Privacy Policy

Kingwood Capital Limited (Kingwood Capital) respects the privacy of the people we deal with and we uphold high standards of privacy practice and security. This policy explains how we handle personal information and how we interact with you online.

Whenever we handle personal information, we take steps to ensure that appropriate standards of privacy practice and security are applied.

This Privacy Policy sets out why we need to collect personal information, how we collect it, what we do with it, how it's stored and who we might share it with. The Policy also describes how you can access or correct information we hold about you, how you can ask further questions or make a complaint, and information about our websites and online activities.

By using the products or services provided by us you consent to Kingwood Capital using your personal information as set out in this Privacy Policy.

Our commitment to protect your privacy

We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any information we hold about you will be treated in a way which ensures protection of that information.

We use security procedures and technology to protect the information we hold. Access to and use of personal information by Kingwood Capital seeks to prevent misuse or unlawful disclosure of the information.

If other organisations provide support services, we require them to take appropriate technical and organisational measures to secure the privacy of the information provided to them.

Personal information

When we refer to personal information we mean information or an opinion relating to an individual which can be used to identify that individual.

The kinds of personal information we collect about you includes (but is not limited to):

Names
Contact Details
Genders
Dates of Birth
Employment details and employment history
Tax File Numbers

You have a right not to provide us with your personal information, but failure to provide such information may affect the services we provide to you. We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.

Sensitive information

Generally, we do not collect sensitive information about you unless required by law or where you consent for us to do so (and in any event only where it is relevant to your product). We will not collect sensitive information about you where this is expressly prohibited by law. Sensitive information includes information relating to:

race;
political or religious beliefs;
sexual orientation and sexual life;
criminal convictions;
membership of professional or trade associations or unions;
biometric and health information; and/or
information about your affiliation with certain organisations, such as professional associations.

Why we collect your information

We collect personal information for the purposes of providing services to you and identifying you. We may also collect your personal information for the purposes of managing our relationship with you. The information may also be used by us for marketing, planning, product development and research purposes.

In providing our services to you we may need to disclose personal information to a third party. This will be done to the extent that it is permitted by law and set out in this Policy.

How we collect your information

We collect personal information about you directly from you — this can be in person, in documents you give us, from telephone calls, emails, competitions you enter, your access to our website or from transactions you make. We take reasonable steps to be transparent about how and why we collect personal data.

We may also collect your personal information from joint account holder(s) or third parties including public sources, your adviser(s), employer (or its affiliates), agents, introducers, referrers, brokers, our related companies and service providers (including credit reporting bodies and information service providers).

How we store your information

We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include processing or storage in the cloud, which may mean in practice that this information is stored outside Australia. Where this occurs, we take steps to protect the security and integrity of personal information.

We also keep records of our interactions with you (including by telephone, email and online) and of your transaction history.

A “cookie” is a packet of information placed on a user's computer by a website for record keeping purposes. While cookies are not considered personal information, they are generally used:

access online services;
manage advertising;
monitor traffic; and
monitor your use of our webiste.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the Help menu of your browser to learn how to change your cookie preferences).

How we use your information

We use your personal information for the purpose for which it was provided to us, including to:

administer and manage our products and services (including monitoring, auditing, and evaluating those products and services);
model and test data (in a controlled environment);
develop scores, risk assessments and related analytical tools; and
communicate with you and deal with or investigate any complaints or enquiries.

We may also:

anonymise your data for our own purposes including market research, new product development and fraud mitigation; and
use or permit our affiliates to use your personal information for related purposes to the extent that it is lawful to do so without your express permission. For example, we may from time to time use your personal information to inform you or your employer of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, if you don't want to receive such communications you can tell us by using any of the methods listed below.

When your information is disclosed

Subject in all cases to law we may disclose personal information outside of Kingwood Capital:

as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator;
to our service providers, who provide services in connection with our products and services (including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, information broking, mailing, marketing, research, investigation, insurance, identity verification, brokerage, maintenance, trustee, securitisation, website and technology services);
to an affiliate;
to your nominated financial or other advisers with your permission;
as contained in the terms and conditions of any specific product or service; and
to anyone, where you have provided us consent;

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
you have consented to us making the disclosure.

How you can access or correct your information

You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

Keeping information accurate and up to date

We take reasonable steps to ensure that all information we hold is as accurate as 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.

Changes in our Privacy Policy

We may, without notice, amend this Policy from time to time for any reason and will update the Policy accordingly. We ask that you visit our website periodically in order to remain up to date with such changes. We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices. As a consequence we may change this Privacy Policy from time to time or as the need arises.

If you have any questions or complaints regarding privacy or information handling, please write to admin@kingwoodcap.com or contact us by phone. We will respond to let you know who will be handling your matter and when you can expect a further response.

If you believe Kingwood Capital has not adequately dealt with any complaint and you are not satisfied, you may complain to the Officer of the Australian Information Commissioner (OAIC) at GPO Box 5218, Sydney NSW 2001, or by telephone on 1300 363 992 or by email at enquiries@oaic.gov.au.