Introduction
Policy is made on behalf of Xynon Pty Limited (ABN 40 681 505 617, referred to as Xynon, we, our or us).
Xynon recognises an individual’s right to privacy and understands the protection and confidentiality of your personal information is important to you. Xynon is bound by the Privacy Act 1988 (Cth).
This Privacy Statement outlines the type of personal information we collect, how that information is collected, used, stored, and protected, and to whom we may disclose your personal information. We may also provide you with additional information about how Xynon will use your personal information at the time that it is collected.
Unless otherwise stated “Employee” refers to all full time and part time employees, contractors and consultants.
Personal information we collect
Any information that identifies you is deemed to be “personal information” and we primarily collect this information through our standard forms, information you provide through our website, and when you phone or contact our staff.
The type of personal information Xynon collects from you includes – your name, contact details (such as your address and telephone number), date of birth, investment details, bank account information and tax file number. The Corporations Act 2001 (Cth) requires us to collect your name, address, and date of birth. Australian anti-money laundering laws may also require us to collect additional personal information from You.
Phone calls to Xynon staff may be recorded or monitored for quality control, training, regulatory or other compliance reasons.
When browsing our website Xynon’s webservers automatically collect standard information as part of the HTTP web protocol – your IP address, browser type, operating system, access times, referring sites, pages viewed and other anonymous information. From time to time, Xynon may use ‘cookies’ in its website and may collect ‘clickstream’ data. Cookies and clickstream data collects information about your use of our website and potentially other websites.
How we use personal information
Xynon uses your personal information to administer your investment, comply with relevant laws and communicate with you on an ongoing basis about your investment. We may also send you educational and marketing material about our other products and services we offer – you may contact us at any time to ask us not to send this information.
Xynon may use information that you provide through our website or over the phone for analysis to improve our products and services.
Staff may also use personal information to verify your identity over the phone.
We may share your information with other persons and entities within our corporate group including our related bodies corporate. In some circumstances Xynon may disclose your personal information to persons/entities outside of Xynon. We are unlikely to disclose your personal information to overseas recipients.
For example:
- Xynon uses agents and external service providers to help us provide our services
- Xynon will facilitate the opening of your Broker, CMA and other third-party accounts required for the service provided
- From time to time, we may be required to provide your details to a governmental or regulatory body (such as ASIC, ATO, AUSTRAC, or a law enforcement agency).
- A court order may require us to disclose certain information
- Xynon takes steps to ensure that our agents and third parties keep your personal information confidential and use it only for the purposes for which they, and Xynon, are authorised.
- You may also authorise us to disclose information we hold about you to your financial adviser, accountant or other person nominated by you. Your express consent is required
Exemptions Note – Xynon intends to rely on some of the exemptions permitted under the Privacy Act. For instance, the exemption for disclosing personal information to our related bodies corporate. Similarly, the employer exemption relates to employee records (we have, however, adopted several measures designed to protect the privacy of our employees).
* If you nominate an individual contact within an Advisory firm or Administrative firm, you will be taken to have given authority to the firm and as well as the individual contact.
Third parties
Where your specific consent has been provided for portfolio data being shared with the third party, Navexa Services Pty Ltd (ACN 639 386 539) for the purpose of generating tax and performance reports, this data will be used solely for creating reports and will be handled in accordance with this Privacy Policy. Xynon have taken care and undertaken due diligence in selecting a third party, your access to the service is in accordance with the Navexa terms and conditions.
Xynon regards the security of your personal information as a priority and has several physical and electronic protection measures in place.
You should be aware that the Internet is not a secure environment. Whilst Xynon takes reasonable steps, we cannot guarantee the security of information you provide to us via our website or that we make accessible to you via the secure Investor site. No personal data is stored on our public website.
Personal data is stored on our secure Investor site.
Access to your personal information
In many circumstances, you can request access to personal information we hold about you. Sometimes it is not possible for us to give you access in which case we will explain why.
You may also ask us to correct information which we hold about You, which is inaccurate, incomplete, or out of date.
Withdrawing Consent of Access to Personal Information
You can withdraw your consent at any time. the Company will make sure the process is easy and accessible, and that you understand the possible consequences of withdrawing your consent. For example, you may no longer have access to a Xynon service.
Once you withdraw consent, the Company will no longer be able to rely on your past consent for any future use or disclosure of your personal information.
If you have any questions about this Privacy Policy or how we handle your personal information, please send us an email to hello@xynon.com.au
What if I have a complaint or concern?
If you wish to make a complaint about how Xynon has handled your personal information or wish to access or correct your personal information held by us, please contact our Company Secretary and Privacy Officer, at hello@xynon.com.auor write to us Level 9, 255 George Street, Sydney NSW 2000.
If you are unhappy with the outcome, you may then subsequently refer your privacy complaint to the Privacy Commissioner on 1300 363 992
or
GPO Box 5218
Sydney NSW 2001
Office of the Privacy Commissioner