Privacy Policy
Application
This Privacy Policy applies to information collected by Allston Capital Pty Ltd ATF Allston Capital Unit Trust (ACN 678 301 230) trading as Allston Capital (ABN 17 122 590 258) (Allston Capital).
We are committed to protecting your privacy and adhere to the Australian Privacy Principles set out in the Privacy Act 1988 (Cth). We reserve the right to change this Privacy Policy from time to time by amending our Privacy Policy, as set out below.
This Privacy Policy outlines how we manage the collection, use, disclosure and storage of your personal and sensitive information. Unless you give us explicit consent otherwise, we will act in accordance with this Privacy Policy about our collection, use and storage of your personal information.
By requesting our Services or by using our Website you consent to our collection and use of your personal information in accordance with this Privacy Policy. If you do not agree to the terms of this policy, please notify us immediately by contacting us at contact@allston.com.au.
The type of Personal Information we collect
We may collect Personal information directly from you which enables us to deliver the Services or conduct enquiries prior to agreeing to provide the Services. This information may relate to you, your businesss, incorporated entities or related third parties (for example your spouse or dependents). In some cases, we may also collect your Personal Information from external sources.
The types of personal information we may collect and retain depends on the nature of our interaction with you and may include:
Contact information such as your name, postal and email address and phone number;
Personal identity information;
Corporate details, including but not limited to, ABN, ACN, trust details, registered business address and the names and addresses of company officers, employees, contractors and customers
Financial records and historical financial data;
Government identifiers;
Insurance history and current policies held;
Information the Services we have historically provided to you and any feedback you have provided regarding our Services;
Non-personal information that does not reveal your identity, including your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address, standard web log information and cookies from your computer.
The information we collect about you will be referred to below as Personal Information.
How we collect your Personal Information
We can collect your Personal Information in various ways, including when you:
visit our website;
request our Services;
provide information to us via the client portal on our Website;
visit our business premises;
engage or correspond with us via telephone, or on social media or messaging platforms, including email, LinkedIn.
We may use cookies and similar technologies to track and collect information about which parts of our Website are visited by you.
This information is used to recognise your computer when you visit our Website, to maintain the quality of the Services and personalise the information appearing on our Website for you.
If you prefer that cookies are not stored on your hard drive you can configure your browser to disable cookies, however this may compromise your experience on website and your ability to use all the functionality on our website.
Protecting your Personal Information
We are committed to keeping your Personal Information secure and protected from misuse, loss or unauthorised access or disclosure. Whilst we take all reasonable measures to protect the Personal Information we hold about you, we cannot guarantee the effectiveness of our data protection or security measures.
We only store your Personal Information electronically on secure databases that we operate or are operated by trusted service providers, however we may also store it in hard copy if necessary or required by law.
We will retain your Personal Information for as long as permitted and required by law, after which time it will be removed from our systems or destroyed.
Use of your Personal Information
We may use your Personal Information in the following ways:
To confirm your identity and provide you with the Services;
To provide you with accurate and relevant information about our Services;
To assist you in relation to any questions you may have about our Services;
To third parties where necessary for us to provide our Services to you, including third party providers of IT software or client portal functionality on our Website;
To send you newsletters, market update or direct marketing campaigns which may align with your preferences and the Services you have previously requested from us;
Inviting you to events and seminars and marketing certain services which we or others provide which we think may be of interest to you;
To follow up regarding any Services we have provided to you.
To respond to any requests or complaints you make to us; and
To disclose it to our advisers or any third parties to whom we are authorised or required by law to disclose your information to.
We may combine data we collect from different sources to achieve the above purposes and to provide you with a more personalized experience across our Services.
We may also use your Personal Information for any other purpose which we state at the time of collection.
You are solely responsible for ensuring that any Personal Information we have in relation to you is current, complete and accurate at all times
Disclosure of your Personal Information
We will only disclose your Personal Information for the purpose of providing the Services. Disclosure to any third parties in order to provide the Services will only be made on a confidential basis and in accordance with applicable law.
We will only disclose your Personal Information:
When we have your consent.
To third parties, including third party cloud based service providers, where necessary for us to provide our Services to you, for administrative, book keeping, CRM, Website or online client portal access, reporting services including delivery of documents, information or other materials, or where you have expressly asked us to do so for the purposes of them or us providing further services.
To our related bodies corporate, and their respective directors, officers, agents, and employees for processing personal, sensitive or protected information on our behalf.
To comply with any law enforcement agency, judicial proceeding, court order, or legal process in any jurisdiction that is investigating any breach or suspected breach of any law in any jurisdiction regarding your identity, or other personal, sensitive or protected information provided by you to us.
Where disclosure is reasonably necessary to protect our rights or intellectual property or to protect the safety of our employees or the public, as required or permitted by law.
Where we consider disclosure is necessary for the protection and wellbeing of a person.
Where your personal information is disclosed to a third party service provider, that third party may disclosue or use of your personal information pursuant to its own privacy policy, a copy of which will be provided to you upon your request.
Where we are otherwise required or permitted by law to disclose your personal, sensitive or protected information
No obligation to provide your Personal Information
If you choose not to provide us with your Personal Information, we may not be able to competently provide you with our Services, in which case we may refuse to commence an engagement with you, or terminate our engagement with you, in our discretion and without any liability.
Electronic storage of your Personal Information
Whilst we take all due care in ensuring the privacy and security of your personal, sensitive and protected information, the possibility exists that this information could be unlawfully intercepted while in transit over the internet or while stored on our systems or on our website. We disclaim all liability to you for any data breach to the greatest extent permitted by law.
We will take reasonable steps to destroy or permanently de-identify personal, sensitive and protected information if it is no longer needed for the purpose for which the information was disclosed.
Storage of your Personal Information
Some entities that we share your Personal Information with may be located in, or have operations in, other countries. If your information is provided to or stored by an overseas recipient, we use all reasonable efforts to ensure that appropriate data protection and handling measures are in place.
Your responsibility to keep your Personal Information current
You acknowledge that it is your sole responsibility to contact us from time to time to inform us of any changes to Personal Information to ensure that it is up to date, relevant and of an appropriate quality to enable us to provide the Services to you, including but not limited to your financial information, account and financial information, your login and other information and relevant record keeping.
We will take reasonable steps to correct your personal, sensitive and protected information if you inform us that your information is inaccurate, out of date, incomplete, irrelevant or misleading, including making any appropriate deletions or additions to your personal, sensitive and protected information.
If you cease to use our Services, we may retain your personal, sensitive and protected information to comply with our record keeping obligations under law
Further Information
You can request more specific information from us about the Personal Information we hold about you, for what purposes it is being collected, held or used.
If you have any queries in relation to this Privacy Policy, or if you wish to correct, update or request access to your Personal Information or have a complaint about a breach of privacy, then please contact our Privacy Officer via contact@allston.com.au.
Your enquiry or complaint will be dealt with as soon as possible, but in any case, you will receive return correspondence from us no later than fourteen (14) days after submitting your enquiry or complaint. If we cannot resolve your enquiry complaint within fourteen (14) business days, we will contact you an let you know how long it will take to address your enquiry or complaint.
Services refers to the services and advice provided by Allston Capital Pty Ltd to you.
We, ours, and us refers to refers to Allston Capital Pty Ltd.
You, yours, and customer refers to the customer requesting the Services.
Website means www.allston.com.au