PRIVACY POLICY

PRIVACY POLICY

Introduction

Red Leaf Securities Pty Ltd (ACN 606 000 800) understands the importance and takes the protection of personal information seriously. The information below explains how Red Leaf Securities Pty secures individual privacy, how it obtains information and how it uses this information to provide services and products.

Red Lead Securities Pty Ltd is safeguarding your personal information in accordance with the requirements of the national privacy principles of the Privacy Act 1988.

Securing Individual Privacy

Generally, Red Leaf Securities Pty Ltd will not disclose or use information collected about you otherwise than for the purposes set out in this policy, for a purpose required or permitted by law, or for a purpose otherwise disclosed to, or authorised by you.

Personal information is stored and held by a combination of hard and electronic client files maintained by Red Leaf Securities Pty Ltd. Personal information is only accessible, on a need to know basis, by authorised representatives of Red Leaf Securities Pty Ltd.

Red Leaf Securities Pty Ltd will take all reasonable steps to protect personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure by using industry standard software protection programs.

Red Leaf Securities Pty Ltd will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.

Obtaining Information

Red Leaf Securities Pty Ltd only collects personal information by lawful and fair means and not in an unreasonably intrusive way. The types of personal information we collect generally includes:

  • name
  • date of birth
  • address
  • telephone number
  • email address
  • financial information (employment details, earnings and assets)
  • bank account details

Red Leaf Securities primary source of collecting personal information is directly from you when you apply for a product or a service, deal with us as a key contact or employee of a client, deal with us over the telephone or in person, send us a letter or visit our website. On occasions, we may collect personal information about you from third parties, for example, share registries, ASIC or credit reporting agencies. Personal information is used by Red Leaf Securities Pty Ltd for the purpose of conducting our business.

We may also need to collect personal and sensitive information in order to comply with our legal obligations, such as the Anti-Money Laundering and Counter-Terrorism Financing laws, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

How Information is used

Personal information is used by Red Leaf Securities Pty Ltd in order to implement our services to you so we can conduct our regular course of business. The use of the personal information includes but is not limited to:

  • determining your identity;
  • complying with legislative and regulatory requirements;
  • providing you with market updates that are connected with your investment;
  • updating you with potential investment opportunities;
  • inviting you to events that maybe of interest to you;
  • conducting research that ensures that we are providing you with an improved investor experience.
  • performing our administrative operations which includes record keeping, risk management analysis, system development and archiving.

Red Leaf Securities may also need to collect personal and sensitive information in order to comply with our legal obligations, such as the Anti-Money Laundering and Counter-Terrorism Financing laws, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

Disclosure of Personal Information

Red Leaf Securities Pty Ltd may disclose personal information to its agents so they can provide services to the client. From time to time, Red Leaf Securities it might disclose personal information to third parties to assist us with our activities. The third parties may include:

  • share registry services;
  • debt collection agencies;
  • entities that are related bodies corporate to Red Leaf Securities Pty Ltd;
  • government and law enforcement agencies;
  • regulators;
  • those that provide Red Leaf Securities Pty Ltd with outsourced functions.

Red Leaf Securities Pty Ltd will disclose your personal information if one of the below applies:

  • Red Leaf Securities is authorised or required to do so by law;
  • Disclosure is necessary for a law enforcement related activity;
  • By your personal consent;
  • Where you would reasonably expect Red Leaf Securities Pty Ltd to use or disclose your personal information in this way;
  • Disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety.

In some cases, Red Leaf Securities Pty Ltd may need to transfer your personal information outside Australia. If Red Leaf Securities Pty Ltd believes that the overseas third party is not subject to, or has not agreed to comply with, privacy obligations equivalent to those which apply to us, we will seek your consent to transfer the information, except where the national privacy principles do not require us to do so.

Red Leaf Securities Pty Ltd Website

Red Leaf Securities Pty Ltd compliance with the national privacy principles also extends to when you transact business via our website.

When you use a link from the Red Leaf Securities Pty Ltd website to the websites of third parties, those websites are not subject to Red Leaf Securities Pty Ltd privacy standards. Those third parties are responsible for informing you of their own privacy policies.

Contact Us

If at any time you wish to know what personal information that Red Leaf Securities Pty Ltd is holding about you, you are welcome to ask us for your details by writing to us in a form or manner which identifies the nature of the personal information requested. The appropriate contact is:

Attention: Red Leaf Securities Pty Ltd Private Policy Administration

Email: contact@redleafsecurities.com

Under certain circumsantaces Red Leaf Securities Pty Ltd may not be able to tell you about the personal information that we hold about you: These circumstances include but not limited to:

  • if the information relates to a legal proceeding;
  • the information would have an unreasonable impact on the privacy of another individual;
  • the information would reveal a commercially sensitive decision-making process; or
  • would legally prevent Red Leaf Securities Pty Ltd from disclosing the information, or providing access which would prejudice certain investigations.

