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Wednesday, January 7, 2009

privacy policy

Version: 3

Issue Date: Thursday, 15th May 2008

PLUM GROVE’S COMMITMENT

If you have any questions in relation to privacy, please contact us between 9.00 am and 5.00 pm, Monday to Friday. Alternatively, you can:

Use the contact us page on the website to send your questions and comments via email.

Plum Grove Pty Ltd trading as Plum Grove Commodity Trading Solutions (Plum Grove) is committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you.  The Privacy Amendment (Private Sector) Act, 2000 sets out a number of National Privacy Principles (NPPs). Our aim is to both support and ensure that we comply with these principles.  Further information on privacy in Australia may be obtained by visiting the website of the Office of the Federal Privacy Commissioner at http://www.privacy.gov.au.

Plum Grove believes that this Privacy Policy discloses how the personal information you provide to us, and our representatives, is collected, used, held, disclosed and disseminated.

Plum Grove collects information about you to meet particular legislative and regulatory requirements including for the purpose of reporting to AUSTRAC under the Anti Money Laundering and Counter Terrorism Financing Act 2006.  In order to provide a comprehensive financial product advice to you, we are required to collect certain personal information from you.


YOUR PERSONAL INFORMATION

Personal information held by Plum Grove may include the following information:

your name, date of birth, current addresses, telephone/mobile/fax numbers, e-mail address;
information regarding your dependents and family commitments
your occupation, employment history and details.
your financial needs and objectives;
your assets and liabilities (current and future), income, expenses;
your risk profile details.

If you choose not to provide certain personal information or provide incorrect information, the advice and/or recommendations may be inappropriate or inadequate.

HOW WE COLLECT PERSONAL INFORMATION

Plum Grove collects personal information in a number of ways, including:

directly from you, when you attend a face-to face interview;
directly from you, when you provide information through a data collection form;
directly from you, when you provide information by phone;
directly from you via an email or the internet; and
directly from grain marketing companies, brokers, banks and other product issuers once once authorisation has been provided by you.

You have a right to refuse us authorisation to collect information from a third party.


HOW WE USE YOUR PERSONAL INFORMATION

Primarily, your personal information is used in order to provide financial product advice (grain derivatives and foreign exchange) to you.

 

Although in certain circumstances we are required to collect government identifiers such as your tax file number or drivers licence number, we do not use of disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.

 

From time to time, we may provide you with direct marketing material. This will include articles and newsletters that may be of interest to you. We maintain a register for those individuals not wanting direct marketing material.  If, at any time, you do not wish to receive this information any further, you may contact us with this request. We will endeavour to meet your request within 2 weeks.


WHEN WE DISCLOSE YOUR PERSONAL INFORMATION

The Corporations Act has provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you.

For the purposes set out above, we may disclose your personal information to organisations outside Plum Grove. The organisations to which we disclose information may include:

compliance consultants to ensure that our representatives are meeting our compliance standards;
paraplanning contractors or temporary staff to handle workloads during peak periods;
mailing houses;
your professional advisers, including your solicitor or accountant as authorised by you;
information technology service providers to manage our IT systems;
government and regulatory authorities and other organisations, as required or authorised by law;
another authorised representative of Plum Grove if necessary;
a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them; and
a new owner of our business that will require the transfer of your personal information.

In addition, our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of any personal information held by Plum Grove.

HOW WE STORE AND SECURE YOUR PERSONAL INFORMATION

We keep your personal information in your client file. These files are accessible to authorised personnel only and are appropriately secured out of hours.

Your personal information may also be held on our computer database. All computer-based information is protected through the use of access passwords. Data is backed up regularly and stored securely off site.

It is a legislative requirement that we keep all personal information and records for a period of 7 years. Therefore, if you are no longer a client of Plum Grove, we will maintain your personal information on or off site in a secure manner for 7 years. After this, we will ensure it is destroyed in a secure manner.

ENSURE YOUR PERSONAL INFORMATION IS CORRECT

Plum Grove takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. To ensure we can maintain this level of accuracy and completeness, we recommend that you:

inform us of any errors in your personal information as soon as possible; and
update us with any changes to your personal information as soon as possible.

ACCESS TO YOUR PERSONAL INFORMATION

You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing (for security reasons) and we will (subject to certain exceptions) provide you with access to that personal information. Access to the requested personal information may include:

providing you with copies;
providing you with the opportunity for inspection; or
providing you with a summary.

Access to your information may be denied if:

tick providing access would pose a serious threat to the life or health of a person;
tick

providing access would have an unreasonable impact on the privacy of others;

tick the request for access is frivolous or vexatious;
tick the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
tick

providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;

tick providing access would be unlawful;denying access is required or authorised by or under law;
tick providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

Should we refuse you access to your personal information, we will provide you with an explanation for that refusal.


COMPLAINTS RESOLUTIONS

Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 10 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.

OUR WEBSITE

Plum Grove’s website provides links to third party websites. The use of your information by these third party sites is not within the control of Plum Grove and we cannot accept responsibility for the conduct of these organisations.
You may register with us to receive newsletters and other information. By doing so, your name and email address will be collected and stored on our database.

If you do not wish to receive any further information from us, or you wish to update your registration details, please email your request to us. We will endeavour to meet your request within 2 weeks.

Our Website utilises cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using our site – they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.

Contact Details

Privacy Officer
: Nathan Omodei
Address

: PO Box 235

: North Fremantle WA 6159

Telephone
: (08) 9335 4773
Facsimile
: (08) 9335 6682
E-mail : nomodei@plumgrove.com.au