STATEMENT OF PRIVACY POLICY – APRIL 2018

1.0 OUR COMMITMENT

Orion Capital Partners Pty Limited abides by the National Privacy Principles established under the Privacy Amendment (Privacy Sector) Act. 2001. A summary of the National Privacy Principles is available by contacting our office.

2.0 COLLECTION

As a financial advisory organisation we are subject to certain legislative and regulatory requirements, which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“personal information”). In addition, our ability to provide you with a comprehensive financial advisory service is dependent on us obtaining certain personal information about you, including:

(a) employment details and employment history
(b) details of your financial needs and objectives
(c) details of your current financial circumstances, including your assets and liabilities (both actual and potential), in come, expenditure, insurance cover and superannuation
(d) details of your investment preferences and aversion or tolerance to risk
(e) information about your medical history, employment circumstances, family commitments and social security eligibility

We are required pursuant to the Corporations Act to collect sufficient information to ensure appropriate advice can be given in respect of recommendations made to our clients. Failure to provide the personal information referred to above may expose you to higher risks in respect of the recommendations made to you and may affect the adequacy or appropriateness of advice we give to you. Generally, collection of your personal information will be effected in either face-to-face interview, over the telephone or by way of an online client engagement form. 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:
• the preparation and development of your financial strategies
• the provision of financial advice to you
• making securities and investment recommendations
• implementing your financial strategies
• reviewing securities and investment recommendations
• risk management

3.0 USE AND DISCLOSURE

We will not use or disclose Personal Information collected by us for any purpose other than:
• the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
• where you have consented to such disclosure; or
• where the National Privacy Principles authorise use or disclosure where required or authorised under law, in specific circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.


We are obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission. In the event that we propose to sell our business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them.

In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client, you will be advised of any such transfer.


4.0 SECURITY

Your personal information is generally held in your client file. Information may also be held in a computer database.

5.0 ACCESS AND CORRECTION

You may at any time, by contacting us by any of the methods detailed below, request access to your personal information and we will (subject to the following exceptions) provide you with access to that information either by providing you with copies of the specific information requested, allowing you to inspect the  nformation requested or 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.

We will not provide you with access to your personal information if:
(a) providing access would pose a serious threat to the life or health of a person
(b) providing access would have an unreasonable impact on the privacy of others
(c) the request for access is frivolous or vexatious
(d) the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings
(e) providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations
(f) providing access would be unlawful
(g) denying access is required or authorised by or under law
(h) 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

We will endeavour to ensure that, at all times, the personal information about you, which 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 by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness or out datedness and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.


6.0 INFORMATION COLLECTED ONLINE

Infinitum Capital’s web site may contain links to other web sites whose operator may or may not adhere to a privacy policy or be governed by the National Privacy Principles.


7.0 IDENTIFIERS

We will not adopt as our own any identifiers that you may wish to provide to us such as TFN’s, Medicare numbers etc.

8.0 CONTACT US

If you seek any further information about this statement or our privacy policy generally, please contact Sam Novak, on the details provided below:
• Registered Business Office :
Level 21, 68 Pitt Street SYDNEY NSW 2000
• Telephone: +612 8224 8000
• Email: samn@orioncp.com.au