Barrenjoey Website Privacy Policy
Barrenjoey Capital Partners Group Pty Limited (ACN 640 529 228) and its related bodies corporate (Barrenjoey, we, us or our) respect the privacy of people we deal with and are committed to protecting the information provided to us by clients, employees, contractors, service providers, visitors to this website and other persons.
This Privacy Statement explains how Barrenjoey collects, stores, uses and may disclose personal information in accordance with the requirements of the Australian Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APP). Please also see our ADGM Privacy Notice.
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.
Sensitive personal information is personal information that includes information or an opinion about an individual’s racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; criminal record; health, genetic or biometric information or biometric templates.
We collect personal information reasonably necessary for us to carry on our business. Personal information we may collect includes:
- identity details, name, and contact details;
- employment and background information, and details of your work history, if you apply for work with Barrenjoey;
- personal information from employees, such as date of birth and, if you choose to provide it, your tax file number;
- potential business information with a view to creating third-party contractual or client relationships;
- information in electronic communications, including emails, instant messages and other communications records, which may be automatically captured and digitally stored securely; and
- information collected from publicly available sources, for instance, the media, social networking websites, regulatory websites, subscription entity and credit databases and criminal history record sources.
We collect personal information by lawful and fair means and not in an unreasonable or intrusive way. Provided it is reasonable and practicable to do so, and subject to 1.2 above and this 1.3, we will only collect personal information directly from you. You may choose not to provide us with your personal information. Without such information, we may not be able to provide you with an appropriate level of service. We are unlikely to collect sensitive personal information, unless required or permitted by law or where you consent.
We may collect personal information about you when you or your organisation uses or makes an enquiry via our website, seeks to do business with us or when you or your organisation offers to provide services to us. On occasions, we may also need to collect personal information from third parties, including public sources, your advisers, agents, brokers, statutory and regulatory bodies, and service providers (including credit reporting companies, fraud and financial crime information bodies, and other information service providers).
Your personal information will generally only be used or disclosed for the reasons for which it was collected; for a reasonably expected secondary purpose; or as otherwise permitted under the law, including the Privacy Act.
When we may use your personal information:
- any purpose for which you consent;
- offering and providing, products or services to you (including to your organisation);
- administering and managing products and services for you (including your organisation)
- operating and carrying on Barrenjoey’s business;
- conducting a client, employment, or contractual relationship with you;
- undertaking risk management functions as part of our operations;
- providing you with information about Barrenjoey and its products and services;
- conducting a client survey regarding our products and services (including potential products and services) or performance;
- communicating with you to manage any enquiries or complaints; or
- otherwise, in connection with Barrenjoey carrying out its business or operations.
We may disclose your personal information:
- to fulfil our legal and regulatory obligations, in Australia or any other jurisdiction, including but not limited to statutory and regulatory requirements, reporting, taxation, audit requirements, anti-money laundering, anti-terrorism financing and sanctions requirements, or in connection with legal or investigative proceedings;
- to a third party for a legal or regulatory requirement or request; or in accordance with laws, regulations, or the rules of any relevant exchange, depository or clearing house;
- to trade repositories or similar institutions (and related third party service providers), in accordance with laws and regulations, directive or otherwise;
- to our financial institution and any financial institution or intermediary with which you or your organisation engage or propose to engage in connection with our services;
- to any service provider in order to conduct our business or that provides services in connection with our operations, for example, information technology and data service providers, business analysts or companies carrying out background and credit checks on our behalf;
- to our officers, employees, agents, subcontractors, advisers, auditors, insurers, consultants and associates in connection with the conduct of our business; as permitted by law, or
- as outlined in the terms and conditions of any specific products or services or in our Terms of Business.
In some circumstances, the parties to whom we disclose personal information may operate outside of Australia, this includes locations in the countries listed at 1.12 below. When this occurs, Barrenjoey takes reasonable steps to protect personal information against misuse or loss and must comply with certain safeguards under the Privacy Act in respect of the transfer of your data from one jurisdiction to another. Those parties may make such personal information available to their regulators and government of such countries in accordance with their respective local law requirements.
We keep personal information secure which includes any information that is collected via our website or from telephone recordings or which is held in either hard copy files or electronically on our computer systems either on our premises or off-site with service providers. We take all reasonable security measures to protect the personal information we hold from interference, misuse, loss and from unauthorised access, modification or disclosure, limit employee access to personal information to a ‘need to know’ basis and take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the personal information may be used and disclosed under this statement.
Your personal information will be retained for not less than the period we are legally required to keep records.
You can request access to personal information that we hold about you at any time. We will provide the information we hold unless for legal or administrative reasons we are unable to do so. Barrenjoey will respond to a request for access to personal information within a reasonable time and will attempt to provide you with convenient access to this information in the way you have requested.
You are also able to request to have any inaccurate personal information we may have about you corrected or request us to restrict our ongoing use of your personal information, which we will do if this is practicable and we are legally entitled to do so in the circumstances.
While we do not currently anticipate doing so, we may use or disclose your personal information for direct marketing purposes. If you do not wish to receive direct marketing about us and our products and services, you can opt out at any time by sending us a request using the contact details below.
The notifiable data breaches scheme requires us to notify affected individuals and the Australian Information Commissioner of certain data breaches. If a data breach occurs, we will perform an assessment whether the access or disclosure of personal information is likely to result in serious harm to the individual(s) to whom the personal information relates (this may be an ‘eligible data breach’). If we assess there has been an eligible data breach, affected individuals will be notified as soon as practicable of the details of the breach and the recommended steps the relevant individual(s) should take in response to it. If required under the Privacy Act, we will inform the Australian Information Commissioner.
Personal information may be disclosed to third parties in jurisdictions outside Australia including: New Zealand, Hong Kong, Singapore, United Arab Emirates, United Kingdom, United States, Japan and European Union member countries.
If you have any questions or complaints about this statement or our collection, use or disclosure of your personal information, please contact the Barrenjoey Privacy Office at enquiries@barrenjoey.com
If you require any further information on Australian privacy laws, you may also contact the Office of the Australian Information Commissioner on 1300 363 992, or by visiting their website at www.oaic.gov.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.
www.barrenjoey.com is owned and operated by Barrenjoey. You must not use our website or any of its content in any manner which violates our rights with respect to intellectual property, logos, copyright and trademarks claimed over information and content on this site.
We may collect information about you through your access to this website. We may use or disclose information gathered via your use of this site for general business purposes, other than personal information, which will be dealt with in accordance with this privacy statement.
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