Where in this policy the terminology used refers to “we’’, ‘’us’’, ‘’our’’ it shall refer to Halcyon Global Pty Limited and where the terminology used refers to ‘’you’’, ‘’the client’’, ‘’your’’ it shall refer to the individual to whom this policy pertains to, or any natural or legal person in a client relationship with the company and who has used or is actively using our products and services.
This privacy statement and/or policy provides an overview of how we collect, process, protect and use your personal data, and informs you about your rights under the Privacy Act 1988 (Cth) (“Privacy Act”).
Collection of personal information
We collect personal information from you in relation to your use of our products and services. It is important to understand why and how we collect and use this information. We may gather data from you such as your:
- Physical location;
- Telephone Number;
- Email Address;
- And other related information as reasonably necessary or directly related to services and products provided by us.
We collect your personal information to better provide quality services to you and to comply with any and all legal and regulatory requirements. Other purposes for which we collect personal information include:
- To verify client identity to prevent identity theft and comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”);
- To contact or notify you as necessary;
- For dispute and risk management purposes;
- For informational and financial security purposes; and
- To assist the activities of the relevant regulatory and enforcement agencies (e.g. ASIC, AUSTRAC etc.).
Halcyon Global will never collect sensitive information about an individual without prior written consent, or where the law or a court/tribunal order requires or authorises us to do so. We will endeavour to collect your personal information from you directly, but where it is unreasonable or impractical to do so we will notify you as soon as practicable if your personal information has been collected from a source other than yourself.
In the event that we do collect your personal information, we will notify you as soon as reasonably practicable, or otherwise ensure that you are aware of our collection of your personal information.
Access to and correction of personal information
Your right to access to Personal Information
Pursuant to our obligations under the Privacy Act, we will endeavour to ensure that the information we collect, hold and use is relevant and up to date. Should you wish to access your personal information held by us, you may request that we provide you with this personal information by emailing firstname.lastname@example.org and we will strive to accommodate you by responding to your request within a reasonable period of time after the response is made. We may choose to charge you a small sum for accessing your information.
However, we can choose not to give you access to personal information if doing so would pose a serious risk of injury or safety, or would prejudice the privacy of other individuals, or if giving access is unlawful or forbidden by court/tribunal order, or if doing so might adversely or materially affect any proceedings or disputes between you and us. However, we may still provide you with some of this information to the extent that it does not impact upon the aforementioned reasons. If we refuse to give you access or full access, we will provide you with a written notice detailing why we have rejected your request and any mechanisms available to you to complain about our decision (see “Making a complaint” below).
Your right to correct personal information
Should you wish to correct your personal information, simply email us at email@example.com and we will update it accordingly. We will respond to any request to correct information within a reasonable period of time after your request is received. Similarly, if we refuse to fully amend your information, we will provide you with a written notice detailing why we have rejected your request and any mechanisms available to you to complain about our decision (see “MAKING A COMPLAINT” below).
Use and disclosure of personal information
We will not use or disclose your personal information for any purpose it was not collected for, unless you have consented to that disclosure, we are required to do so by law or a court/tribunal order or if the use/disclosure is reasonably necessary or expected.
As per this policy, Halcyon Global may disclose your personal information to additional parties. We may choose to disclose your personal information to the below parties in connection with us providing you our products and services:
- Individuals or companies in the employ of Halcyon Global whether staff or contracted, either in Australia or overseas;
- Authorised agents of Halcyon Global;
- Financially related institutions and other comparable entities regarding our corporate activities or that are named by you;
- Organisations which you request us to or any persons acting on your behalf, which may include your financial adviser, broker, solicitor or accountant.
- Other entities to whom disclosure is reasonably necessary to facilitate the use of our services.
- We may disclose information to third parties provided to us by you in order to substantiate your identity(ies) and other personal details, in accordance with our AML/CTF Act obligations. Your personal information can also be disclosed by us to facilitate the activities of relevant enforcement agencies such as ASIC or AUSTRAC.
Similarly, where your personal information has been disclosed to overseas recipients, we are legally bound to take reasonable steps to ensure that these recipients do not breach the principles contained within the Privacy Act unless you consent otherwise or the recipient in question is located in a country with a similar scheme to the Privacy Act.
We may use your personal, non-sensitive information collected from you for, to the extent permissible by the relevant laws and regulations, the purpose of informing you about products and services that may be relevant or useful to you. However, you can request that we refrain from doing so by emailing firstname.lastname@example.org and letting us know.
Halcyon Global records incoming and outgoing calls between you and Halcyon Global representatives. These recordings or transcripts may be used as evidence in the event of a dispute between you and Royal, or otherwise for training purposes.
How we keep your information secure
We are committed to the protection of your privacy and adhere closely to the Australian Privacy Principles contained in Schedule 1 of the Privacy Act. Your privacy is important to Halcyon Global and as such we take plausible steps to protect your personal information from misuse, interference by unauthorised persons, loss, unauthorised access, erroneous modification and unauthorised disclosure.
If we hold personal information that we no longer need (for use, disclosure, to meet legal/regulatory requirements etc.) then we will take reasonable steps to destroy or de-identify said information.
Halcyon Global may use “cookies”. Cookies are text files placed on your hard drive by your web browser for operational and record keeping purposes. These cookies sometimes track information about you. You may choose to disable cookies in your web browser or alerts when cookies are sent; however, doing so may cause web pages to function incorrectly.
Halcyon Global uses the information from cookies to improve our website’s accessibility and relevance, generate promotions, contests, surveys and likes according to the interests of our users.
Making a complaint
It is Halcyon Global policy that all complaints undergo an internal review process before resolution or escalation. Halcyon Global aims to provide a resolution to all complaints within 14 days from the date of complaint. If you are dissatisfied with the process or conclusion you are welcome to contact Halcyon Global to discuss the outcome.
If you are still unsatisfied, you can make a complaint to the Office of the Australian Information Commissioner (“OAIC”), the government agency responsible for privacy and security.
The details of the OAIC are:
Level 32, 101 Miller St
North Sydney NSW 2060
Halcyon Global Pty Limited (ACN 623 074 251) Halcyon Global It is an Authorised Representative (Number: 001275105) of Royal Financial Trading Pty Ltd (ACN:157 780 259) AFSL 420268. Royal Financial Trading Pty Ltd (“Royal”) is the issuer of the products and provider of the platform described on this site.
Halcyon Global is only authorised to provide financial services to wholesale clients (as defined in sections 761G and 761GA of the Corporations Act).