1. Privacy generally
This policy (Policy) applies to the handling of personal information by Alluvial Wealth Pty Ltd ACN 139 507 618 trading as International Commodities House (Alluvial Wealth, we, us, our).
Alluvial Wealth understands the importance of protecting the privacy of an individual’s personal information.
This Policy sets out how Alluvial Wealth aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Alluvial Wealth and how Alluvial Wealth collects, holds, uses, discloses and otherwise manages your personal information.
In collecting, holding, using, disclosing and otherwise managing your personal information, Alluvial Wealth will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.
Alluvial Wealth will regularly review its policies regarding personal information and may therefore update and amend this Policy from time to time. Any updated Policy will be made available on the website www.int-ch.com or otherwise on request.
2. Kinds of personal information collected
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its products and services, Alluvial Wealth may collect your personal information.
Generally, the kinds of personal information Alluvial Wealth collects are:
- contact and identification information such as your name, address, telephone number, email address and date of birth;
- information regarding your purchasing or trading history with Alluvial Wealth or your other dealings with Alluvial Wealth;
- where Alluvial Wealth provides you with fuel card products or services, the registration number, colour, model and make of the vehicle linked to your fuel card and the PIN assigned to your fuel card;
- your bank details, including your account name, number and BSB; and
- details regarding the transactions you undertake using Alluvial Wealth’s products, services or platforms.
Alluvial Wealth may also collect other kinds of personal information about you, for example where Alluvial Wealth is required to collect certain kinds of personal information about you for Alluvial Wealth to undertake identification and verification processes in accordance with the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) or any other relevant laws
3. Collection of personal information by Alluvial Wealth
Generally, Alluvial Wealth collects your personal information directly from you.
For example, Alluvial Wealth may collect personal information directly from you:
- when you register with us, request information from us or otherwise provide us with your personal details (such as your name, contact details, e-mail address etc) to us;
- where you purchase or order products or services from us; or
- as a result of your use of our websites or other online services or your other interactions with us.
There may be occasions when Alluvial Wealth collects your personal information from other sources, such as from:
- your employer, where necessary for Alluvial Wealth to deal with you in relation to Alluvial Wealth providing its products or services to your employer;
- an information services provider, such as an identity verification services provider; or
- a publicly maintained record or other publicly available sources of information.
Generally, Alluvial Wealth will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you or if you have consented to the collection.
4. Purposes for which personal information is used
Alluvial Wealth collects, holds, uses and discloses your personal information to:
- enable us to provide you with information which you have requested (for example where you request information regarding our gold bullion products and services, fuel card products and services or other products or services);
- process, administer and fulfil orders or other requests you place in respect of our products or services;
- supply our products and services to you;
- administer any commercial arrangement you have in place with Alluvial Wealth from time to time;
- analyse the information we collect so that we can administer, support and improve and develop our business and the products and services we offer;
- contact you for your views on our products and services;
- comply with the obligations of Alluvial Wealth under any applicable laws; and
- for all other purposes consistent with the proper performance of our operations and business.
In addition, Alluvial Wealth may use and disclose your personal information in order to inform you of products and services that may be of interest to you. This may include Alluvial Wealth disclosing your personal information to related bodies corporate of Alluvial Wealth or other entities with which Alluvial Wealth has a commercial relationship or arrangement for the purpose of such other entities contacting you regarding offers or information (which may include offers or information about the products or services of the entity). In the event you do not wish to receive such communications, you can opt-out by contacting Alluvial Wealth via the contact details set out in paragraph 9 or through any opt-out mechanism contained in a marketing communication to you.
We may contact you by means including post, telephone or e-mail. If you change your mind about being contacted in the future by any of these means then please let us know.
Alluvial Wealth may also use your personal information for purposes related to the above purposes and for which you would reasonably expect Alluvial Wealth to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law.
Where personal information is used or disclosed, Alluvial Wealth takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Alluvial Wealth. However, without certain information from you, Alluvial Wealth may not be able to provide its products and/or services to you.
5. Disclosure collection and use of personal information
Alluvial Wealth discloses your personal information for the purpose for which Alluvial Wealth collects it. As a result, generally Alluvial Wealth will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to:
- third parties engaged to perform administrative or other business management functions;
- suppliers of products or services to Alluvial Wealth relevant to the products or services your order from Alluvial Wealth (for example, suppliers of gold bullion and fuel card administration services to Alluvial Wealth);
- people or entities considering acquiring an interest in Alluvial Wealth’s enterprise or assets;
- Alluvial Wealth’s professional advisors, contractors and consultants;
- Alluvial Wealth’s insurance providers; and
- government agencies and regulatory authorities where Alluvial Wealth is required or authorised to do so by law.
Alluvial Wealth may also disclose your personal information for other purposes with your consent or for any purposes if the disclosure is required or authorised by law.
Alluvial Wealth’s disclosures of your personal information to third parties are on a confidential basis or otherwise in accordance with law. Alluvial Wealth may also disclose your personal information with your consent or if disclosure is required or authorised by law.
6. Overseas disclosures
Alluvial Wealth may disclose personal information to overseas recipients, for example to data storage providers located overseas or to related bodies corporate Alluvial Wealth located overseas.
7. Security of personal information
Alluvial Wealth takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. Alluvial Wealth holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.
Alluvial Wealth will destroy or de-identify personal information in circumstances where it is no longer required, unless Alluvial Wealth is otherwise required or authorised by law to retain the information.
8. Access and correction
Alluvial Wealth takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.
Under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Alluvial Wealth. If at any time you would like to access or correct the personal information that Alluvial Wealth holds about you, please contact Alluvial Wealth’ Privacy Compliance Officer on the details set out in paragraph 9 below. Alluvial Wealth will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you may be asked to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- Alluvial Wealth requests that you be reasonably specific about the information you require; and
- Alluvial Wealth may charge you a reasonable administration fee, which reflects and will not exceed the cost to Alluvial Wealth for providing access in accordance with your request.
Alluvial Wealth will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If Alluvial Wealth refuses your request to access or correct your personal information, Alluvial Wealth will provide you with written reasons for the refusal and details of complaint mechanisms. Alluvial Wealth will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of Alluvial Wealth.
If you are dissatisfied with Alluvial Wealth’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.
9. Contacting Alluvial Wealth
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact Alluvial Wealth’s Privacy Compliance Officer on +61 2 8035 4407, by email on email@example.com or by post to GPO Box 7063 Sydney, 2001 NSW Australia.
10. Privacy complaints
If you believe that Alluvial Wealth have not dealt with your personal information in a manner that complies with the Privacy Act or the Australian Privacy Principles or have any other complaint regarding how Alluvial Wealth has dealt with your personal information, you can make a privacy complaint to Alluvial Wealth.
Please direct all privacy complaints to Alluvial Wealth’s Privacy Compliance Officer. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and Alluvial Wealth.
Alluvial Wealth’s Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Alluvial Wealth will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.