隱私保障政策

This Policy applies to Hantec Markets (Australia) Pty Ltd (ACN 129 943 086) and any holding companies, subsidiaries or related entities, all of which arereferred to as “HMA”, “we”, “our”, “us”. The Policy extends to and covers all operations and functions of HMA. At HMA, we are committed to ensuring the confidentiality and security of the personal information supplied by individuals. HMA is bound by the National Privacy Principles ('NPPs') contained in the Privacy Act 1988 (C’th) ('Privacy Act').

The word “individual” refers to a customer, client, trustee or any other person with whom we come into contact. All contractors, sub-contractors, vendors, service providers, customers, agents or any other third parties that have access to and/or utilise personal information collected and/or held by HMA must abide by this Privacy Policy.

“Personal information” is information or an opinion relating to an individual, which can be used to identify that individual. Some personal information, which we collect, is 'sensitive information'. Sensitive information includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, which is also personal information, and also includes health information about an individual.

“Sensitive information” means personal information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, which is also personal information, and also includes financial details about an individual, including his bank account details and credit history.

1. How we collect personal information

As the provider of financial services, we may collect sensitive information about an individual’s personal circumstances and financial details such as their bank account details, and credit history, which may potentially identify the individual and/or contains an opinion about the individual.

Our ability to provide individuals with our services and advice is sometimes dependent on us obtaining certain personal information about the individual. Typically, the type of personal information we collect about the individual includes his or her name, age, date of birth, occupation, mailing address, phone numbers, email address and other information that is relevant to the services we provide.

The personal information may also include information about the form of identification used in relation to an individual to send or receive a transaction (required by law in some instances), and information about a transaction in relation to an individual, including details of the amounts paid in or out of an individual’s account as well as delivery instructions.

The personal information may also include:

1.1 employment details, employment history, family commitments and social security eligibility;

1.2 details of the individual’s financial needs and objectives;

1.3 details of the individual’s current financial circumstances, including assets and liabilities, income, expenditure, insurance cover and superannuation;

1.4 details of the individual’s foreign exchange preferences and aversion or tolerance to risk; and 1.5 health information (asappropriate).

We generally collect personal and/or sensitive information from the individual by the following methods:

1.6 directly from applications, questionnaires and/or forms completed by individuals who wish to use our services or to apply for aposition in our organisation;

1.7 from information disclosed to us by an individual on the phone, or by sending us correspondence (by letter, fax or email) or contact us in person;

1.8 from information disclosed to us by an individual via our website and online trading platform; and

1.9 from a variety of third party sources, including our business contacts credit reference and credit checking agencies, and financial institutions.

The above list is not exhaustive.

In some circumstances HMA may be provided with personal information about an individual from somebody else, for example a referral from another person. HMA will take reasonable steps to inform the individual that it holds the personal information and the purpose for which it holds the personal information.

HMA must not collect sensitive information unless the individual has consented, or it is required by law, or in other special specified circumstances.

If the personal information we request is not provided, we may not be able to process an individual’s application to transfer funds as requested, or provide individuals with the benefit of our services, or meet an individual’s needs appropriately.

2. Why do we collect personal information?

HMA collects personal information for the following purposes:

  • to conduct our business of providing foreign exchange and other services to our clients and to their counter parties;
  • to enter into contracts with sub-contractors to conduct our business;
  • to assess applications by individuals to provide them with our services;
  • to comply with our legal obligations; and
  • to help us manage and enhance our services.

3. About whom do we collect personal information?

The type of information we may collect and hold includes (but is not limited to) personal information about:

  • individuals;
  • third parties;
  • prospective employees; and
  • other people with whom we come into contact.

4. How might we use and disclose personal information?

When we refer to “use “of personal information, we mean use within our organisation, for the purposes outlined above. When we use the word “disclose” we mean providing the information to persons outside our organisation.

HMA may use and disclose personal information for the primary purposes for which it is collected, and also for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (eg, where required by law).

