Privacy Policy

Commitment to Privacy
Harbour FX Pty Ltd trading as Harbour Investment Partners (HIP) is committed to safeguarding the privacy of wholesale clients, investors, and institutions. This Privacy Policy explains how we collect, use, store, and share your personal information in accordance with the Privacy Act 1988 (Cth) and related Australian privacy regulations.

Collection of Personal Information
We collect personal information from a variety of sources, including:

  • Directly from You: When you interact with us, apply for services, or communicate with our team.
  • Public Registers and Administration: Government bodies and publicly available sources.
  • Third Parties: Wealth screening services, credit agencies, financial advisers, and other service providers.

When third parties provide your personal information, we assume your consent unless you explicitly state otherwise.

Privacy Law Compliance
For institutional or corporate clients, we may collect personal information about directors, representatives, employees, shareholders, and beneficial owners. You are responsible for sharing this Privacy Policy with those individuals before providing their information to us.

Types of Credit Information Collected
HIP and its affiliates may collect, use, and disclose credit information as defined under the Privacy Act, including:

  • Identification Details: Name, date of birth, gender, addresses, employment details, and driver’s licence number.
  • Credit Applications: Amount and type of credit applied for.
  • Credit Providers: Details of current and previous providers, credit limits, and repayment history.
  • Requests to Credit Agencies: Records of enquiries made about you.
  • Default Information: Overdue payments, payment arrangements, and court judgments.
  • Sensitive Information: Health data, membership details, or other sensitive information collected with your consent.
  • Derived Data: Credit scores and ratings obtained from credit reporting bodies.

We may obtain credit information from credit reporting bodies, financial advisers, and fund managers. By providing your personal information, you consent to its collection and use as outlined in this policy.

Purpose of Processing Personal Information
We process personal information for the following purposes:

  • Client Onboarding: Identity verification, anti-money laundering checks, and fraud prevention.
  • Relationship Management: Managing interactions, handling queries, and understanding client preferences.
  • Service Delivery: Implementing and executing financial products and services.
  • Business Development: Evaluating new services, direct marketing, and promotional activities.
  • Compliance: Meeting legal obligations, handling complaints, and crime prevention.
  • Technology Enhancement: Improving systems, conducting research, and testing new services.
  • Operational Management: Ensuring security, facilitating mergers, and undertaking analysis.

Use of Credit Information
HIP uses credit information to:

  • Assess creditworthiness and applications.
  • Provide relevant services and products.
  • Meet legal and regulatory obligations.
  • Failure to provide requested information may result in our inability to offer certain services.

Protecting Personal Information
HIP implements stringent technical and organisational measures to protect personal information from unauthorised access, loss, or misuse. Our employees adhere to strict confidentiality protocols and data security policies.

Sharing Personal Information

Within HIP:
We share personal information within HIP entities to ensure consistent service delivery.

Third Parties:
We may share information with:

  • Credit providers, insurers, and financial institutions.
  • Professional advisers (lawyers, auditors, consultants).
  • Payment providers and credit card networks.
  • Introducing brokers and fund managers.
  • Credit reporting agencies, such as Equifax Australia.

Service Providers:
External suppliers, including IT providers, logistics firms, and marketing agencies, may access personal information under strict confidentiality agreements.

Public Authorities:
We may disclose information to regulators, government bodies, and courts as required by law.

Credit Reporting Bodies
HIP engages credit reporting bodies to assess credit eligibility. These bodies may include your information in reports to other credit providers. You can opt out of pre-screening services or request protection if you believe you are a victim of fraud. For more information, refer to the credit reporting body’s privacy policy.

Data Transfers
Your personal information may be transferred and processed outside Australia. We ensure such transfers comply with applicable data protection regulations and implement necessary safeguards.

Data Retention
We retain personal information for as long as necessary to fulfil the purpose for which it was collected or to meet legal and regulatory obligations. Data retention periods are determined based on compliance requirements, risk management, and operational needs. Personal information is securely stored, and you may request its deletion, subject to legal limitations.

Your Rights
You have the right to:

  • Access your personal information.
  • Correct inaccurate or outdated data.
  • Complain about the handling of your information.

Contact Details:

We aim to respond within 30 days. If unresolved, you can contact the Australian Financial Complaints Authority (AFCA):

  • Website: www.afca.org.au
  • Email: info@afca.org.au
  • Phone: 1800 931 678 (free call)
  • Mail: GPO Box 3, Melbourne VIC 3001

You may also escalate concerns to the Office of the Australian Information Commissioner (OAIC):

  • Website: www.oaic.gov.au
  • Phone: 1300 363 992
  • Mail: GPO Box 5218, Sydney NSW 2001

Changes to Personal Information
To ensure accuracy, please notify us promptly of any changes to your personal details.

Updates to This Policy
This Privacy Policy was last updated in January 2025. We reserve the right to update it periodically. Please check our website for the latest version. For any queries, contact compliance@harbourinvestmentpartners.com.au.

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