PRIVACY POLICY

What is this policy about?

Advance Trading Australia Pty Limited (“Advance”) recognises the importance of ensuring that its clients have confidence in the way Advance handles personal information. Advance is committed to implementing and promoting this Privacy Policy.

This document sets out the policy of Advance for handling personal information and has been prepared to provide clients with information about what Advance can do with personal information.

Advance is bound by, and committed to the terms of the Privacy Act 1988 and the National Privacy Principles forming part of that Act. A summary of the National Privacy Principles is available by contacting our office.

What is personal information?

Personal information is any information about you, that identifies you or by which your identity can reasonably be ascertained.

What kinds of personal information do we collect and hold about you?

Advance only collects personal information that is necessary for one or more of its functions or activities.

Advance is the holder of an Australian Financial Services Licence and is subject to certain legislative and regulatory requirements which necessitate it obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“Personal Information”). 

In order to provide you with an advisory and dealing service in Financial Products (specifically derivatives and/or foreign exchange contracts) and to have a reasonable basis for recommendations we make, Advance may require certain Personal Information about you, including:

1. name and/or names used;

2. permanent address and postal address if different;

3. employment details;

4. date of birth;

5. Tax File Number (or exemption). While it is optional for clients to provide a Tax File Number or exemption, failure to do so will oblige Advance to deduct income tax from distributions to the investor (where applicable);

6. details of an individual’s current financial circumstances, including your income, assets and liabilities (where you wish Advance to take into consideration your objectives, financial situation and needs in providing you financial product advice). This information may not required where your investment in a financial product is in excess of $500,000;

7. details of your financial needs and objectives (where you wish Advance to take into consideration your objectives, financial situation and needs in providing you financial product advice);

8. details of your investment history and preferences; and

9. your aversion or tolerance to risk.

Advance will not collect any Personal Information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.  Generally, collection of your Personal Information will be effected in either face-to-face interviews, over the telephone, via email or by way of a Client Agreement Form and other client establishment documentation.  From time to time additional and/or updated Personal Information may be collected through one or more of those methods.

We will only collect, maintain and use Personal Information about you if it is necessary for us to adequately provide to you the services you have requested including:

1. making financial products recommendations; and

2.arranging for the execution of financial products transactions on your behalf

3. and all things necessary or incidental to the above.

How is Personal Information collected?

Most information we hold about clients is collected from the Client Agreement Form and other client establishment documentation. Information may also be collected over the phone or via email during the course of the client's relationship with Advance. Sometimes, information about an individual is collected from other people or organisations. For example, information about a director of a corporate client may be obtained from a public record relating to the company. Regardless of how it is collected, all Personal Information is handled in accordance with this Privacy Policy.

Advance uses the Personal Information it holds in order to provide its clients with the services they request.  Advance will not use or disclose Personal Information collected by us for any purpose other than:

1. the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or

2. where you have consented to such disclosure; or

3. where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

Advance is required under the Corporations Act to make certain information available for inspection by the Australian Securities and Investments Commission on request to ensure ongoing compliance with licensing and regulatory requirements. This may involve the disclosure of your Personal Information.

Advance may disclose your Personal Information to market operators, clearers, brokers and product issuers for the purpose of giving effect to your instructions and the recommendations made by us.  Advance may disclose your Personal Information to external contractors for the following purposes:

1. execution, clearing and settlement of financial products transactions;

2. accounting for financial products transactions;

3. causing statutory audits to be conducted as required by law;

4. maintenance and service of our information technology systems; or

5. in the course of reviews by external consultants.

You can be assured that your information will be maintained by any contractor to whom it is disclosed in accordance with this policy.  If you have any concerns in this regard, you should contact us by any of the methods detailed below (refer paragraph below entitled “Contact Details”).

If Advance is unable to collect Personal Information from or about an individual, it may not be able to do business with that individual or the organisation with which the individual is connected.

