Introduction

JF Capital Partners Ltd (“JFCP”) recognises the importance of the personal information we hold about individuals and the trust they place in us.

By explaining our Privacy Policy to you, we hope that you will better understand how we keep personal information private and secure while using it to provide services and products. "Personal information" for the purposes of this Policy is information about and which identifies individuals, whether that information is obtained from the relevant individual or from a third party.

We are committed to safeguarding your personal information in accordance with the requirements of the National Privacy Principles of the Privacy Act 1988.

In general, we will not use or disclose such information collected about you otherwise than for the purposes set out in this Policy, for a purpose you would reasonably expect, a purpose required or permitted by law, or a purpose otherwise disclosed to, or authorised by, you.

We may, in connection with particular services we offer or provide to you, make other privacy disclosures to you or seek your authority to use your personal information in ways which are different from or more specific than those stated in this Privacy Policy. In the event of any inconsistency between the provisions of this Privacy Policy and those additional materials, the provisions of the additional materials will prevail.

Personal information collected before 21 December 2001

The National Privacy Principles came into force on 21 December 2001 but some of the Principles have application to personal information collected prior to as well as after that date. This means that for personal information we hold, which was collected prior to that date, we will, in accordance with those particular Principles:

• take reasonable steps to ensure that such information, if used, is accurate, complete and up to date;
• take reasonable steps to protect it from misuse, loss or unauthorised access or disclosure;
• provide you with access to the information if we still use it;
• not use any government identifier to identify you; and
• only transfer such information overseas with your consent or as authorised by the Principles.

Except in so far as this Privacy Policy further addresses the particular Principles reflected in those five matters, the remainder of this document is concerned with personal information which is collected on or after 21 December 2001.

Collection of personal information

JFCP will collect personal information that it believes is necessary for us to deliver our services or products or otherwise for our primary business functions and/or activities.
Ordinarily we will only collect information about you when you provide it to us or it is provided to us with your authority.

JFCP will only collect personal information by lawful and fair means and not in an unreasonably intrusive way. The types of personal information we collect generally includes your name, address, telephone number, email address, financial information and other contact or identification details and, in some cases, information necessary to make or receive payments to or from you or necessary to effect security transactions on your behalf.

In certain circumstances, we may also collect personal information, which is sensitive. Sensitive information includes information about health, religious or philosophical beliefs, membership of professional or trade associations or a criminal record. Unless the collection of sensitive information is required or permitted by or under law, we will obtain your consent to its collection.

We will collect personal information directly from you when you apply for a product or a service, deal with us as a key contact or employee of an institutional client, deal with us over the telephone or in person, send us a letter or visit our website, www.jfcp.com.au. On occasions, we may need to collect personal information about you from third parties.

Apart from the necessity to collect your information in order to provide a service to you or maintain our relationship with you, the purposes for which we would generally collect and use your personal information will include:

• complying with legislative and regulative requirements;
• performing our administrative operations, including accounting, risk management, record keeping, archiving, systems development and testing and staff training;
• managing our rights and obligations in relation to external payments systems;
• conducting market or customer satisfaction research;
• inviting you to other events that may interest you;
• developing and identifying products and services that may interest you; and
• (unless you ask us not to) telling you about other products and services we offer.

Personal information about third parties

If at any time you supply us with personal information about another person, you should ensure that you are authorised to do so and you must agree to inform that person who we are, that we will use and disclose that personal information and that they may gain access to it should we hold that information.

Use and disclosure of personal information

You authorise JFCP to disclose necessary information to related companies, affiliates, and any agents or contractors who provide services to us in connection with the provision of products or services you have sought from us. These parties are prohibited from using your personal information except for the specific purpose for which we supply it to them.

Subject to what is permitted by law, the types of third parties we may disclose your personal information to include:

• our agents, contractors, insurers and external advisers we engage from time to time to carry out, or advise on our functions and activities;
• any person or organisation who introduces you to us;
• regulatory bodies, government agencies, law enforcement bodies and courts;
• external payment systems operators;
• debt collection agencies;
• other financial institutions; and
• any person to the extent necessary, in our view, in order to carry out the instructions you give to us.

In some cases, we may need to transfer your personal information outside Australia. If we believe 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.

JFCP’s internet website

Our compliance with the National Privacy Principles also extends to when you transact business via our website. Our website terms of use and any privacy notices are clearly posted on all pages of the website.

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

For statistical purposes we collect information on website activity (such as the number of users who visit the website, their country, the date and time of visits, the number of pages viewed, navigation patterns and the operating systems and browsers used to access the site). This information on its own does not identify an individual but it does provide us with statistics that we can use to analyse and improve our website.

When you use our website, we send you a temporary cookie. A ‘cookie’ is a packet of information that allows the server to identify and interact more effectively with your computer, that gives you a unique identification number. This identification number is sent each time you use our website. Cookies do not identify individual users, although they do identify a user’s browser type and your Internet Service Provider. You can configure your browser to accept all cookies, reject all cookies, or to notify you when a cookie is sent. However, if you do not accept cookies, you may not be able to make full use of the JFCP website. At the end of your interaction with our website, the cookie no longer exists and it cannot be used for further identification or access to your computer.

Access to your personal information

If at any time you wish to know what personal information we are 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:

Privacy Officer
JF Capital Partners Ltd
Level 23
600 Bourke Street
Melbourne
VIC 3000

Under certain circumstances, we may not be able to tell you what personal information we hold about you. This includes where:
• it would have an unreasonable impact on the privacy of another individual;
• information relates to legal proceedings with you;
• the information would reveal a commercially sensitive decision-making process; or
• we are prevented by law from disclosing the information, or providing access would prejudice certain investigations.

We may charge a fee for accessing your personal information.

We 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 JFCP’s Privacy Officer immediately and we will correct it.

Security of your personal information

JFCP will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure. In line with our internal authorisation and access polices, employees only have access to information on a need to know basis.

JFCP will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used and disclosed under this Policy.

No data transmission over the internet can be guaranteed as fully secure and we cannot guarantee or warrant the security of any information you send to us over the internet. You submit information over the internet at your own risk.

Direct marketing

We may use your personal details, including your address, to provide you with newsletters and information about products, services or other events that may be of interest to you.

If at any time you do not wish to receive such marketing information, you have the option to ask us not to send you any further such material and you may do so by writing to our Privacy Officer.

Identifiers

JFCP will not adopt as its own identifier an identifier that has been previously assigned by a government agency (or by an agent of, or contractor to, a government agency or contracted service provider for a Commonwealth contract). We will only use and disclose such identifiers for purposes required by law.

Complaints

If you believe that the privacy of your personal information is not being adequately protected, you should contact our Privacy Officer. We will make every effort to resolve your complaint internally.

If we do not resolve your complaint to your satisfaction, you may apply to the Federal Privacy Commissioner to have your complaint investigated. For more information about how you may lodge a complaint with the Federal Privacy Commissioner, please contact the Commissioner's hot line service on 1300 363 992.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. You may at any time request a current copy from our Privacy Officer or access it from our website, www.jfcp.com.au. We encourage you to review our Privacy Policy periodically for any changes.

Need more Information?

If you have a query concerning how your personal information is collected and used or in relation to JFCP’s Privacy Policy, contact our Privacy Officer. Additional information, including the National Privacy Principles, may be found on the Federal Privacy Commissioner’s website on www.privacy.com.au.