Privacy policy
01. Your rights in relation to privacy
1010 Capital Pty Ltd ACN 646 501 297 (1010 Capital) understands the importance of protecting the privacy of an individual’s personal information. This policy sets out how 1010 Capital aims to protect the privacy of your personal information, your rights in relation to your personal information managed by 1010 Capital and the way 1010 Capital collects, holds, uses and discloses your personal information.
In handling your personal information, 1010 Capital will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act.
This policy may be updated from time to time.
02. What kinds of personal information does 1010 Capital collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its products and services, 1010 Capital may collect your personal information.
Generally, the kinds of personal information 1010 Capital collects are:
contact and identification information such as your name, address, telephone number, email address and date of birth;
where you are acting on behalf of another entity (whether as an employee, director, beneficial owner, beneficiary, or other representative), details of that entity and your relationship with it;
financial information, and credit-related personal information, including:
identification information, including copies of relevant identification documents;
Tax File Numbers and other financial identification numbers such as account numbers, Holder Identification Numbers, Shareholder Reference Numbers or the like;
consumer credit liability information which includes information about your credit providers and credit accounts, including the dates on which the accounts are opened and closed, their limits, and their terms and conditions (or any changes to their terms and conditions);
information about the types of credit, and the amounts of credit, you have sought from a credit provider;
personal insolvency information and other publicly available information relating to your credit worthiness;
any other information lawfully obtainable within the Australian credit reporting system;
other personal information and sensitive information including health information:
where you consent to the collection of such information and if relevant to the provision of our products or services; or
where you are applying for an employment position with 1010 Capital and it is relevant to the recruitment process through which you must progress following your application to 1010 Capital (for example, background checks, including financial background checks, and criminal record information, information about your education and work history, qualifications and skills, and the opinions of others about your work performance); or
where you are applying for an employment position with 1010 Capital, and it is relevant to 1010 Capital’s assessment of whether you are able to perform the inherent requirements of the particular role; and
In some circumstances 1010 Capital may also hold other personal information provided by you.
03. How does 1010 Capital collect personal information?
Generally, 1010 Capital collects your personal information directly from you. For example, 1010 Capital may collect your personal information through the completion of a manual or online form, an interaction or exchange in person or by way of telephone, video conference, facsimile, email, post or through the use of 1010 Capital’s website.
There may be occasions when 1010 Capital collects your personal information from other sources such as from:
an agent authorised to act on your behalf, including your accountants or lawyers;
an information services provider;
a publicly maintained record or other publicly available sources of information including social media and similar websites;
if for recruitment purposes, an external recruitment or background screening services provider; and
other sources such as investment managers, financial institutions or brokers authorised to act on your behalf.
Generally, 1010 Capital will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you or with your authorisation.
04. Why does 1010 Capital need your personal information?
1010 Capital collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:
identification purposes;
providing and facilitating the provision of its products and services to you or an
entity you represent;
accounting, billing and other internal administrative purposes;
assessing your application for employment with 1010 Capital or otherwise for the purpose of engaging you as a contractor or consultant;
ensuring that 1010 Capital is compliant with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
directly related internal management purposes; and
any other legal requirements.
1010 Capital may also use your personal information for purposes related to the above purposes and for which you would reasonably expect 1010 Capital to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law.
Where personal information is used or disclosed, 1010 Capital takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to 1010 Capital. However, without certain information from you, 1010 Capital may not be able to provide its products and/or services to you or an entity for which you represent.
05. To whom does 1010 Capital disclose your personal information?
1010 Capital discloses your personal information for the purpose for which 1010 Capital collects it. That is, generally, 1010 Capital will only disclose your personal information for a purpose set out at paragraph 4 above. This may include disclosing your personal information to:
third parties engaged to perform administrative or other business management functions, including payroll;
people or entities considering acquiring an interest in 1010 Capital’s enterprise or assets;
1010 Capital’s professional advisors, business partners, contractors, suppliers, consultants and related bodies corporate;
insurers and insurance providers;
investment managers and investment administrators with whom you are, or potentially will be, investing assets;
financial institutions, including in relation to an application for credit made by you, or made on behalf of an entity you represent;
debt collection and recovery service providers; and
regulatory bodies, including but limited to, AUSTRAC in relation to suspicious matters which 1010 Capital are obliged to report under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
1010 Capital’s disclosures of your personal information to third parties are on a confidential basis or otherwise in accordance with law. 1010 Capital may also disclose your personal information with your consent or if disclosure is required or authorised by law.
06. Overseas disclosure
1010 Capital may disclose personal information to overseas recipients in order to provide its services and/or products and for administrative or other business management purposes. Recipients of such disclosures (including related bodies corporate of 1010 Capital) are located in New Zealand, USA and UK.
Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, 1010 Capital takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.
If you have any queries or objections to such disclosures, please contact 1010 Capital’s Privacy Compliance Officer on the details set out in section 11 below.
07. Direct marketing
1010 Capital may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting 1010 Capital via the contact details set out in paragraph 11 or through any opt-out mechanism contained in a marketing communication to you.
08. Security of your personal information
1010 Capital takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. 1010 Capital holds personal information in electronic forms in secure databases on secure premises, accessible only by authorised staff.
Where appropriate, a third party service provider may hold your personal information, and in those circumstances, a strict confidentiality agreement will be entered into.
1010 Capital, or any third party service provider, will destroy or de-identify personal information in circumstances where it is no longer required, unless 1010 Capital is otherwise required or authorised by law to retain the information.
09. Can you access and correct the personal information that 1010 Capital holds about you?
1010 Capital takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. You may access and seek correction of your personal information that is collected and held by 1010 Capital.
If at any time you would like to access or correct the personal information that 1010 Capital holds about you, or you would like more information on 1010 Capital's approach to privacy, please contact 1010 Capital Operations on the details set out in paragraph 11 below. 1010 Capital will grant access to the extent required and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
1010 Capital requests that you be reasonably specific about the information you require; and
1010 Capital may charge you a reasonable administration fee, which reflects the cost to 1010 Capital, for providing access in accordance with your request.
1010 Capital will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If 1010 Capital refuses your request to access or correct your personal information, 1010 Capital will provide you with written reasons for the refusal and details of complaint mechanisms available. 1010 Capital will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of 1010 Capital.
10. Cookies
When accessing 1010 Capital’s website, 1010 Capital uses ‘cookies’ to store a log file which is retained for technical and statistical purposes only. The information collected is not personal information and, to the extent any personal information is collected, it is de- identified prior to being analysed for the technical and statistical purposes. Cookies are a feature of your Internet browser that you can disable at any time. However, if a browser does not accept cookies or if you reject a cookie, some portions of 1010 Capital’s online services may not function properly.
11. How to contact us
For access to your personal information, or for further information on 1010 Capital’s approach to privacy please contact our Operations team via email to operations@1010capital.com.au.
12. Enquiries
Please direct any enquiries relating to your private matters, or any privacy complaints to our Privacy Compliance Officer Dale Sanftl via email to dale@1010capital.com.au.
At all times, privacy complaints:
will be treated seriously;
will be dealt with promptly;
will be dealt with in a confidential manner; and
will not affect your existing obligations or affect the commercial arrangements between you and 1010 Capital.
Our Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following the completion of the investigation. In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.