Privacy Policy

Aitken Mount Capital Partners Pty Ltd (ACN 169 972 436) (‘Aitken Mount’) (‘We’) (‘Our’) is committed to protecting and handling information that we collect about you in accordance with the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (‘APP’).

This document sets out Aitken Mount’s Privacy Policy and the measures that We followed to keep your information confidential and secure.

Information that We Collect and Hold about you.

Aitken Mount is required under relevant Australian Laws to collect and hold personal information about you. We will only collect personal information which is reasonably required for us to:

• Provide the financial services that we authorised to provide under our AFSL;
• Comply with Australian Laws including the Corporations Act 2001 (Cth), the Corporations Regulations 2001 and the Anti Money Laundering & Counter Terrorism Financing Act 2006 (Cth); and
• Be able to contact you in relation to the financial services we provide.

Personal information that We reasonably are required to collect and hold about you may include the following:

• Transaction details of your dealings in financial products;
• Records of our interacts with you by phone, email or letter; and
• Personal details such as name, address, date of birth, contact phone number and email address.

When We collect personal details about you, We will only collect that information directly from you except where another person is authorised to provide that information on your behalf, for example a manager or principal of the organisation that employs you.

When do We collect information about you

Personal information that We collected about you is when:

• you hold an account with us in your own name; or
• you hold an account in the name of an entity that you either own or control; or
• you are an employee who is authorised to place orders on behalf of an entity such as a financial institution or family office.

Some of this information is collected at the time of opening an account with Aitken Mount and some of this information is collected each time you place an instruction with us to deal in financial products.

Without collecting this information, We would not be able to provide financial services to you or the organisation that you are authorised act on behalf of.

We generally do not collect sensitive information about you, unless it is required to be collected by law and you have consented to this information being collected by us.

How We use your information

We hold personal information that We have collected about you on file.  We may also pass this information onto our service providers who We have engaged, such as our executing broker, so that they are able to comply with their obligations under relevant Australian Laws.  Where personal information is required to be passed onto our service providers, We will only do so after entering into a service agreement with them which contains Terms and Conditions around maintaining confidentiality of such information and where they have a Privacy Policy in place.

How We store your information

We hold your personal information in electronic form and where We have done so, We have engaged the services of IT professionals to ensure that all such information is held securely.  We may also hold personal information at our executing broker who is also subject to regulatory requirements to have arrangements in place that meet the requirements of the Australian Privacy Principles to keep your personal information confidential and to store your information securely.

Generally, we do not hold personal information outside of Australia, however our service providers may, as part of their IT arrangements, hold information outside of Australia.  Where our service providers have IT arrangements where personal information is stored overseas, for example as part of a cloud storage arrangement, our service providers must ensure that personal information is only held in overseas jurisdictions that have Privacy Laws that are comparable to those in Australia.

We will hold personal information about you for the minimum period required under Australian Laws.  After the statutory period for holding personal information has been reached, we will determine whether the personal information may be lawfully destroyed.  We will not destroy your personal information while We continue to provide financial services either to you, or to your controlled entity or to the institution that you are employed by.

Security of Personal Information

Aitken Mount will only use personal information for the purposes for which it has been collected. We will take reasonable steps to ensure personal information is protected from misuse, interference and loss, and from unauthorised access, modification or disclosure. Our executing broker also has arrangements in place to ensure personal information is protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.

Unsolicited personal information

If Aitken Mount receives unsolicited personal information about you, the unsolicited personal information will assess for the following:

• Determine whether the personal information would be entitled to be collected in accordance with this Privacy Policy;
• If the personal information could be collected under this Privacy Policy, We will inform you that unsolicited personal information has been received about you;
• We will inform you about the circumstances around how it was collected; and
• Inform you about accessing a copy of this Privacy Policy.

If the personal information could not be ordinarily collected by Aitken Mount, We will either destroy the information or de-identify the information about you.

Keeping personal information up to date

Under our Privacy Policy, We will take reasonable steps to keep your personal information current.  Should you become aware that the personal information We hold in our records about you becomes out of date, We ask that you immediately advise us of the updated information so that We may correct and keep your personal information current.

Should you wish to access your personal information held by us, We will provide you with a copy of the information that We hold about you in within a reasonable period of time after you have made that request.  While there is no charge for requesting access to your personal information, We may charge a fee to provide that information where We believe it is reasonable and not excessive.

Anonymity and personal information

APP sets out that entities must give individuals the option of not identifying themselves, or to using a pseudonym.  This privacy principal is not practical or permitted for the purposes of Aitken Mount providing financial services to you.

Should your personal information relate to your proposed or actual dealings involve inside information (as that term is defined under the Corporations Act) and is subject to the insider provisions of the Corporations Act, We will deal with that information in accordance with our policy on handling inside information including those aspects of personal information that forms part of the inside information.

Marketing

Aitken Mount will only use your personal information for the purposes of soliciting business from you where We have a reasonable belief that you may be interested in that business or it is relevant to the ordinary course of your business.  This contact may include bringing to your attention information about securities that has already disclosed in the market place, or market soundings conducted in accordance with our market sounding policy.  You may opt out at any time from receiving contacts from us on an unsolicited basis or decline to participate in a market soundings.

We will never provide your personal information to any third party for any purpose what so ever where the provision of personal information is unrelated to the provision of our financial services to you, other than that which is required to be provide under Australian laws to a Government statutory body such as the Australian Taxation Office, the Australian Securities and Investments Commission or to our executing broker pursuant to their obligations under the ASIC Market Integrity Rules.

Complaints About a Breach of the APP

The APP provides some exceptions to providing access to personal information.  Should We rely on one of the exceptions or are unable to provide the personal information in the manner you have requested, We will take reasonable steps to give access to the information that meets the needs of both you and us.  In such an event, we will provide written communication to you setting out:

• The basis for refusal to provide you access, setting out what We have taken into consideration as the grounds for the refusal, where it would be unreasonable to do so;
• Provide the process available to you to complain in relation to the refusal; and
• Other such details relevant to the matter.

We will always act reasonably in regards to requests for access to personal information and would always seek a resolution to a complaint that is satisfactory to both you and ourselves.

Should you remain unsatisfied and wish to make a complaint to Aitken Mount about a likely breach of the APP, you may do so by contacting us by phone or by addressing your complaint in writing to the Privacy Officer and send to:

Aitken Mount Capital Partners
52 Victoria Street
Paddington , NSW 2021, Australia