We may use and disclose personal information for the following purposes:

  • to conduct our business of providing foreign exchange and other services to clients and to their counterparts;
  • to enter into contracts with sub-contractors to conduct our business;
  • to collect and analyse statistical information regarding the number of visitors to our website and our online trading platform;
  • to assess applications by individuals to provide them with our services;
  • to help us manage and enhance our services;
  • to communicate with individuals, by providing them from time to time with information contained in newsletters, emails or  brochures;
  • to comply with our legal obligations.

We do not disclose personal information we collect to others for the purpose of allowing them to direct market their products and services. We do not use or disclose sensitive information for direct marketing purposes.

We may engage other people to perform services for us which involves that person handling personal information we hold. In these situations, we prohibit that person from using personal information about you except for the specific purpose for which we supply it.

In relation to sensitive information held by us about an individual’s financial history, credit worthiness or bank account details, wherever possible, HMA will attempt to de-identify the information. We also undertake to delete all personal information about an individual when it is no longer needed or relevant.

We may disclose personal and/or sensitive information to:

  • third parties;
  • a related company;
  • consultants we engage to assist individuals;
  • consultants we engage to manage our business;
  • organisations involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables);
  • organisations involved in managing our corporate risk and funding functions (eg securitisation);
  • our lawyers;
  • our accountants;
  • our compliance consultants;
  • regulatory authorities, including the Australian Securities and Investment Commission (ASIC), if required by law; and
  • anyone else to whom the individual authorises us to disclose it.

We also collect personal and/or sensitive information from these organisations and individuals, and deal with that information in accordance with this Policy.

5. Sending information overseas

We will not send personal or sensitive information to recipients outside of Australia other than to a related company without:

  • obtaining the individual’s consent (in some cases this consent will be implied); or
  • otherwise complying with the NPPs.

We will not send personal or sensitive information to recipients in a foreign country that is not subject to an information privacy scheme similar to the Privacy Act, without the consent of the individual.

6. Management of personal information

The NPPs require us to take all reasonable steps to protect the security of personal information. HMA personnel are required to respect the confidentiality of personal information and the privacy of individuals. HMA will seek to ensure that individuals’ personal information is protected from misuse, loss, unauthorised access, modification or disclosure.

HMA takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Where we no longer require the personal information for a permitted purpose under the NPPs, we will take reasonable steps to destroy it.

In the event that an individual ceases to be a client of HMA, the individual’s personal information will be kept for a period of 7 years in accordance with legislative requirements, after which the information will be destroyed.

7. Identifiers

We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes.

8. How do we keep personal information accurate and up-to-date?

HMA takes reasonable steps to ensure that the personal information it holds is accurate, complete and up-to-date. We encourage individuals to contact us in order to update any personal information we hold about them. Our contact details are set out below.

Hantec Markets (Australia) Pty Ltd
Level 25, 2 Park Street
Sydney NSW

9. Access to personal information

Subject to the exceptions set out in the Privacy Act, individuals may gain access to the personal information, which HMA holds, about them by contacting the HMA Privacy Officer. If we refuse to provide the information, we will provide reasons for the refusal and inform the individual of any exceptions relied upon under the Privacy Act. We will endeavour to respond to any request for access within 14 -30 days of the request depending on the complexity of the information requested.

We will require identity verification and to specify what information is required. An administrative fee for search and photocopying costs may be charged for providing access. We will advise the likely cost in advance.

10. Updates to this Policy

This Policy is dated 1 January 2009, and will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.

11. Responsibilities

It is the responsibility of management to inform employees and other relevant parties that Privacy Policy is maintained and enforced. Management must ensure that they periodically advise HMA’s employees and other relevant parties of any changes or any new Privacy Policies in a timely manner. It is the responsibility of all employees and other relevant parties to ensure that they understand and adhere to this Privacy Policy. Ignorance of the existence of the Privacy Policy will not be an acceptable excuse for non-compliance.

