Privacy Policy

Your Privacy

Central to Pareto Capital Pty Ltd's ('Pareto') success is our commitment to our existing and potential customers. We honour our obligation to respect and protect the privacy of the personal information of individuals and companies with whom we deal and we are committed to upholding the Privacy Act 1988 (Commonwealth) and the National Privacy Principles as it applies to them.

The Information We Collect

The types of personal information that Pareto collects will depend on the nature of your dealings with us.

Whenever it is reasonable and practicable to do so, we only collect information about you, directly from you.

Whenever it is reasonable and practicable to do so, we only collect information about you, directly from you.

• Set up, manage and administer financial products and financial services;
• Assess your financial product and service needs;
• Determine your requirements and provide the appropriate financial product or service to meet your needs;
• Provide financial product advice and financial services;
• Determine your requirements and provide the appropriate financial product or service to meet your needs;
• Perform securities and derivatives transactions; and
• Identify clients.

We may also use personal information to send you research reports and information on related services we provide, which may be of benefit to you.

If we do not collect this information from you we will not be able to provide you with our products and services.

We generally hold personal information relating to:

• the products and services we provide or have provided to you.
• your name, date of birth, bank account details, shareholding details,
• investment experience and objectives, risk profile,
• your financial interests and sometimes your financial position.
• your contact details.

How We Collect That Information

Pareto may collect personal information in the following ways:

• When you complete an application form for a financial product or service, or a related form required for administering or managing the product or service we are providing.
• By telephone, email or facsimile.
• When you meet with one of our Advisers.
• In correspondence.
• Completed questionnaires.
• When you provide a change of details eg. address or banking details.
• Our web sites use "Session" cookies which are short-lived, used only during a browsing session and expire when the individual quits their browser. Cookies are pieces of information used for tracking site usage and user navigation.

Pareto will only collect personal information that is necessary for us to properly provide our services to you. In most cases we will collect information directly from you. Sometimes personal information may be collected about you from other sources. Examples of where we may receive personal information from another source and why this would happen are:

• From share registries;
• From other organisations providing outsourced functions on our behalf or on behalf of whom we provide outsourced functions; and
• From credit reporting agencies if necessary to provide products or services.

Where it is practical to do so, we will seek a signed authorisation from you to allow us to obtain information from third party organisations.

How that Information is Used

Pareto will use the personal information we collect to provide you with the required product or service and to enhance the financial service relationship we have with you. To enable us to do this we may share your personal information with a company with whom Pareto has a commercial arrangement which provides services to Pareto customers.

Customer information may also be used for providing a service requested by you, planning, product development and research purposes.

We only use and disclose personal information about you for the purpose for which it was disclosed to us or related purposes which would reasonably be expected, without your permission.

Depending on the purpose for which we have collected personal information, we may store some of the information in our company records. Some or all of this information may be available to Directors and authorised staff of Pareto for use in accordance with this policy.

Internally, we have controls and procedures to ensure that personal information provided to us remains confidential. All of our staff are trained in privacy and are bound by strict duties of confidentiality to Pareto and its clients.

We will not collect or use personal information in ways other than as stated in this policy unless we have obtained an individual's consent. In some cases we may specifically request a consent form to be signed. In other cases, consent may be implied (for instance, where an individual gives us information after being fully advised of how it will be used).

For example, we may from time to time use your personal information to inform you of other products and services which we expect may be of interest to you. However, we do respect your right to ask us not to do this.

We may need to disclose your personal information to a third party for a number of reasons, they may include:

• Mail service providers for the mailing of information.
• Organisations with whom Pareto has a contractual arrangement to provide investment advising and related services. Customer information will be collected by Pareto on behalf of the company and disclosed to the company as authorised by the customer.
• Credit reporting agencies when seeking credit reports in connection with the establishment of certain financial services and the collection of any overdue payments.
• Share registries and other organisations for trading and investment purposes.

We may from time to time be required to provide information to a regulatory authority eg. Australian Securities & Investments Commission or some other Commonwealth government agency eg. the Australian Taxation Office or to a court in response to a subpoena.

Disclosure of Personal Information

We do not sell or trade personal information, or allow third parties to use that personal information for their own purposes.

