Barrenjoey Website Privacy Policy

1. Our Privacy Policy 

Barrenjoey Capital Partners Group Pty Limited (ACN 640 529 228) and its related bodies corporate (“Barrenjoey”, “we”, “us” or “our”) respect the privacy of people we deal with and are committed to protecting the information provided to us by clients, employees, contractors, service providers, visitors to this website and other persons.

This Privacy Policy explains how Barrenjoey collects, stores, uses and may disclose personal information in accordance with the requirements of the Australian Privacy Act 1988 (Cth) (“Privacy Act”) and Australian Privacy Principles (“APP”).

1.1    What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true or not; and regardless of how the information or opinion is recorded.

Sensitive personal information is personal information that includes information or an opinion about an individual’s racial or ethnic origin; political opinions or associations; religious or philosophical beliefs; trade union membership or associations; ; criminal record; or health or genetic information.

1.2.    What personal information might Barrenjoey collect?

We collect personal information reasonably necessary for us to carry on our business. Personal information we may collect includes:

  • identity details, name, and contact details;
  • employment and background information, and details of your work history, if you apply for work with Barrenjoey;
  • personal information from employees, such as date of birth and, if you choose to provide it, your tax file number;
  • potential business information with a view to creating third-party contractual or client relationship;
  • information in electronic communications, including emails, instant messages and other communications records, which may be automatically captured and digitally stored securely; and
  • information collected from publicly available sources, for instance, the media, social networking websites, regulatory websites, subscription entity and credit databases and criminal history record sources.

1.3    How do we collect your personal information?

We collect personal information by lawful and fair means and not in an unreasonable or intrusive way. Provided it is reasonable and practicable to do so, we will only collect personal information directly from you. You may choose not to provide us with your personal information. Without such information, we may not be able to provide you with an appropriate level of service. We are unlikely to collect sensitive personal information, unless required or permitted by law or where you consent.

We may collect personal information about you when you or your organisation uses or makes an enquiry via our website, seeks to do business with us or when you or your organisation offers to provide services to us. On occasions, we may also need to collect personal information from third parties, including public sources, your advisers, agents, brokers, statutory and regulatory bodies, and service providers (including credit reporting companies, fraud and financial crime information bodies, and other information service providers).

1.4   How we use and disclose your personal information?

Your personal information will generally only be used or disclosed for the reasons for which it was collected; for a reasonably expected secondary purpose; or as otherwise permitted under the law, including the Privacy Act.

Examples are set out below.

When we may use your personal information:

  • any purpose for which you consent;
  • offering and providing, products or services to you (including to your organisation);
  • administering and managing products and services for you (including your organisation)
  • operating and carrying on Barrenjoey’s business;
  • conducting  a client, employment, or contractual relationship with you;
  • undertaking  risk management functions as part of our operations;
  • providing you with information about Barrenjoey and its products and services;
  • conducting a client survey regarding our potential products and services or performance;
  • communicating with you to manage any enquiries or complaints; or
  • otherwise, in connection with Barrenjoey carrying out its business or operations.

1.5   When we may disclose your personal information:

We may disclose your personal information:

  • to fulfil our legal and regulatory obligations,  in Australia or any other jurisdiction, including but not limited to  statutory and regulatory requirements, reporting, taxation, audit requirements, anti-money laundering, anti-terrorism financing and sanctions requirements, or in connection with legal or investigative proceedings;
  • to a third party for a legal or regulatory requirement or request in accordance with laws and regulations, or rules of any relevant exchange, depository or clearing house;
  • to trade repositories or similar institutions (and related third party service providers), in accordance with laws and regulations, directive or otherwise;
  • to our financial institution and any financial institution or financial intermediary with which you or your organisation engage or propose to engage  in connection with our services ;
  • to any service provider in order to conduct our business or whom provide services in connection with our operations, for example, information technology and data service providers, business analysis or companies carrying out background and credit checks on our behalf;
  • to our officers, employees, agents, subcontractors, advisers, auditors, insurers, consultants and associates in connection with the conduct of our business ,
  • as permitted by law, or
  • as outlined in the terms and conditions of any specific products or services.

1.6   Outside Australia

In some circumstances, the parties to whom we disclose personal information may operate outside of Australia, this includes locations in the countries listed below. When this occurs, Barrenjoey takes reasonable steps to protect personal information against misuse or loss and must comply with certain safeguards under the Privacy Act in respect of the transfer of your data from one jurisdiction to another. Those parties may make such personal information available to their regulators and government of such countries in accordance with their respective local law requirements.

1.7   Storage and security of your personal information

We will utilise appropriate technical and organisational measures to keep your personal information confidential and secure in accordance with our internal practices concerning the storage, disclosure of and access to personal information. Your personal information may be kept on data technology systems and files, either those of our third-party vendors or our own. Access to your personal information will be restricted to representatives of Barrenjoey or to persons who are authorised by us.

1.8   How long will we retain your personal information?

Your personal information will be retained for the period we are legally required to keep records.

1.9   Accessing and correcting your personal information

You can request access to personal information that we hold about you at any time. We will provide the information we hold unless for legal or administrative reasons we are unable to do so.  Barrenjoey will respond to a request for access to personal information within a reasonable time and will attempt to provide you with convenient access to this information in the way you have requested.

You are also able to request to have any inaccurate personal information we may have about you corrected, or request us to restrict our ongoing use of your personal information, which we will do if this is practicable and we are legally entitled to do so in the circumstances.

1.10   Opting out of direct marketing

Whilst we do not currently anticipate doing so, we may use or disclose your personal information for direct marketing purposes. If you do not wish to receive direct marketing about us and our products and services, you can opt out at any time by sending us a request using the contact details below.

1.11   Notifiable data breaches

The notifiable data breaches scheme requires Barrenjoey to notify affected individuals and the Australian Information Commissioner of certain data breaches. If a data breach occurs, Barrenjoey will perform an assessment to determine

if there has been a ‘eligible data breach’ whereby the access or disclosure of personal information is likely to result in serious harm to the individual(s) to whom the personal information relates. If Barrenjoey determines there has been an eligible data breach, affected individuals will be notified as soon as practicable of the details of the breach and the recommended steps the relevant individual(s) should take in response to it. If required, Barrenjoey will inform the Office of the Australian Information Commissioner.

1.12   Disclosure to other Countries

Personal information may be disclosed to third parties in jurisdictions outside Australia including: Hong Kong, Singapore, UK, United States, Japan, European member countries.

1.13   Questions and complaints

If you have any questions or complaints about this policy or our collection, use or disclosure of your personal information, please contact the Barrenjoey Privacy Officer or Head of Compliance at enquiries@barrenjoey.com

If you require any further information on Australian privacy laws, you may also contact the Office of the Australian Information Commissioner on 1300 363 992, or by visiting their website at www.oaic.gov.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.

2.   Use of this website

www.barrenjoey.com is owned and operated by Barrenjoey.  You must not use the Barrenjoey website or any of its content in any manner which violates our rights with respect to intellectual property, logos, copyright and trademarks claimed over information and content on this site.

Barrenjoey may collect information about you through your access to this website.  We may use or disclose information gathered via your use of this site for general business purposes, other than personal information, which will be dealt with in accordance with this privacy policy.

2.1   Use of cookies

Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used to make websites work, as well as to provide information to the owners of visited websites. Barrenjoey and its third-party service providers may collect, analyse and use information collected from the use of cookies. You can manage and control the use of cookies via your web browser and your device’s browser history when you leave this site.