Red Leaf Securities will take reasonable steps to ensure that your personal information is accurate, complete and up to date.

If at any time, you find that current personal information we hold about you is inaccurate, incomplete or out of date, please contact Red Leaf Securities Pty Ltd and they will correct it.

If at any time you do not wish to receive such marketing information, you have the option to ask Red Leaf Securities Pty Ltd not to send you any further such material – you may do so by contacting Red Leaf Securities Pty Ltd.

Updates

Please note that this policy may change from time to time due to business or law change requirements. Red Leaf Securities Pty Ltd will review its Privacy Policy on a regular basis and update it as required.

COMPLAINTS

Complaints

Complaints in relation to this Privacy Policy or the collection of personal information will be investigated by Red Leaf Securities Pty Ltd within a reasonable period after the complaint is received. Following an investigation, a response will be provided by Red Leaf Securities Pty Ltd to the individual.

If a person is not satisfied with the way in which Red Leaf Securities Pty Ltd handles an enquiry or complaint, they can call the Office of the Australian Information Commissioner on 1300 363 992.

COMPLAINT MANAGEMENT POLICY

1.   INTRODUCTION

1.1   Red Leaf Securities Pty Limited (“Red Leaf Securities, we or us”) is committed to effective and efficient complaints management and to fair and transparent dealings in the financial marketplace.

1.2   A complaint is an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.

2.   OUR COMPLAINTS MANAGEMENT PROCESS

2.1   We take your feedback seriously and will work proactively to investigate and resolve your complaint. If you have a complaint, please contact us by any of the following methods:

(a)   Email: administration@redleafequities.com.au;

(b)   Toll-free telephone: 02 8318 4300;

(c)   Post: Level 1, 37 Bligh Street, Sydney NSW 2000; or

(d)   Social Media: Red Leaf Securities on Twitter.

2.2   Any material relating to Red Leaf Securities’ Internal Dispute Resolution (“IDR”) process will be provided to you free of charge.

2.3   We will collect certain information from you, including:

(a)   Your name;

(b)   Your contact details;

(c)   How you would prefer to be contacted;

(d)   A description of your complaint; and

(e)   How you would like the complaint resolved.

2.4   We will acknowledge your complaint, generally within one (1) business day, and give you the contact details of the person responsible for dealing with your complaint.

2.5   The person responsible for dealing with your complaint will commence their investigation and may require further details from you. Upon completion of their investigation, the person responsible for dealing with your complaint will contact you with an IDR response. This will provide you with information about:

(a)   the final outcome of your complaint at IDR; and

(b)   your right to take the complaint to the Australian Financial Complaints Authority (“AFCA”) if you are not satisfied with the IDR response and how to contact AFCA.

2.6   An IDR response is not required to be provided to you when a complaint is resolved by the end of the fifth (5th) business day of receipt of the complaint, where we have:

(a)   resolved the complaint to your satisfaction; or

(b)   given you an explanation and/or apology when no further action to reasonably address the complaint can be taken.

2.7   A written response will be provided if:

(a)   you request a written response; or

(b)   the complaint is about hardship.

3.   TIMEFRAME FOR RESOLVING COMPLAINTS

3.1   We endeavour to resolve all complaints as quickly as practicable. Many complaints can be resolved within days or on the spot. We will keep you informed in relation to your dispute and will provide you with an IDR response within thirty (30) calendar days of receiving your complaint.

4.   IF YOU ARE UNHAPPY WITH OUR RESPONSE

4.1   If your complaint is not resolved to your satisfaction through our IDR process, you have the right to refer your complaint to AFCA. AFCA is an independent and external dispute resolution scheme, of which Red Leaf Securities is a member.

4.2   You can lodge your complaint with AFCA by sending the relevant information and documents to:

Australian Financial Complaints Authority Limited

GPO Box 3

Melbourne VIC 3001

Phone: 1800 931 678

Fax: (03) 9613 6399

Email: info@afca.org.au

Website: https://www.afca.org.au/

5.   ACCESSIBILITY SERVICES

5.1   We take our commitment to provide accessible services to customers seriously.

5.2   If you are deaf or have a hearing or speech impairment, you can contact us on the National Relay Service, a government initiative that offers an Australia-wide phone service for people who are deaf or have a hearing or speech impairment. It’s available at no additional charge:

(a)   Talk to text users, please call 133 677 and then ask for 02 8318 4300;

(b)   Speak to listen users, please call 1300 555 727 and then ask for 02 8318 4300;

(c)   Internet relay users, please connect to the NRS and then ask for 02 8318 4300.

5.3   If you require this Policy is another language, please contact us at the details below.

6.   CONTACT US

6.1   If you have any questions or would like further information about our complaints handling process, please contact us by:

(a)   Email: administration@redleafequities.com.au; or

(b)   Phone: 02 8318 4300; or

(c)   Post: Level 1, 37 Bligh Street, Sydney NSW 2000.