If information needs to be accessed by a third party, we attempt to limit that access to the extent necessary for the third party to provide services to us or to perform its functions. We will ensure that those suppliers and contractors are also bound by duties of confidentiality and by the same privacy obligations as Pareto itself.

In all other cases, we will only disclose personal information to a third party if the disclosure is permitted by law (including under the National Privacy Principles).

We also ask our clients to confirm that they have made their own disclosures or obtained consents before they pass any personal information to us. We may also transfer personal information where permitted under the National Privacy Principles.

Privacy on Our Website

This policy applies equally to any personal information we collect via our website. Apart from personal information provided to us by members, clients and companies intentionally (eg. where they make a request or complete a registration form), this section explains some other ways in which Pareto collects information via its website. Pareto may from time to time provide links to websites operated by third parties. We are not responsible for the privacy practices or policies of those sites. We encourage Clients and Members to review each website's privacy policy, especially if they intend to disclose any personal information via that site. A link to another a third party website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.

Keeping that Information Secure

We store your personal information in different ways, these include both paper and electronic. We use security procedures and the latest technology to protect the information we hold. Access to and use of personal information within Pareto is limited to prevent misuse or unlawful disclosure of the information.

If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.

Pareto aims to achieve industry best practice in the security of personal information which it holds. It is our policy to destroy personal information once there is no longer a legal or business need for us to retain it.

Use of Cookies

In order to offer our services and to better respond to any problems Clients and Members may experience with the services or corporate website, Pareto uses cookies. A cookie is a small amount of data that is sent to a Member's browser from a web server and stored on the computer hard drive for record-keeping purposes.

Our services use cookies in two ways. First, we use them to identify Members in order for them to use the site. This cookie expires at the end of each Member session unless the Member affirmatively elects to use the "Remember My Password" feature at the time he first logs in to the site. We also use cookies to store and sometimes track information and record Member preferences. This information cannot be linked to a Member's personally identifiable information except for internal purposes when necessary (to contact a Member, for example). These cookies are an integral part of providing the services. If a Member's browser does not accept cookies, the Member cannot use the services.

Our corporate website uses two anonymous cookies in order to administer our website and best serve our visitors. The first is used to track how visitors have come to our site, and expires after 24 hours. The second cookie is used to determine how frequently a visitor or Member visits our corporate website, and expires after 1 year. Both of these anonymous cookies do not include any personally identifiable information about a site visitor, Member or Client.

Most browsers are initially set up to accept cookies. If you are concerned about receiving cookies you can reset your web browser program to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie.

Our Third Party Providers may also use their own cookies. Our Privacy Statement does not apply to their cookies, which are subject to the terms of their own privacy policies.

Traffic Monitoring

As well as collecting information such as contact and address details, our servers will also record traffic statistics such as the number of visitors to our site, the date and the time of the visits, the numbers pages viewed, etc. These details are primarily used for optimising our site and its performance. Any details recorded are anonymous and we cannot link your identity to these statistics.

We may also record telephone conversations for the purposes of staff training, compliance monitoring and ensuring orders that have been taken from customers are passed correctly to the issuer of that product.

Recorded Phone Lines

In order to ensure Pareto services are efficient and upheld with the highest integrity, Pareto may choose to record and monitor its incoming and outgoing land lines.

If you have a dispute over an order with one of our advisers, you may request a copy of the conversation (if a recording device has been used) or a written Record of Advice from the Complaints Manager, please see our Financial Services Guide for details on how to lodge a complaint.

Accuracy of Records

We take all reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

Access to Information

We will provide access to personal information upon request by a Client or Member, unless a request is unreasonable and the National Privacy Principles would permit us to decline that access (for instance, where granting access would infringe another person's privacy). Clients or Members who wish to gain access to their personal information should contact Pareto using the contact details set out in our website. When a request to access personal information is made, we will require you to provide some form of identification (eg. driver's licence or passport) so we can verify that you are the person to whom the information relates. In some cases we may also request an administrative fee to cover the cost of access.

Effect of Policy

This policy does not form a contract between an individual or corporate and Pareto. The policy may also be subject to change. Whenever you need to refer to this policy you should contact us, or check our website, for the most up to date version.