Reginsun Group Privacy Policy
This is the Privacy Policy of Reginsun Credit Pty Ltd (ACN 165 224 055, ABN 26 165 224 055) (Reginsun Credit) and Reginsun Funds Pty Ltd (ACN 165 224 224, ABN 66 165 224 224) (Reginsun Funds) (collectively, the Reginsun Entities). The Reginsun Entities (we, us or our) operate the website www.reginsun.com.
This Privacy Policy applies to Reginsun Credit in its capacity as an Australian Credit Licence holder (ACL 445579) when providing credit arranging and assisting services and consultations and to Reginsun Funds, in its capacity as an Australian Financial Services Licence Holder (AFSL 448540) as the trustee, custodian, administrator or investment manager of various trusts and other investments to which Reginsun Funds is a service provider as well as in its personal capacity.
Your Privacy
Your privacy is important to us and we are committed to managing your personal information responsibly and in accordance with our legal obligations including the requirements of the Privacy Act 1988 (Cth) (Privacy Act) and with the Australian Privacy Principles. These laws and principles regulate, among other things, the way we collect, use, disclose, keep secure, and give you access to your personal information.
This Privacy Policy sets out the type of information we collect and how we collect, store, use and disclose your personal information. We recommend that you read it carefully.
While you are not required to provide us with your personal information and where lawful and practicable, you may deal anonymously with us, given the nature of our products and services, it is unlikely that this will be a viable option. Therefore, if you do not provide us with your personal information, we may not be able to provide you with the full functionality of our products or services.
If you apply for or accept any of our products or services or otherwise provide us with your personal information, you agree to your information being collected, held, used and disclosed as set out in this Privacy Policy. We may revise this Privacy Policy from time to time by placing the revised Privacy Policy on our website or otherwise notifying you of the change.
What kind of information do we collect?
In order to provide our products and services to you, without limitation, we may collect the following personal information from you:
your full name, date of birth, gender and contact details including telephone, address, e-mail, fax number and social media handle (as applicable);
financial information about you in order to support an application for credit from a lender;
a copy of your driver licence and/or passport or other identification documentation for the purpose of verifying identity and to ensure compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and/or other legislation and regulations regarding identification verification, and tax reporting and withholding, including without limitation the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS);
your tax file number (TFN), bank account details and other payment details (as applicable);
details about authorised signatories on your investments or accounts with us;
detailed contact information about your financial adviser; and
copies of any relevant trust deeds, partnership agreements or constitutions (including information about trustees and beneficiaries of relevant trusts and shareholders of companies and partners of partnerships), which may be relevant to comply with the AML/CTF Act, the FATCA and the CRS.
It may, on occasion also be necessary to obtain other details, including information relating to powers of attorney or for probate and estate administration.
How do we collect and hold personal information?
We may collect your personal information in various ways including by telephone, our website, from documents or correspondence and by email. Wherever practicable, we will collect information about you from you personally.
However, it may be necessary at times to collect information about you from other external sources, such as:
a financial adviser or broker;
authorised representatives, such as executors or administrators; and
identification verification service providers.
If you use our website, our web server (i.e. the computers that house our website) has the capacity to collect the following types of information for statistical purposes:
the number of users who visit the website;
the number of pages viewed; and
traffic patterns.
This is anonymous statistical data and no attempt is made to identify users or their browsing activities. This data is used only to evaluate our website performance and to improve the content we display to you.
Cookies
Other information, such as browser type, may be included in a ‘cookie’ that is sent to your computer when you complete certain tasks on our website. A cookie contains bits of information that enables our servers to identify and interact efficiently with your computer. Cookies are designed to provide a better, more customised website experience, and to make it easier for you to use our website. You can configure your computer to accept or reject cookies.
Sensitive Information
We will only collect sensitive information about you with your consent and when it is reasonably necessary for our functions or activities, in accordance with the Privacy Act. If sensitive information (including health information) is provided by you to us, then we will ensure we hold, disclose and store your sensitive information in accordance with applicable privacy laws and regulations relating to sensitive information.
Anonymity and Pseudonymity
Wherever lawful and practicable, you may deal anonymously with us, however, given the nature of our products and services, it is unlikely that this will be a viable option.
We do not use official government related identifiers (e.g. tax file numbers) to identify individuals.
Local Data Centres
We process your personal information at our Australian data centres where your personal information is encrypted, securely stored and processed for the provision of our products and services. We do not use offshore data centres.
