Marshall Investments Pty Ltd (ACN 058 848 561) of Suite 1, Level 12, 53 Martin Place, Sydney NSW 2000 and its related bodies corporate (we, us and our) understand that your privacy is paramount and are committed to protecting your privacy.
2 Collection of personal information
Personal information is information or an opinion about an individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in material form or not.
We may collect the following types of personal information:
- mailing or street address;
- email address;
- telephone number and other contact details;
- age or date of birth;
- details of the investment products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through mail or electronic mail ; or
- any other personal information that may be required in order to facilitate your dealings with us.
We may collect personal information from you when you:
- when you onboard with us as a client, we will collect the personal information you provide to us during the ordering process or in the course of your application
- communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
- visit our website; or
- contact us by any method, such as telephone, email, post, facsimile or in person,
or otherwise as notified to you from time to time.
The personal information you provide to us may vary depending on the nature of your interaction with us, but may for example include your name, date of birth, contact details and any communications you send to us.
Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, if you contact us with a general enquiry, we will not ask for your name unless we need it to adequately handle your enquiry.
However, for most of our functions and activities we usually need your name and contact information.
3 Our website
Our web servers may automatically collect anonymised information when you visit our websites, including:
- device type;
- operating system;
- the date and time of your visit;
- the parts of our website you access during your visit;
- your actions on our website; and
- the browser you are using.
Please note that rejecting cookies may mean that some or all of the functions on our website will not be available to you.
Sometimes our websites contain links to other websites that may be operated by third parties. Those links are provided for convenience and may not remain current or be maintained. When you access a website other than our websites, we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each website you visit.
4 Using your personal information
The personal information that we collect is generally used to provide investment products or services to you, and, if you use our website, to anonymously track your usage and to evaluate performance of our website. Information collected by us may also be used for the following purposes:
(i) provide you with information in relation to the investment opportunities we provide;
(ii) to send you marketing and promotional messages and other information that may be of interest to you;
(iii) to conduct marketing activities and to conduct market research;
(iv) to respond to your questions or suggestions;
(v) to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
(vi) to improve the quality of our products or services; or
(vii) to improve the quality of your visit to our Website.
You may opt out of receiving marketing information by notifying us accordingly, or by using any unsubscribe facility we provide for that purpose.
5 Sharing your personal information
We may disclose your personal information to other related entities within our corporate group in Australia for our own business purposes. While some of our related entities are located overseas, we do not provide your personal information to these entities.
We may disclose information to third party contractors, who help us conduct our business. Where information is shared with these third parties, we will take all reasonable steps to ensure that third parties observe the confidential nature of such information and are prohibited from using any or all of this information beyond what is necessary to assist us.
We may also disclose your personal information as permitted or required by law.
6 Accessing and correcting your personal information
We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under relevant privacy legislation. If you require access to your personal information, please contact our Compliance Officer as described in section 9 below. You may be required to put your request in writing for security reasons.
For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.
If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).
We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it. If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.
7 Protecting your personal information
We are committed to protecting your personal information. We take appropriate security measures to protect your personal information from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes the use of technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information.
8 Change of policy
9 Contact information
If you have any queries or complaints with regards to our collection, use or management of your personal information, please contact our Compliance Officer:
Attention: Compliance Officer
Subject line: Privacy query
Telephone: +61 2 8239 2000
If you make a complaint, we will endeavour to respond to it as soon as possible. If you are dissatisfied with our response, you have the right to make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email at email@example.com.