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StoneBridge is committed to implementing and promoting a privacy policy which will ensure the privacy and security of your Personal Information. The following Privacy Policy expresses our policies on the management of your Personal Information. 1. National Privacy Principles The StoneBridge Group abides by the National Privacy Principles established under the Privacy Amendment (Private Sector) Act 2001. A summary of the National Privacy Principles is available on our website or by contacting our office. 2. Collection of Personal Information 2.1 As a licensed securities dealer and as a futures broker we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“Personal Information”). In order to provide you with a comprehensive advisory and dealing service in financial products (“Financial Products”), we require certain Personal Information about you, including: a. your employment details; b. home address and contact details; c. details of your income, assets and liabilities. 2.2 We will not collect any Personal Information about you except where you have knowingly provided that information to us or authorised a third party to provide that information to us. 2.3 Generally, collection of your Personal Information will be effected either by face to face interviews, over the telephone, by email or by completion of a client account application form. From time to time additional and/or updated Personal Information may be collected through one or more of those methods. 2.4 We will only collect, maintain and use Personal Information about you if it is necessary for us to adequately provide to you the services you have requested including: a. making Financial Product recommendations; b. executing Financial Product transactions on your behalf; c. clearing and settling Financial Products transactions on your behalf, - and all things necessary or incidental to the above. 3. Use and Disclosure of Personal Information 3.1 We will not use or disclose Personal Information collected by us for any purpose other than: a. the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or b. where you have consented to such disclosure; or c. where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body. 3.2 We are required under the Corporations Act and the Rules of the ASX to make certain information available for inspection by the Australian Securities and Investments Commission and ASX on request to ensure ongoing compliance with licensing and regulatory requirements. This may involve the disclosure of your Personal Information. 3.3 We may use the Personal Information collected from you for the purpose of providing you with investment product and services information and marketing material for any member of the StoneBridge Group such as research that may be of interest to you. However, you may, by contacting us by any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow 2 weeks for your request to be actioned. 3.4 We may disclose your Personal Information to market operators, clearers and product issuers for the purpose of giving effect to your instructions and the recommendations made by us. 3.5 We may disclose your Personal Information to external contractors for the following purposes: a. execution, clearing and settlement of Financial Products transactions b. registration and/or changes to shareholder details; c. accounting for Financial Products transactions; d. causing statutory audits to be conducted as required by law; e. maintenance and service of our information technology systems; and f. in the course of reviews by external consultants. It is a condition of our agreement with each of our external contractors that they adopt and adhere to this privacy policy. You can be assured that your information will be maintained by any contractor to whom it is disclosed in accordance with this policy. If you have any concerns in this regard, you should contact us by any of the methods detailed below. 4. Document storage and security 4.1 Your Personal Information is generally held in your client file. Information may also be held in a computer database. 4.2 We will at all times seek to ensure that the Personal Information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your Personal Information is treated as confidential and any sensitive information is treated as highly confidential and stored securely. Access to our premises is controlled by allowing only personnel with security passes to access the premises. Unauthorised persons are strictly prohibited from entering our dealing rooms. All computer based information is protected through the use of access passwords on each computer and screen saver passwords. Data is backed up each evening. 4.3 In the event you cease to be a client of the StoneBridge Group, any Personal Information which we hold about you will be maintained in a secure off site storage facility for a period of 7 years in order to comply with legislative and regulatory requirements, following which time the information will be destroyed. 4.4 When permitted by your agreement with us, telephone recordings of your conversations with us may be kept, used and deleted prior to the expiry of the 7 year period. 5. Access to your Personal Information
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