Security
The security of your personal information is important to us. All personal information we collect will be held securely and in accordance with this Privacy Policy. We take reasonable steps and implement appropriate safeguards to protect your personal information from loss, misuse, interference, unauthorised access, modification or disclosure. Your information is protected from unauthorised access through the use of secure passwords, user logins and other security procedures. Developments in security and encryption technology are reviewed regularly.
We take this opportunity to advise you that the internet is an insecure medium. If you use the internet to communicate with us, you should be aware that there are inherent risks in transmitting information over the internet. We do not have control over information while in transit over the internet or held in a method of electronic storage and thus, we cannot guarantee its security.
Where information is no longer required to be held or retained by us for any purpose or legal obligation, we will take all reasonable steps to destroy or de-identify the personal information accordingly within a reasonable timeframe. Where it is not practicable/possible for us to destroy or de-identify the personal information, we will securely store the information and isolate it from any further use until it can be deleted. We strive to use commercially acceptable means to protect your personal information.
Unsolicited personal information
Where we receive personal information about an individual which is unsolicited by us and not required for the provision of our products or services, we will destroy the information (provided to the extent it is lawful and reasonable for us to do so).
Links to other sites
Our website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the privacy statement/policy of every site you visit.
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
For what purpose do we use personal information?
Generally, we only use and disclose information for the purpose for which it was disclosed to us or related purposes which would reasonably be expected during the provision of our products or services.
We may use your personal information for providing and improving our products and services. By using our products and services, you agree to the collection and use of information in accordance with this Privacy Policy. The purpose for which we collect personal information is to provide you with the best service experience practicable and for our internal business purposes that form part of normal business practices. A primary purpose may include (without limitation):
to enable us to provide information to credit providers;
to establish and administer your investment or account and your relationship with us;
for communication purposes which may include surveys and questionnaires;
to comply with our record-keeping, reporting and tax obligations;
to protect legal rights and comply with legal obligations;
to prevent fraud and abuse;
for quality assurance and training purposes;
to enable us to provide information about new and existing products and services that will enhance our relationship with you. However, we do respect the right of individuals to ask us not to do this; and
to handle any relevant enquiries or complaints.
In certain cases, we will use or disclose personal information for secondary purposes (in addition to the primary purpose). Personal information obtained to provide our products and services may be applied for a secondary purpose if the secondary purpose is related to the primary purpose and it is reasonable to expect the personal information to be used or disclosed for such secondary purpose.
For instance, in order to meet our clients’ and our investors’ needs it may be necessary to release information or provide access to external service providers, which may include (without limitation):
to any organisations involved in providing, managing or administering our products systems or services such as lenders, custodians, registries, administrators, mail houses and software and information technology providers;
to auditors, consultants and other professional advisers;
to your financial adviser;
to a legal personal representative, attorney or any other person who may be entitled to receive the proceeds from your investment or account with us;
to other financial institutions who hold an account in an investor’s name, for example, where amounts have been transferred to or from that account; and
to authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to an investment or account.
We may also be required by law to disclose personal information. For instance, we may be required to provide details to:
Australian Government regulators such as the Australian Securities and Investments Commission, the Australian Tax Office, the Australian Transaction Reports and Analysis Centre and to other regulatory or government entities;
as required by a court order (including in Family Law matters); and
other regulatory or governmental entities outside of Australia.
We do not sell, trade or rent client lists or personal information to any third party. If you are a potential customer in respect of a credit product or service, we will disclose personal information about you to our credit providers and agents where it relates to our credit assistance. This may also include information we obtain about your credit rating from credit reporting agencies. In all cases, we will only disclose that information that is strictly required, and take all reasonable steps to ensure that your personal information is handled in accordance with the Australian Privacy Principles and applicable privacy laws and regulations. Otherwise, we will not disclose personal information unless you consent, we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.
Behavioural remarketing
We may use remarketing services to advertise on third-party websites to you after you have visited our website. We, and our third-party vendors, may use cookies to inform, optimise and serve ads based on your past visits to our website.
Google AdWords Remarketing and Google Display Network are provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy and Terms web page: http://www.google.com/intl/en/policies/privacy/.
Facebook and Instagram
Facebook and Instagram remarketing services are provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/about/ads/#568137493302217.
Facebook adheres the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.
Can you access and amend your personal information?
