Kanberry

Privacy policy

1. INTRODUCTION

Kanberry Pty. Ltd. ABN 85 642 154 809 (referred to as ‘we’, ‘our’, ‘us’) is bound by the Privacy Act 1988  (Privacy Act), including the Australian Privacy Principles and recognises the importance of ensuring the confidentiality and security of personal information, related to key persons, associated with CustomersIn this Policy:

 

(a) ‘Disclosing’ information means providing information to persons outside of us

 

(b) ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual

 

(c) ‘Customer’ means a body corporate (legal entity) that established contractual relations with Kanberry in relation to services rendered by Kanberry

 

(d) ‘Key personnel’ refers to all personnel, performing key roles within Customer business and corporate governance: Ultimate Beneficial Owners, Shareholders, Directors, Compliance Officer, Signatory and other persons who essentially influence Customer business on benefits from it

 

(e) ‘Sensitive information’ is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union 

or other professional or trade association membership, sexual preferences and criminal record, and also includes health information

 

This Policy is applied for exclusive purposes to collect necessary information about Customer’s Key Personnel in order to comply with Kanberry AML Policy and requirements of Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (“AML/CTF Act”)’s and the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No.1) (“Rules”). The information collected will be used for identification and verification only. All other than above purposes are strictly limited by Kanberry internal procedures and rules.

2. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?

We may collect and hold a range of information about Key Personnel to provide Customers with our services, including:

 

(a) Key Personnel full names, contact details, dates of birth, email addresses, phone numbers, employment details, photographic identifications, bills

 

(b) Information about Key Personnel banking details and account numbers

3. HOW DO WE COLLECT PERSONAL INFORMATION?

We generally collect personal information directly from Customer representative. Personal information will be collected through our application processes, forms and other interactions with the Customer in the course of providing Customers with our products and services. We may also collect personal information about Customers from publicly available sources.


We will not collect sensitive information about Key Personnel without their consent unless an exemption in the Australian Privacy Principles applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.


We note that Customers are not required to provide us with Key Personnel personal information. However, if Customers do not provide us with the personal information we request, we may not be able to provide you with our services.

4. UNSOLICITED PERSONAL INFORMATION

We may receive unsolicited personal information about Key Personnel. We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to our purposes for collecting personal information. We may retain additional information we receive about Key Personnel if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.

5. WHY DO WE COLLECT PERSONAL INFORMATION?

We collect and hold personal information about Key Personnel so that we may:

 

(a) Allow Customer to open and operate an account and render services to Customers

 

(b) Correspond with the Customer and relevant Customer representatives in relation to Customer Account and Transactions

 

(c) Comply with relevant laws, regulations and other legal obligations

 

We may use and disclose Key Personnel personal information for any of these purposes. We may also use and disclose such personal information for secondary purposes in other than above circumstances authorised by the Privacy Act. 

Sensitive information will be used and disclosed only in case that an exemption in the Privacy Act applies.

6. WHO DO WE DISCLOSE PERSONAL INFORMATION TO?

We may disclose personal information to:

 

(a) Contractors or service providers for the purposes of operation of our platform or our business

 

(b) Organisations involved in the case of a merger, divestiture, or other corporate re-organisation or sale

 

(c) Financial institutions as required for the purposes of our dealings with those institutions, such as banks

 

(d) Regulatory bodies, government agencies, law enforcement bodies and courts

 

(e) Any financial dispute resolution scheme to which we subscribe, and

 

(f) Anyone whom the Customer authorises us to disclose it, for example nominated advisors.

 

If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy.

7. SENDING INFORMATION OVERSEAS

We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above.


We take reasonable steps to ensure that the overseas recipients of Key Personnel personal information do not breach the privacy obligations relating to their personal information.


We may disclose Key Personnel personal information to entities located outside Australia.

8. MANAGEMENT OF PERSONAL INFORMATION

We will take steps to ensure Key Personnel personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.

 

Key Personnel personal information is generally stored in our computer database. Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:

 

(a) Passwords are required to access the system

 

(b) Employees have restricted access to certain sections of the system. Unauthorised employees are barred from updating and editing personal information

 

(c) All computers which contain personal information are secured both physically and electronically

 

(d) Data is encrypted during transmission over the network, and

 

(e) Print reporting of data containing personal information is limited.

9. IDENTIFIERS

We do not adopt identifiers assigned by the Government (such as driver’s licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies. 

10. MAINTAINING OF PERSONAL INFORMATION

We are committed to ensuring that the personal information we collect, hold, use and disclose is relevant, accurate, complete and up-to-date. 

We encourage Customers to contact us if any personal information we hold about Key Personnel needs to be updated. If we correct information that has previously been disclosed to another entity, we will notify the other entity of the correction within a reasonable period. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless Customers agree otherwise.

11. ACCESSING YOUR PERSONAL INFORMATION

Subject to exceptions in the Privacy Act and law, Customer can access the personal information that we hold about Key Personnel by contacting us at the Contact details. We will generally provide access within 30 days of Customer request. If we refuse to provide the Customer with access to the information, we will provide reasons for the refusal.

 

We will require identity verification and specification of what information is required.

12. UPDATES TO THIS POLICY

This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.

13. MAKING A COMPLAINT

    • Writing to U3 85 Palmer Street, Balmain, 2041, NSW or
    • Online, by raising a new support request at Kanberry Support