Dominium Capital Group is committed to client service and this policy outlines our ongoing obligations toyou in respect of how we manage your Personal Information.
Dominium Capital Group is bound by the Australian Privacy Principles (APPs) contained in the Privacy Act1988 (Cth) (Privacy Act). The APPs are designed to protect the confidentiality of information and theprivacy of individuals by regulating the way personal information is collected, used, disclosed and managed.Personal information is, generally speaking, information or an opinion relating to an identified, orreasonably identifiable, individual.
This policy explains the types of personal information that we may collect and hold, how that information isused and with whom the information is shared. It also sets out how you can contact us if you have anyqueries or concerns about this information.
Why do we collect personal information?Dominium Capital Group collects your personal information so that we can perform our various functionsand activities. Dominium Capital Group also collects your personal information if the law requires us to collect it. If Dominium Capital Group does not collect your personal information, we may not be able todeal with you, or provide you with a product or service.
Dominium Capital Group collects most personal information directly from you. For example, you provide uswith your information when you open an account, fill in an application form, deal with us over thetelephone, send us a letter, use our websites or visit our office. If you apply for products or services,Dominium Capital Group may collect and hold information from you such as your name, address, telephonenumber, e-mail address, tax file number (TFN), date of birth, annual income and other financial details,place of work, credit history, and your transaction history.
Collecting information from third partiesDominium Capital Group may also collect information about you that is publicly available, includinginformation from telephone directories, the electoral roll or other websites.
There may be occasions when Dominium Capital Group collects personal information about you from athird party. For example, Dominium Capital Group may collect personal information from:• Credit reporting bodies if we request a report about your credit history;• Other credit providers if we request information from them about the products they provide to you;• Organisations that Dominium Capital Group has an arrangement with to jointly offer products and/or hasan alliance with to share information for marketing purposes to provide you with products or servicesand/or to promote a product or service;• Our related entities so we can better manage your relationship with all Dominium Capital Groupcompanies;• Marketing companies if we acquire contact information to tell people about Dominium Capital Groupproducts and services that may interest them; and• Other parties who may have introduced you to Dominium Capital Group.
Collecting sensitive informationSensitive information is personal information about a person’s racial or ethnic origin, political opinion,membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of aprofessional or trade association, membership of a trade union, sexual orientation or practices, criminalrecord, genetic information or health information.
Dominium Capital Group will not collect, use or disclose sensitive information about you unless we needthe information for one of our functions or activities and we have your consent (or we are legally requiredto do so).
For example, Dominium Capital Financial Advisers often collects health information from you, with yourconsent, to assist you in applying for life insurance. Any chosen insurer that Dominium Capital FinancialAdvisers deals with may also collect information about you if your family members apply for products suchas life insurance or trauma and disablement cover.
Collecting information required by lawDominium Capital Group may collect information from you because we are required or authorised by anAustralian law or court or tribunal order to collect that information. We will tell you if collection is requiredor authorised by law and provide you with details of the law, court or tribunal order.
For example, when you open a deposit account or take out a loan, Dominium Capital is required under theAnti-Money Laundering and Counter-Terrorism Financing Act to collect certain information from you toprove your identity, such as your driver’s licence or passport details.
Dominium Capital Group companies may collect your Australian tax file number (TFN) when you open adeposit account. It is not compulsory to provide your TFN, but if you do not, the financial institution (forexample, a bank) may deduct withholding tax from your interest payments at the highest marginal rate.Dominium Capital Group will only collect your TFN in order to pass this information on to a financialinstitution, for the purposes of that entity being able to determine whether you are subject to withholdingtax on any interest payments you receive and for no other purpose. As always, we will only collect thisinformation with your consent.
If Dominium Capital Group collects your TFN, we will handle your TFN in accordance with the Privacy Actand Guidelines issued by the Commissioner.The National Consumer Credit Protection Act 2010 requires entities which provide credit assistance andadvice, like Dominium Capital, to make inquiries into the financial situation, needs and objectives ofindividuals who apply for consumer credit. This is to ensure the credit provider has the information – suchas the individual’s financial commitments, income and liabilities - to make an informed decision aboutwhether the individual can afford the credit they are applying for.
