This following document sets forth the Privacy Policy for the Norfolk Capital Management Pty Ltd (ABN 73650327218) (“Norfolk Capital Management”) website, http://www.norfolkcapital.com.au. ”We”, “us” and “our” means Norfolk Capital Management. This document sets out a number of principles concerning the privacy of individuals.
Collection of Your Personal Information
There are many aspects of the site which can be viewed without providing personal information, however, for access to future Norfolk Capital Management support features you may be required to submit personally identifiable information.
The nature of our business relationship with you, the product or service that we provide or receive will determine what information we collect. If you are an investor or client, we may collect your name, residential and/or postal address, date of birth, email address, employment information, financial details (including banking details, investment details), government issued identifying numbers (such as tax file number or national identity number), citizenship, passport details, or other information that we consider necessary to provide our product or service. In the context of our recruitment process, we may collect your name, date of birth, residential address, citizenship, employment references, background checks, education, employment history, contact details or other information that we consider necessary to process your employment application. We may collect your personal information in a variety of different ways including directly from you (including in person, by telephone, letter, facsimile, email, via an application form which may be either paper based or online), indirectly from your nominated agent (such as a financial adviser, agent or attorney) or indirectly from third parties (such as a government database for the purpose of complying with ‘Know Your Client’ requirements). The collection of sensitive personal information is restricted by the provisions of the Act. This means we will not collect any information such as personal information relating to your religious views, ethnicity, political opinion, criminal record, health, sexual preference, unless it is required for a purpose specifically disclosed to you at the time of collection. Norfolk Capital Management has the capability to collect information about the use of our website. This information could include the number of users, when they visit, how they navigate through the pages, which pages are visited and the amount of time spent on looking through the website. Similar statistical information is also collected when we distribute other electronic material such as marketing information on our products and services. By using this website, you agree to our collection and use of this information. You are not required to give us the information that we request. However, if you do not give us the information that we ask for or the information you give us is incomplete or inaccurate, this may prevent or delay the processing of your application or any claim, prevent us from contacting you or impact on the taxation treatment of your account.
We only use or disclose your tax file number or other government agency identifier for the purposes required by law. Norfolk Capital Management is not permitted and does not adopt government identifiers as identifier of any individual.
Sharing of Your Personal Information
We may disclose personal information to external organisations that help us to provide services. For example, we may provide names and addresses to a mailing house to mail account statements to you. We may also seek expert help from time to time to improve our IT systems. These organisations are bound by confidentiality agreements as well as the APPs. Those companies will be permitted to obtain only the personal information they need to deliver the service. Norfolk Capital Management takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
Use of Your Personal Information
For each visitor to reach the site, we expressively collect the following non-personally identifiable information, including but not limited to browser type, version and language, operating system, pages viewed while browsing the site, page access times and referring website address. This collected information is used solely internally for the purpose of gauging visitor traffic, trends, delivering personalised content to you while you are at this site, and/or for internal general business purposes (such as providing you with our products or services, answering enquiries, and establishing/managing your accounts or investments with us).
From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will use for these new purposes only, data collected from the time of the policy change forward will adhere to our updated practices.
Changes to this Policy
Norfolk Capital Management reserves the right to make amendments to this Privacy Policy at any time. If you have objections to the Privacy Policy, you should not access or use the Site.
Accessing Your Personal Information
You have a right to access your personal information, subject to exceptions allowed by law. If you would like to do so, please let us know. You may be required to put your request in writing for security reasons. Norfolk Capital Management reserves the right to charge a fee for searching for, and providing access to, your information on a per request basis.
If for some reason we are unable to comply with your request to access your personal information, we will inform you and explain the reasons why. You may request us to provide the source of the personal information we hold, which will be notified unless it is impractical or unreasonable to do so.
Contacting Us
Norfolk Capital Management welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact us by any of the following means during business hours Monday to Friday.
Attn: Administration Team
Norfolk Capital Management,
12 High Street
Fremantle WA 6943
Australia
E-mail: [email protected]