- Version: September 2024
- 1. Introduction
- Peninsula Capital Investment Management Pty Ltd ABN 46 668 438 373 (“Peninsula Capital”, "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and manage your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). We take just as much pride in providing you with data protection as we do in providing you with our core products and services. This notice is to inform you on our adherence to the obligations of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) as well as the steps we have taken to provide security and protection for the data you have provided. By using our Website, social media, products or services, you agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy.
- 2. Collection of Personal Information
- Personal information as defined in the Privacy Act includes any information or opinion about a reasonably identifiable individual, whether itis true or not, and whether it is recorded in a material form or not. It includes personal information provided to us by you, provided to us by a third party, or collected through our website.
We may collect the following types of personal information:
a) Personal Identification Information: Name, date of birth, gender, residential address, Tax File Number, email address, phone number, and other contact details.
b) Financial Information: Bank account details, credit card information, transaction history, details of employment, income, assets and other financial details necessary for providing our services.
c) Identification Documents: Government-issued identification such as a driver's license, passport, or Medicare card.
d) Employment and Income Information: Employment status, salary details, and other relevant employment information.
e) Digital Information: We collect information from you electronically when you interact with us online. This may include your IP address, browser type, operating system, and information about your use of our website and/or mobile applications.
- 3. How We Collect Your Information
- We may collect personal information directly from you when you:
a) Enquire about or use our services.
b) Communicate with us via email, phone, or other communication channels.
c) Use our website.
We may also collect your information from third parties, such as credit reporting bodies, government agencies, or other financial institutions, where you have consented to the disclosure or where itis required by law.
We will provide individuals with the opportunity to remain anonymous or use a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). It is generally not practicable for us to deal with individuals anonymously or pseudonymously on an ongoing basis, and if we do not collect personal information about you, you may be unable to utilise our services, access information or otherwise interact with us. We may be required or authorised by or under an Australian law, or a court/tribunal order, to only deal with individuals who have identified themselves, in which case you may not be able to deal with us if you choose to remain anonymous or use a pseudonym.
We generally do not collect your personal information unless (a) it is provided to us voluntarily by you directly or via a third party who has been authorised by you to disclose your personal information to us, or (b) collection and use of personal information without consent is permitted or required by the relevant laws. We will seek your consent before collecting any additional personal information and before using your personal information for a purpose which has not been notified to you (except where permitted or authorised by law).
- 4. Use of Personal Information
- We use your personal information to:
a) Provide, manage, and enhance our service offering.
b) Verify your identity and conduct credit checks.
c) Process transactions, payments and manage accounts requested by you.
d) Communicate with you about your account and our service offering.
e) Managing your relationship with us.
f) Help identify products or services that may interest you and provide you with relevant information about them (but you may unsubscribe from our marketing updates at any time)
g) Any other incidental business purposes related to or in connection with the above.
h) Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you.
i) Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority,
j) Any other purposes for which you have provided the information.
k) Detect and prevent fraud, misconduct, or other unlawful activities. Improve our website, service offering, and customer experience.
- 5. Disclosure of Personal Information
- We may disclose your personal information:
a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;
b) the disclosure could be to related companies, affiliates or other third party service providers we have engaged to perform any of the functions with reference to the above-mentioned purposes
c) Credit reporting bodies and financial institutions.
d) To Government agencies, regulators, or law enforcement where required or authorised by law.
e) To any other party with your consent or as required to provide our services to you.
- 6. Cross-Border Disclosure
- We may disclose your personal information to entities located outside Australia. These countries are likely to include England or United States. When doing so, we takereasonable steps to ensure that the overseas recipient does not breach the APPs concerning your personal information
- 7. Withdrawing your content
- This Website utilises cookies. If you do not have cookies enabled in your web browser some functions of the site may not work as intended.
a) The consent that you provide for the collection, use and disclosure of your personal information will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal information for any or all of the purposes listed above by submitting your request inwriting or via email to our Privacy Officer at the contact details provided below.
b) On receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we will seek to process your request within fourteen (14) business days of receiving it.
d) Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we will, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above. ·
e) Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
- 8. Security of Personal Information
- We are committed to ensuring the security of your personal information. To safeguard your personal information from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, web security measures against risks, usage of one time password (otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, credential exposure checks, and device vulnerability assessments and security hardening.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures
- 9. Access to and Correction of Personal Information
- We generally rely on the completeness and accuracy of personal information provided by you. You have the right to access and correct your personal information held by us. We will not charge you for providing you with access to your personal information, but reserve the right to charge you a reasonable amount in compiling this information in response to your request. Please contact us in writing using the details provided below if you would like to access or correct your personal information. We will respond to your request within a reasonable time frame and in accordance with the Privacy Act.
- 10. Complaints and Enquiries
- If you have any concerns or feedback on our personal information protection policies and procedures, or if you wish to write in to the Privacy Officer address: privacy@peninsulax.com.
We take privacy complaints seriously and will respond promptly to your concerns. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) as shown on their website https://www.oaic.gov.au/.
- 11. Effect of Notice and Changes to Notice
- We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes, and by continuing to use our Website, social media, products or services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy (as updated from time to time).
- 12. Contact Us
- If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@peninsulax.com.
