve complaints within five business days but some complaints take longer to resolve. If your complaint is taking longer, we will let you know what is happening and a date by which you can reasonably expect a response.

If you are unhappy with our response, there are other bodies you can go to.

The Financial Ombudsman Service (FOS) can consider most privacy complaints involving providers of financial services.

FOS can be contacted at:

Financial Ombudsman Service

GPO Box 3

Melbourne VIC 3001

Phone: 1300 78 08 08 www.fos.org.au

Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information.

The Commissioner can be contacted at:

GPO Box 5218

Sydney NSW 2001

Phone: 1300 363 992 Email: enquiries@oaic.gov.au www.oaic.gov.au

Contact us

You can contact us as following:

Level 5, 350 Collins Street

Melbourne VIC 3000

Phone: +61 3 96021669 Email: Melbourne@etrans.com.au

Changes to the Privacy Policy

We may change the way we handle personal information from time to time for any reason. If we do so, we will update this Privacy Policy. An up-to-date version is available on www.etrans.com.au.