Unless stated otherwise, Halberd Bastion on this page, means any of:
- Halberd Bastion Pty Ltd; and/or
- any of their related bodies corporate or related companies wherever incorporated in Australia or New Zealand.
Halberd Bastion understands and appreciates that the privacy of personal information Halberd Bastion may collect about you is important. Halberd Bastion is committed to providing you with high quality consultation services in a secure and confidential manner. Halberd Bastion complies with the Australian Privacy Principles as required under the Privacy Act 1988 (Cth) in Australia and its obligations under the Privacy Act 1993 in New Zealand when handling your personal information.
- what personal information we may collect about you;
- to whom your personal information may be disclosed;
- the purposes for which your personal information may be used and disclosed;
- our arrangements for the security of any personal information we hold about you;
- how you may access and correct your personal information;
- how you may make a complaint in relation to your privacy; and
- how you can contact us.
What Personal Information We Collect About You
Where possible, we will collect your personal information from you directly. Circumstances in which we may collect your personal information from third parties include:
- for payment purposes at your direction;
- to verify identity and for customer due diligence purposes;
- for the prevention and detection of money laundering and terrorism financing;
- background checking and verification in connection with recruitment;
- where you have consented;
- where you have defaulted on payment or delivery of products
- where we are required or authorised by law to do so; and
- for the purposes of providing you with products, services or information in accordance with your requests or reasonable expectations.
Use and Disclosure of Personal Information
The purposes for which Halberd Bastion uses your information will vary depending on the Halberd Bastion services and products you have applied for or use, and the relationship which you have with us. By providing your personal information to Halberd Bastion, you consent to our use of your personal information for any purpose which is related to the purpose for which such information has been provided to Halberd Bastion.
Your personal information may be disclosed to third parties for purposes related to the purposes for which your personal information was collected, with your consent or as authorised or required by law.
We may disclose your personal information to the following third parties (as distinct from the member of Halberd Bastion to whom you have provided your personal information):
- any member of Halberd Bastion or any of its affiliates worldwide;
- any third party service providers carrying out functions for or on behalf of Halberd Bastion or any of its affiliates worldwide;
- any person acting on your behalf including your solicitor, accountant, executor, administrator, trustee or guardian;
- government agencies, courts of law, tribunals or regulators (examples include in connection with a subpoena or order with which a member of Halberd Bastion must comply, or a regulatory investigation conducted by an Australian or New Zealand regulator of Halberd Bastion); and/or
- any other third party with your consent or where authorised or required by law.
Depending on the connection which a member or members of Halberd Bastion has/have with you, we may use and disclose your personal information for the purposes of:
- providing you with products, services or information in accordance with your requests or reasonable expectations;
- administering any accounts, you hold with Halberd Bastion or any of its affiliates worldwide;
- enabling Halberd Bastion or any of its affiliates worldwide to ascertain whether or not they have other services or products which may foreseeably meet your needs or may be of interest to you, and to notify you about these;
- the research, planning, product development, risk assessment, risk modelling and marketing conducted by Halberd Bastion or any of its affiliates worldwide;
- where you have not requested that any marketing communications sent to you, direct marketing of any products or services which Halberd Bastion decides may be of interest to you;
- identity verification and customer due diligence purposes;
- the prevention and detection of money laundering and terrorism financing;
- determining whether you have any history of defaulting on payment or delivery of products;
- background checking and verification in connection with recruitment;
- compliance with laws including but not limited to the Corporations Act 2001 (Cth), the Anti-Money Laundering and Counter Terrorism-Financing Act 2006 (Cth), the Proceeds of Crime Act 1987 (Cth), the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (New Zealand), and any associated Acts and Regulations enacted pursuant to those Acts named above;
- any other purpose to which you have consented; or
- disclosure where required or authorised by law.
Consequences If You Do Not Consent to the Collection or Use of Some or All Your Personal Information
Where you do not consent or do not provide the relevant member(s) of Halberd Bastion with some or all of your personal information, depending on your relationship with such member(s) and the products or services for which you are applying, Halberd Bastion may not be able to process your application or provide you with any of the requested products or services. Where such failure to provide personal information constitutes suspicious activity under relevant law, Halberd Bastion may be required to report such failure to the relevant authorities.
Transferring Your Information Outside Australia or New Zealand
Given the global nature of Halberd Bastion’s business, depending on the products or services being provided by Halberd Bastion to you, your information may be disclosed to third party service providers carrying out functions on behalf of Halberd Bastion or any of its affiliates worldwide or as required by law.
By providing us with your personal information, you acknowledge that the parties above may be located outside of Australia or New Zealand (as relevant to you), including in Singapore, Hong Kong and other countries in which Halberd Bastion has an office.
If we disclose your personal information outside Australia or New Zealand, we comply with transborder data ﬂow privacy standards under the relevant Privacy Act, for example, by taking reasonable steps to:
- ensure that the recipient does not breach the Australian Privacy Principles;
- protect the information being held, used or disclosed by the recipient; and
- ensure that the recipient is subject to substantially similar privacy laws as Australia or New Zealand (or where that recipient is not – that you have consented to such disclosure).
Employee Record Exemption
Use of the Halberd Bastion Website
Security of Your Personal Information
Halberd Bastion takes reasonable steps to preserve the security of personal information it collects. Personal information of clients, applicants and any other individuals are held in a secure environment in writing, electronically, or both. We have implemented security procedures, controls and protocols across all of our physical premises and electronic environments to ensure that personal information is protected from interference, loss, misuse, unauthorized access, modification, or disclosure. All stored client information is protected from unauthorised access through the use of secure passwords and user log ons or other security procedures.
Access and Updating of Information
Halberd Bastion takes reasonable steps to make sure that the personal information which we collect, use and disclose is accurate, complete and up-to-date.
You are able to make a request to access and update the personal information that we hold about you. Please provide us with as much detail as possible to assist us to retrieve the personal information which you have requested. In accordance with privacy laws a reasonable fee may be charged to cover our costs of providing access to you. To access or amend personal information that Halberd Bastion holds you should write to:
GPO Box 12345
or via email:
The Australia and New Zealand Privacy Officer will respond to your request within a reasonable period after your request is made and, if it is reasonable and practicable to do so, provide you with access to your personal information in the manner you requested.
Please be aware, in certain circumstances, Halberd Bastion may not be required to provide you with access to, or the ability to correct, your personal information. If such a decision is made, we will provide you with a written notice setting out our reasons and other available options for you.
How You Can Contact Us
If you have any questions or feedback about this statement or any complaints about our collection, storage or handling of your personal information, please contact the Privacy Officer in Australia in writing at any time by using the contact details set out above.
If you are located in Australia, where you have made a privacy-related complaint, we will respond to your complaint by no later than 45 days after receipt. If you are not satisfied with our response to your complaint or your concerns are not satisfactorily resolved, you may contact the independent statutory agency:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001