Dominium Capital Group may also be required to ask about your tax residency status under taxationinformation sharing agreements the Australian Government has in place with other countries. For example,a tax treaty between Australia and the United States formed under US law (Foreign Account Tax Compliance Act) requires Australian financial institutions and fund managers to ask account holders of some types of products whether they are US citizens or US tax residents when they open their product. If you are a tax resident of another country, the relevant treaty or law may require us to collect your relevant foreign tax identification number.
Using your personal informationWe may use and disclose personal information we collect about you for several purposes including:• To consider your request for a product or service;• To enable Dominium Capital Group to provide a product or service;• To tell you about other products and services that may be of interest to you;• To manage accounts and perform other administrative and operational tasks (including risk management,systems development and testing, credit scoring and staff training, collecting debts and market or customersatisfaction research);• To consider any concerns or complaints you raise against Dominium Capital Group and/or to manage anylegal action between you and Dominium Capital Group, its associates and or other related entities;• To prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;• To identify you or establish your tax status under any Australian or foreign legislation, regulation or treatypursuant to an agreement with any tax authority; and• As required by relevant laws, regulations, codes of practice.
Disclosing your personal information overseasDominium Capital Group does not generally disclose your information to any overseas parties.Dominium Capital Group will not send your personal information to a recipient outside Australia withoutobtaining your consent or otherwise complying with the APPs.
For the purposes of communicating and marketing information and offers to our clients, Dominium CapitalGroup does (as at the date of this document) use the services of a bulk email service provider, whichnecessitates the storage of client information (first name, surname and email address(s)) on the serviceprovider’s secure servers located in the United States.
Dominium Capital Group has taken reasonable stepsto seek undertakings from our service providers to ensure that client information deleted from the serviceprovider in the United States will not be stored or made available for future retrieval from any party(including the service provider) at any future time and that the information is unable to be restored by thatprovider. Additionally, Dominium Capital Group uses the services of United States based company,Alphabet, through their G Suite and Drive application, to operate our servers remotely and these serversare located in several offshore locations. Our data backup and recovery provider is also located in the United States. We have also taken reasonable steps to ensure the security and privacy of our clients are adhered to by these service providers. Additionally, we may use the service of providers in the following countries, including: Canada, Malaysia, India, Ireland, the United Kingdom, Singapore, Taiwan, Netherlands, Finland, Belgium and the Philippines.
Security and management of personal informationDominium Capital Group will take reasonable steps to protect the personal information we hold frommisuse and loss and from unauthorised access, modification or disclosure. The ways we do this include:• limiting physical access to our premises;• limiting access to the information we collect about you (for instance, only those of our personnelwho need your information to carry out our business activities are allowed access);• requiring any third party providers to have acceptable security measures to keep personalinformation secure; and• putting in place physical, electronic, and procedural safeguards in line with industry standards.If we no longer require your personal information and are not legally required to retain it, DominiumCapital Group will take reasonable steps to destroy or permanently de-identify the personal information.Links from our website to other websitesOur website may contain links to third party websites. We do not operate these websites and therefore arenot responsible for the collection or handling of personal information by the operators of these websites.Accessing the information we hold about youUnder the APPs, you may be able to obtain a copy of the personal information that we hold about you. TheAPPs provide some exceptions to your rights in this regard. To make a request to access this information,please contact us in writing. We will require you to verify your identity and specify what information yourequire.
Updating your personal informationWe endeavour to ensure that the personal information we hold about you is accurate, complete and up-todate. Please contact Dominium Capital Group at the contact address set out below if you believe that theinformation we hold about you requires correction or is out-of-date.
ComplaintsIf you are concerned that we have not complied with your legal rights or applicable privacy laws, you maybring a complaint internally through our complaints process or you may decide to make a formal complaintwith the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulatorresponsible for privacy in Australia).We will deal with complaints as follows:Step 1: Please let us knowIf you would like to make a complaint, you should let us know by contacting our Privacy Officer (see belowfor contact details).Step 2: Investigation of complaintYour complaint will be investigated by our Managing Director and our Complaints Manager.A response to your complaint will be provided in writing within a reasonable period.Step 3: Contact OAICWe expect our procedures will deal fairly and promptly with your complaint. However, if you remaindissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:Office of the Australian Information Commissioner (OAIC)Telephone: 1300 363 992