ALPINE CAPITAL PTY LTD PRIVACY POLICY

Alpine Capital Pty Ltd (ABN: 96 155 409 653) (Australian Financial Services Licence No: 422 477) understands the importance and takes the protection of personal information seriously. The information below explains how Alpine Capital Pty Ltd (referred to variously in this policy as “Alpine”, “Alpine Capital”, “we”, “our” or “us”) secures individual privacy, how it obtains information and how it uses this information to provide services and products.

Alpine Capital is safeguarding your personal information in accordance with the requirements of the national privacy principles of the Privacy Act 1988.

Securing Individual Privacy

Generally, Alpine Capital Pty Ltd will not disclose or use information collected about you otherwise than for the purposes set out in this policy, for a purpose required or permitted by law, or for a purpose otherwise disclosed to, or authorised by you.

Personal information is stored and held by a combination of hard and electronic client files maintained by Alpine Capital. Personal information is only accessible, on a need to know basis, by authorised representatives of Alpine Capital.

Alpine Capital Pty Ltd will take all reasonable steps to protect personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure by using industry standard software protection programs.

Alpine Capital will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.

Obtaining Information

Alpine only collects personal information by lawful and fair means and not in an unreasonably intrusive way. The types of personal information we collect generally includes:

  • name
  • date of birth
  • address
  • telephone number
  • email address
  • financial information (employment details, earnings and assets)
  • bank account details

Alpine’s primary source of collecting personal information is directly from you when you apply for a product or a service, deal with us as a key contact or employee of a client, deal with us over the telephone or in person, send us a letter or visit our website. On occasions, we may collect personal information about you from third parties, for example, share registries, ASIC or credit reporting agencies. Personal information is used by Alpine Capital for the purpose of conducting our business.

We may also need to collect personal and sensitive information in order to comply with our legal obligations, such as the Anti-Money Laundering and Counter-Terrorism Financing laws, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

How Information is used

Personal information is used by Alpine Capital Pty Ltd in order to implement our services to you so we can conduct our regular course of business. The use of the personal information includes but is not limited to:

  • determining your identity;
  • complying with legislative and regulatory requirements;
  • providing you with market updates that are connected with your investment;
  • updating you with potential investment opportunities;
  • inviting you to events that maybe of interest to you;
  • conducting research that ensures that we are providing you with an improved investor experience;
  • performing our administrative operations which includes record keeping, risk management analysis, system development and archiving.

Alpine may also need to collect personal and sensitive information in order to comply with our legal obligations, such as the Anti-Money Laundering and Counter-Terrorism Financing laws, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

Disclosure of Personal Information

Alpine may disclose personal information to its agents so they can provide services to the client. From time to time, Alpine might disclose personal information to third parties to assist us with our activities. The third parties may include:

  • share registry services;
  • debt collection agencies;
  • entities that are related bodies corporate to Alpine Capital Pty Ltd;
  • government and law enforcement agencies;
  • regulators;
  • those that provide Alpine Capital Pty Ltd with outsourced functions.

Alpine Capital will disclose your personal information if one of the below applies:

  • Alpine Capital is authorised or required to do so by law;
  • Disclosure is necessary for a law enforcement related activity;
  • By your personal consent;
  • Where you would reasonably expect Alpine Capital Pty Ltd to use or disclose your personal information in this way;
  • Disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety.

In some cases, Alpine Capital may need to transfer your personal information outside Australia. If Alpine Capital believes that the overseas third party is not subject to, or has not agreed to comply with, privacy obligations equivalent to those which apply to us, we will seek your consent to transfer the information, except where the national privacy principles do not require us to do so.

Alpine Capital Pty Ltd Website

Alpine Capital Pty Ltd compliance with the national privacy principles also extends to when you transact business via our website.

When you use a link from the Alpine Capital Pty Ltd website to the websites of third parties, those websites are not subject to Alpine Capital privacy standards. Those third parties are responsible for informing you of their own privacy policies.

Contact Us

If at any time you wish to know what personal information that Alpine Capital Pty Ltd is holding about you, you are welcome to ask us for your details by writing to us in a form or manner which identifies the nature of the personal information requested. The appropriate contact is:

Under certain circumstances Alpine Capital may not be able to tell you about the personal information that we hold about you: These circumstances include but not limited to:

  • If the information relates to a legal proceeding;
  • The information would have an unreasonable impact on the privacy of another individual;
  • The information would reveal a commercially sensitive decision-making process; or
  • would legally prevent Alpine Capital Pty Ltd from disclosing the information, or providing access which would prejudice certain investigations.

Alpine Capital will take reasonable steps to ensure that your personal information is accurate, complete and up to date.

If at any time, you find that current personal information we hold about you is inaccurate, incomplete or out of date, please contact Alpine Capital Pty Ltd and they will correct it.

If at any time you do not wish to receive such marketing information, you have the option to ask Alpine Capital Pty Ltd not to send you any further such material – you may do so by contacting Alpine Capital at info@alpinecapital.au.

Updates

Please note that this policy may change from time to time due to business or law change requirements. Alpine Capital will review its Privacy Policy on a regular basis and update it as required.