You may request access to any personal information we hold about you. We will not charge you a fee for your access request. Please contact us and we will seek to provide such information within a reasonable period, and in the manner so requested where reasonable to do so.
Your right to access is subject to some exceptions allowed by law. We will notify you of the basis for any denial of access to your personal information, together with details of our complaints process if you wish to challenge the decision.
We will correct your personal information where:
we believe personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading; or
you request us to correct personal information held about you.
Please contact us if you wish to correct your personal information. We will take all reasonable steps to correct such information in a reasonable time frame. No fees are payable for such requests. If you request us to similarly advise a relevant third party of such correction, we will facilitate that notification unless impracticable or unlawful for us to do so.
If we refuse to comply with your correction request, we will notify you in writing of our reasons for such refusal, and the complaints process you may access if you wish to challenge that decision.
Please note that the access and correction requirements under this Privacy Policy operate alongside and do not replace other informal or legal procedures by which an individual can be provided access to, or correction of, their personal information, including the requirements under the Freedom of Information Act 1982 (Cth).
Communications
We may use your personal information obtained for the provision of our products and services to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you (e.g., new lending products and services).
We will only use your personal information for the secondary purpose of direct marketing where:
we have collected your personal information;
you would have reasonably expected us to use or disclose the information for the purpose of direct marketing;
we provide a simple means through which you can request to not receive marketing communications; and
you have not requested that such communications cease.
For example, your email address will not be added to a mailing list without your consent unless the mailing list is related to the purpose(s) (as described in this document) for which you provided your email address to us. However, if through using our products and services you provide your email address to us so that we may communicate with you through email, we may also use your email address to advise you of offers, upgrades and changes to our products and services. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Children’s Privacy
Our service does not address anyone under the age of 18.
We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us. If we become aware that we have collected personal information from children under 18 without verification of parental consent, we will take steps to remove that information from our servers or replace it with the personal information of the child’s parent or guardian.
Can you complain?
Yes. If you have a complaint about a breach of this Privacy Policy including the manner in which we have collected, held, used, disclosed, kept, or given people access to your personal information, then you may make a complaint to us using the contact details in this Privacy Policy (see Contact Us section below). You will need to provide us with sufficient details regarding your complaint and any supporting evidence.
Your complaint will be referred to our Responsible Managers who will investigate the issue and determine the steps we will take to resolve your complaint. We may ask you to provide additional information.
We will notify you in writing of our determination, generally within 30 days. If you are not satisfied with our determination or you do not receive a response within 30 days, you can contact us to discuss your concerns and you can refer the complaint to the Office of the Australian Information Commissioner (see www.oaic.gov.au).
Will your information be sent overseas?
We do not anticipate that we will need to disclose information to overseas recipients.
Business transaction
If we sell or buy businesses or their assets, or engage in transfers, acquisitions, mergers, restructurings, changes of control and other similar transactions, customer or user information is generally one of the transferable business assets. Thus, your personal information may be subject to such a transfer and you consent to your personal information being transferred on a confidential basis in connection with a proposed transfer or restructure or similar transaction. In the unlikely event of insolvency, personal information may be transferred to a trustee or debtor in possession and then to a subsequent purchaser and you also consent to such transfer in such circumstances.
Consent
You warrant that you are able to give consents under Australian Law or, in the event that you do not have the capacity to give consent, you warrant that your guardian or attorney is able to give any consent required under this Privacy Policy on your behalf.
By providing information to us in connection with our products and services, you hereby expressly and voluntarily grant your informed consent to us to deal with your personal information in accordance with the disclosures, terms and conditions of this Privacy Policy (and as applicable, the terms and conditions of any written agreement you enter into with us). Should you retract your consent, please contact us. If you retract your consent, you acknowledge and agree that failure to provide certain types of personal information may not give you access to the full functionality of our products and services.
Are copies of this Privacy Policy available?
A copy of our current Privacy Policy (this document) is available from us free of charge. You can:
download a copy in document format from our website www.reginsun.com; or
request it by email, phone, or post using the contact details in this Privacy Policy (see Contact Us section below).
Contact Us
If you have any further questions relating to this Privacy Policy, or concerns about the way in which we have handled your personal information, please do not hesitate to contact us at:
Email: contact@reginsun.com
Address: Suite 405, 35 Lime Street, Sydney NSW 2000
Telephone: (+612) 9948 8780