542 Partners Pty Ltd Privacy Notice

1.1 542 Partners is committed to safeguarding the personal data we collect and hold in connection with the financial services business that we are authorised to provide to Australian clients. This Privacy Notice describes the personal data we may collect and hold, and how we use, manage, process and disclose it. In this Privacy Notice, client, you or your means a prospective, existing or former client entity to whom this notice applies, and we, our or 542 Partners means 542 Partners Pty Ltd, together with any other member or affiliate of 542 Partners processing personal data in the course of providing services to you.

1.1  This Privacy Notice, as required by the Australian Privacy Act 1988 (Cth), sets forth how 542 Partners manages personal data.

1.2  To the extent required by local law, you must ensure that your Relevant Individuals are made aware of how we will process their personal data. Whenever you or a corporate representative within your organisation provide us with personal data about a Relevant Individual, you confirm that you have obtained any necessary consents or are otherwise entitled to provide this information to us and for it to be processed in accordance with this Privacy Notice.

2. Personal data we collect

2.1  We collect personal data in respect of Relevant Individuals, including financial, personal and other information to uniquely identify Relevant Individuals, when on-boarding new clients and to provide services to clients. The personal data we collect may include details of a Relevant Individual’s name, residential address, date of birth, telephone number, email address or other contact details, and/or information about their place of work and position title, information generated in the ordinary course of a banking/financial relationship with us, or any other information from which the Relevant Individual can be identified, whether in electronic form or otherwise.

2.2  Although we collect most of this information directly from corporate representatives within your organisation acting on your behalf, we may also collect such information (including information about political, professional and trade association affiliations) from publicly available resources, and receive or derive information in the course of our relationship with you. The information collected by 542 Partners includes information required under Australian law, for example, the Anti- Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

2.3 To the extent that personal data is provided to 542 Partners, a request for anonymisation or use of pseudonym may be made. However, regulatory and/or global policy requirements may restrict our ability to effectively deal with such requests and prevent us from completing the necessary client on-boarding process.

3. Purposes of use

3.1 The use of Relevant Individuals’ personal data is incidental to our dealings with the wholesale and corporate client entities they represent and includes dealing with relevant authorised persons of such client entities in respect of the business activities 542 Partners performs including:

• Conducting regulatory checks or other work that 542 Partners is required to complete pursuant to any legal or regulatory requirements or
542 Partners’ policy;

• Measuring or reporting business performance and/or forecasting future budget or performance;

• Obtaining necessary business or credit approvals for transactions with clients;

• Performing administrative tasks related to transactions with clients, including responding to client inquiries;

• Where all or part of the personal data processing is outsourced by other business operators, etc., performing such outsourced services appropriately or, where all or part of the personal data processing is outsourced to other business operators, etc., ensuring that there are commensurate controls implemented by outsourced services providers to protect personal data;

• Exercising rights and performing obligations under any contracts with clients or any applicable laws and regulations;

• Managing contact information to ensure accurate and appropriate contact with clients, including sending greeting cards or providing information about seminars, receptions, events etc. (but see paragraph 4 below);

• Obtaining information necessary to respond to inquiries from clients;

• Ensuring appropriate and smooth execution of transactions with clients;

• Administering clients’ accounts (including identifying and verifying the identity of Relevant Individuals), developing our services to our clients, for assessment, testing (including system tests) and analysis, capturing and managing risks and internal controls; and

• For any purpose reasonably connected with the above purposes, including to comply with our legal and regulatory obligations, including responding to regulatory requests for information.

3.2   3.3  If we need to obtain or use any personal data beyond the purposes of use stated in this notice or any additional purposes outlined when personal data is collected, we will notify you (directly or via your corporate representative(s)) of such further purpose(s) in advance.

4. Marketing

4.1  We may use a Relevant Individual’s personal data to send them marketing as described in this notice, including using this information to invite Relevant Individuals to seminars, events etc. that we reasonably consider to be relevant to the organisation you represent.

4.2  Relevant Individuals can contact us (see paragraph 9) at any time if they would like to opt out of receiving such communications and we shall process their request within a reasonable timeframe.

5. Overseas Disclosure of information

5.1  542 Partners conducts its business across the globe and may need to share personal data with its affiliates and vendors to the extent necessary to conduct its business appropriately.

5.2  Personal data could be accessed by entities (including members of our group and third parties, such as service providers) based in the following countries:

• United Kingdom

• United States

• Singapore

• India

5.3  We will ensure that suitable safeguards are in place before personal data is transferred to other countries or parties or, where this is not possible (for example, because we are required by law or court order to disclose the information), we will ensure that the sharing is lawful.

5.4  We will ensure that when we outsource any processes, the vendor has appropriate security measures in place, including requiring them to comply with our privacy principles.

6. Disclosure and retention of information; Security measures

6.1  We will keep personal data for as long as we are allowed to for legitimate business purposes, to help prevent fraud and other financial crime, and for other legal and regulatory reasons.

6.2  We will keep personal data confidential but we may share it if we have a duty to disclose it, if it is required for the management of your accounts or a law or regulation allows us to do so, or for legitimate business purposes with the following (who are also bound to keep it secure and confidential):

• other companies within the 542 Partners Group;

• our affiliates, vendors, professional advisors and/or companies or organisations acting as our agents (including sub-contractors);

6.3  If we have reason to think that you or any Relevant Individual are required to report your income or are subject to tax in another country, we may have to share information about you, your accounts, such Relevant Individual or any accounts of such Relevant Individuals held with 542 Partners with the Australian or relevant tax authorities, either directly or via the local tax authority who may share that information with the appropriate tax authorities abroad.

6.4  We may also share personal and other information if we have a duty to do so or if the law, public interest, or our terms and conditions allow us to do so, including sharing information with regulators and authorities, in Australia and overseas, in connection with their duties (such as crime prevention).

6.5 We carefully safeguard the personal data we hold. We will ensure that appropriate physical and technological security measures are implemented to protect personal data. This includes compliance with regulatory requirements, our local and global information technology and security policies, and measures and policies to safeguard the personal data we hold and process. We also require that third parties acting on our behalf, including our affiliates and vendors, implement appropriate controls and measures.

7. Ongoing improvement

7.1 To ensure proper handling of personal data on an ongoing basis, we may review this Privacy Notice from time to time and notify you of any changes accordingly, whether online via an electronic medium or otherwise. You can find the most up-to-date Privacy Notice by emailing info@542partners.com.au

8. Point of contact for inquiries

8.1  Relevant Individuals have a right to request access to the personal data we hold about them, to seek correction of their information or to lodge a complaint in case of any concerns about the manner in which 542 Partners has managed their personal data. They can ask for a copy of their information we hold about you by writing to us. We may charge a fee for this service as permitted by applicable law or regulation.

8.2  Below are the contact details for any complaints or any access, correction or other requests in respect of the personal data we hold about Relevant Individuals.

• Compliance Officer
Stuart Brandman (02) 9527 1782. This notice is effective 01 February 2016