Advance may use the Personal Information collected from you for the purpose of providing you with direct marketing material such as research that may be of interest to you, to inform you about new products and services or special offers from time to time.  However you may, by contacting us by any of the methods detailed below, request not to receive such information and we will give effect to that request.  Please allow 2 weeks for your request to be actioned.

Document storage and security

We will at all times seek to ensure that the Personal Information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure.  At all times your Personal Information is treated as confidential and any sensitive information is treated as highly confidential and stored securely.

Your Personal Information is generally held in your client file.  Information may also be held in a computer database. Advance will take reasonable steps to ensure that all Personal Information we collect or use is:

1. accurate, complete and up-to-date;

2. stored in a secure environment; and

3. accessed only by authorised personnel for permitted purposes.

If your details change, we ask that you advise us of the change as soon as possible in order that we may maintain accurate records.

All electronic information is protected by maintaining a certified security capable Operating System i.e. access is only granted via suitable passwords on each computer. 

In the event you cease to be a client of Advance, any Personal Information which we hold about you will be maintained in a secure off site storage facility for a period of 7 years in order to comply with legislative and regulatory requirements, following which time the information will be destroyed. 

Access to your Personal Information

You may at any time, by contacting us (refer paragraph below entitled “Contact Details”), request access to your Personal Information.

Advance will (subject to the following exceptions) provide you with access to that information either by:

1. providing you with copies of the information requested;

2. allowing you to inspect the information requested; or

3. providing you with an accurate summary of the information held. 

We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.

Advance will not provide you with access to your Personal Information if:

1. providing access would pose a serious threat to the life or health of a person;

2. providing access would have an unreasonable impact on the privacy of others;

3. the request for access is frivolous or vexatious;

4. the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;

5. providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;

6. providing access would be unlawful;

7. denying access is required or authorised by or under law; and

8. providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

In the event we refuse you access to your Personal Information, we will provide reasons.

Correction of Personal Information

Advance will endeavour to ensure that, at all times, the Personal Information about you (that we hold) is up to date and accurate.  In the event that you become aware, or believe, that any Personal Information which we hold about you is inaccurate, incomplete or outdated, you may contact us (refer paragraph below entitled “Contact Details”) and provide us evidence of the inaccuracy or incompleteness.  Advance will, if we agree that the information requires correcting, take all reasonable steps to correct the information.

If we do not agree that your Personal Information requires correcting, Advance must, if you request, take reasonable steps to ensure that whenever your Personal Information is accessed or handled in the future, it is apparent that you are not satisfied as to the accuracy or completeness of that information.

We will endeavour to respond to any request for access within 2 weeks, depending on the complexity of the information and/or the request.  If your request is urgent please indicate this clearly.

Does Advance disclose the Personal Information it holds?

Sometimes Advance obtains services from other organisations and where necessary (and where the law permits), Personal Information will be provided to those organisations. The kinds of services obtained externally by us include information technology support, financial advice, compliance advice and legal advice.

External service providers are only authorised to use Personal Information for the purpose for which we supplied it. Those organisations are not authorised to use that Personal Information for their own purposes.

Sometimes, the law requires us to disclose Personal Information. For example, information may be disclosed to a court in response to a subpoena or to a Government agency such as the Australian Taxation Office on receipt of a direction issued under taxation laws.

Where a client nominates someone to act on their behalf, Advance may provide information to that person, for example, the client's accountant or financial adviser.

Resolving concerns

If you believe that the privacy of your Personal Information has been compromised, you are entitled to complain. Complaints can be made by contacting the person you were dealing with or by contacting the Privacy Officer. We will respond to complaints as soon as possible.  It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.

Contact Details

Mr Andrew Woodhouse

Privacy Officer

Advance Trading Australia Pty Limited

1 Wentworth Street

WAGGA WAGGA NSW 2650

Tel: 02 6921 2851

Fax: 02 6921 6253

Email: This email address is being protected from spam bots, you need Javascript enabled to view it

Additional information

 If you would like more information about our approach to privacy, you are encouraged to contact the Privacy Officer.