1. Our commitment to privacy

Candour Capital Pty Ltd (“Candour”, “we”, “us” or “our”) is an Authorised Representative of Candour Private Wealth Pty Ltd (AFSL 544396). We are committed to protecting the privacy of your personal information and handling it in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

This policy explains how we, and our related entities, collect, hold, use and disclose personal information; how you may access and correct the personal information we hold about you; and how you may contact us with a privacy question or complaint.

It applies to personal information collected through our website, by email, telephone or in face-to-face meetings, in connection with our financial services activities.

Our website may contain links to third-party websites, portals or applications. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies before providing your personal information.

2. Personal information

“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is accurate and whether or not it is recorded in a material form.

“Sensitive information” is a subset of personal information and includes information such as health information and information about an individual’s racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record and biometric information.

We generally do not collect sensitive information unless it is reasonably necessary for our functions or activities, required or authorised by law, or you have consented to its collection.

3. What personal information we collect and hold

The kinds of personal information we collect depend on the nature of your relationship with us and the services you request from us. The personal information we may collect and hold includes:

  • your name, and company or trust details;
  • professional or employment information, and financial information relevant to assessing whether you are or remain a wholesale client;
  • identity, contact details and identification documents;
  • tax residency information;
  • transactional and bank account information;
  • account and login information; and
  • any other information you provide to us, or that we are required or authorized to collect.

We may also create records based on our interactions with you, including compliance, due diligence, onboarding and service records.

If we collect Tax File Number information, we will do so only where authorised or required by law and will handle that information in accordance with applicable law.

If you provide us with personal information about another person, you must be authorised to do so and must make that person aware of this policy.

4. How we collect personal information

Where practicable, we collect personal information in a variety of ways, including:

  • directly from you: when you complete a website form, contact us by email or phone, subscribe to updates, attend our events, or in face-to-face meetings;
  • from third parties: including our related entities, authorised representatives, financial advisers, brokers, introducers, referral partners, product issuers, registries, custodians, platform providers, identity verification providers, and publicly available sources (including social media, company registers, and government or regulatory sources); and
  • through our website or digital services: we may automatically collect information such as your IP address, device and browser type, usage patterns through cookies and similar technologies. Further details are set out in section 12 below.

5. Why we collect, hold, use and disclose personal information

We collect and use your personal information for purposes including:

  • responding to enquiries and providing information about our products, services or events;
  • assessing whether we can provide services to you, and assessing and confirming your wholesale client status where relevant;
  • establishing, administering and servicing client relationships;
  • meeting our legal, regulatory and compliance obligations;
  • risk management, and maintaining and securing our website and systems; and
  • supporting our business operations and continual improvement.

If you do not provide personal information we reasonably require, we may be unable to respond to your enquiry or provide some or all of our services.

6. Disclosure of personal information

We may disclose your personal information to third parties, including:

  • our authorised representatives, service providers and business partners;
  • issuers, brokers, counterparties, custodians, administrators, registries, platform providers and other participants involved in a product, transaction or service you request;
  • financial services professionals, such as accountants, lawyers or other representatives, where you have authorised us to do so or where it is otherwise appropriate;
  • regulators, government bodies, courts, tribunals, law enforcement agencies and other parties where disclosure is required or authorised by law; and
  • other persons or entities with your consent or at your direction.

7. Overseas disclosure of personal information

In certain circumstances, your personal information may be disclosed to, or accessed by, service providers or counterparties located outside Australia. This may occur where:

  • we engage technology, cloud, communications, analytics or other professional service providers that operate internationally; or
  • a product, investment or transaction you request involves an overseas party.

Where we disclose personal information to overseas recipients, we take reasonable steps to ensure that such recipients handle your personal information in a manner consistent with the Australian Privacy Principles, unless:

  • the recipient is subject to laws or binding schemes that provide substantially similar protections to the Australian Privacy Principles;
  • the disclosure is otherwise permitted under the Privacy Act 1988 (Cth);
  • the disclosure is required or authorised by law, including by government authorities or regulators in a relevant jurisdiction; or
  • You have consented to the disclosure.

8. Dealing with us anonymously and consequences of not providing information

Where lawful and practicable, you may interact with us anonymously or by using a pseudonym, for example when making a general enquiry. However, in many cases, we require certain personal information to respond to your enquiry or to provide you with the requested services or information.
We may not be able to provide you with the relevant services or information you require if you choose not to provide the personal information we reasonably require.

9. How we store and protect personal information

We store personal information in electronic formats and, in some cases, physical records, including:

  • Secure servers and databases (including cloud-based storage);
  • Systems operated by our service providers;
  • Physical files and records at our offices and secure storage facilities.

We take reasonable steps to protect the personal information we hold from unauthorised access, use, disclosure, modification, loss, misuse, interference, and data breaches, as well as other security incidents.

Our safeguard measures include access controls, authentication measures, encryption, network and endpoint security controls, secure document handling procedures, staff training, and incident response and data breach notification processes.

We require our service providers and business partners to implement appropriate security measures and to handle personal information in accordance with applicable privacy laws.

We retain personal information for as long as reasonably necessary for the purposes for which it was collected, and as required to meet our legal, regulatory, tax, accounting, dispute resolution and record-keeping obligations. When personal information is no longer required, we take reasonable steps to destroy or de-identify it.

10. Access to and correction of personal information

You may request access to the personal information we hold about you and request correction of personal information that is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, please contact our Privacy Officer using the details in section 13.

We will respond to your request for access to or correction of personal information within a reasonable period, and generally within 30 days.
We will generally provide you with access to your personal information. Subject to certain exceptions permitted by law, we may charge a reasonable fee to cover the cost of providing access to the information.

11. Direct marketing

Where permitted by law, we may use your personal information to send you information about our products, services, educational content, market insights or events that may be of interest to you.

We may contact you by email, mail, telephone or other permitted means. You can opt out of receiving marketing communications at any time by using the unsubscribe facility in the message or by contacting us using the details in section 13.

Please note that even if you opt out of receiving marketing communications, we may still send you non-promotional communications that are necessary and related to the services or products we provide to you, or to respond to your enquiry.

12. Visiting our website

When you visit our website, we may collect information such as your IP address, the date and time of your visit, pages viewed, referral source, browser type, device information and operating system through cookies and similar technologies.
The information collected from your visit to our website is generally not personal information, as it does not usually identify you on its own, unless you are logged into our website, or it is otherwise combined with other information that can identify you.

We use cookies and similar technologies to support website functionality, remember user preferences, analyse website traffic and user behaviour, and improve website performance and user experience.

You can control cookies through your browser settings and any consent tools made available on our website. Disabling or refusing cookies may affect the functionality of our website.

13. Privacy complaints and contact details

If you have a question about this policy, wish to access or correct your personal information, or wish to make a privacy complaint, please contact us using the details below:

Email:    info@candourcapital.com

Mail:      The Privacy Officer
              Candour Capital Pty Ltd

              Level 7, 9 Help Street, Chatswood NSW 2067

When making a complaint, please provide your contact details, details of the privacy concern or breach, and any relevant supporting documentation to assist us in understanding and investigating the issue.

We will acknowledge your complaint, generally within 5 business days, and provide a written response within 30 days.

14. Changes to this policy

We may update this policy from time to time to reflect changes in our practices, technology, legal requirements or the services we provide. We encourage you to review this policy periodically on our website to stay informed about our current privacy practices.