12. Privacy Training

All new employees must be provided with timely and appropriate access to HMA’s Privacy Policy. All employees must be provided with opportunities to attend appropriate and periodic Privacy awareness training and must ensure that they understand the Privacy related issues that could adversely affect HMA’s position if not properly adhered to.

13. Non-compliance and disciplinary actions

Any HMA employee or relevant third party that identifies, knows about or suspects a Privacy breach must immediately report the matter to the Privacy Officer. Employees or other relevant parties that contravene or do not comply with HMA's Privacy Policy may be subject to disciplinary action.

14. Incidents/Complaints Handling

If an individual has a privacy complaint, he is required to send it in writing to the Privacy Officer.

HMA has an effective incidents/complaints handling process in place to manage privacy risks and issues. The incidents/complaints handling process involves:

  • identifying (and addressing) any systemic/ongoing compliance problems,
  • increasing consumer confidence in HMA’s privacy procedures; and
  • helping to build and preserve HMA's reputation and business.

15. Contractual arrangements with third parties

HMA must ensure that all contractual arrangements with third parties adequately address privacy issues.

Each third party is aware of and understands this Privacy Policy, and has implemented policies in relation to the management of personal information in accordance with the Privacy Act, including:

  • regulating the collection, use and disclosure of personal information;
  • de-identifying personal information wherever possible;
  • ensuring that personal information is kept securely, protected from loss or misuse, with access to it only by authorised
     employees or agents of the related organisations; and
  • ensuring that personal information is only disclosed to organisations which are approved by HMA.

The third parties specifically agree only to use personal information for the purposes consented to by HMA or by the individual concerned.

16. Privacy Audits

HMA conducts periodic privacy audits in order to ascertain:

  • what sort of personal and/or sensitive information is collected and held;
  • how that information is collected;
  • what the reasons are for collection of that information;
  • where and how that information is stored;
  • how that information is secured;
  • who has access to that information;
  • whether that information is shared with anyone;
  • whether the intended use of collection is communicated; and
  • whether that information is current and necessary.

17. Website

HMA’s website contains links to other websites whose operator may or may not adhere to a privacy policy or be governed by the NPPs.

When an individual accesses our website, our website uses cookies which allow us to identify the individual’s browser. Cookies do not identify the individual – they simply allow us to track usage patterns so that HMA can measure the level of interest in various areas of its site. All browsers allow individuals to be notified when they receive a cookie and elect whether to accept it.

We may also use third parties to analyse traffic at our website, which may involve the use of cookies. Information collected through such analysis is anonymous. Our website privacy policy can be accessed by clicking on the privacy button on our website.

18. Enquiries

If you have any questions about privacy-related issues please contact the HMA Privacy Officer:

Joanne Ding

Telephone: (02) 8016 8099

Fax: (02) 9261 2672

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PRIVACY STATEMENT:

HMA Privacy Statement:

Hantec Markets (Australia) Pty Ltd (ACN 129 943 086) (“HMA”) is committed to ensuring the confidentiality and security of the personal information of its clients, and is also committed to complying with both the Privacy Act 1988 (Cth) and the Financial Transaction Reports Act 1988 (Cth). The HMA Privacy Policy detailing our handling of personal information is available upon request. You may request access to information held about you by contacting the HMA Privacy Officer, Joanne Ding at (+612) 8017 8099.

If you do not provide some or all of the information requested on our application form or on our website, we may not be able to accept your application to transfer money or otherwise provide you with our services.

HMA may use information received from its clients to send marketing material to its clients from time to time unless you elect not to receive it. HMA will not provide your information to any third party other than in accordance with the HMA Privacy Policy.

If you do not wish to receive any promotional material from HMA, please send us a written application letter via email or mail.

 

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Address: Level 25, Citigroup Centre, 2 Park Street, Sydney, NSW, 2000, Australia

 

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