Privacy policy.
Loftus Group Pty Limited and its related bodies corporate and affiliates (altogether, the Loftus Group) respect the privacy of your personal information and are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) as established under the Privacy Act. The APPs regulate the handling of personal information including its collection, handling, use, disclosure and storage.
This Privacy Policy outlines what will happen to the personal information you provide through your communications with Loftus Group or its website. Please read this Privacy Policy before submitting personal information to Loftus Group or using the Loftus Group’s website.
Personal Information
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not. This may include your name, address and telephone number.
Your consent
By providing Loftus Group with personal information (by any means, whether verbal, written or electronic and either directly or through others) or through your use of Loftus Group’s website, you agree with the terms of this Privacy Policy. Whenever you submit personal information to Loftus Group, you consent to the collection, handling, use, disclosure and storage of that personal information in accordance with this Privacy Policy, and the Privacy Act (as amended from time to time) including the APPs.
How Loftus Group collects your personal information
Loftus Group may collect your personal information in a number of ways, including:
directly from you;
from publicly available sources; and
by analysing Loftus Group’s own records of your use of Loftus Group’s services and website.
Loftus Group may also collect your personal information when required to do so by law.
Kinds of personal information collected and held
Loftus Group collects personal information in the ordinary course of business. The personal information collected, held, used and disclosed will depend on the nature of your relationship with Loftus Group.
The kind of personal information we may need to collect from you includes:
Clients - Name, address, personal and business contact details, professional or practice details.
Client’s Customers and Investors- Name, address, personal and business contact details, personal financial, banking and tax information (including tax file numbers), adviser details.
Employment Applicants – Name, address, personal and business contact details, resumes including professional qualifications, professional or practice details, membership of any professional association, education, prior employment, history, references and any other information that the applicant may provide.
Use and purposes of collection
Loftus Group collects personal information in the ordinary course of business to in order to provide its services to clients. Loftus Group may use your personal information to:
verify your identity;
facilitate the provision of our services to you or your services to Loftus Group;
inform you of existing and proposed commercial opportunities;
manage our business;
better understand your needs in the area of private equity fund management and operations;
improve the quality and scope of the services Loftus Group provides;
employee recruitment and assessment;
to comply with legal obligations; and
do things related to the purposes described above which would be reasonably expected by you.
Loftus Group will not use your personal information for purposes other than those described above unless you have consented to it or Loftus Group is required to do so by law.
Disclosure of your personal information to others
Loftus Group may disclose your personal information to third parties to assist Loftus Group in providing its services. Third parties that Loftus Group may disclose your personal information to include:
Loftus Group’s business partners;
persons engaged in providing Loftus Group with professional, financial, business, technology and corporate services when reasonably required;
foreign and domestic governmental agencies and regulators in relation to compliance, anti-money laundering or law enforcement, including Foreign Investment Review Board and the Australian Taxation Office (or the equivalent in foreign jurisdictions); and
others in accordance with your express consent or otherwise authorised by you.
Other than as outlined in this Privacy Policy, Loftus Group will not disclose your personal information to third parties unless it has your consent or it is authorised or required to do so by law.
Loftus Group does not sell any personal information to any third party nor does it share or disclose your personal information to third parties for separate and unrelated use of that personal information by the third party.
Sending your personal information outside Australia
In relation to personal contact information, Loftus Group’s technology and data service providers may send your personal information overseas for the purposes of data storage and processing on hosted and other cloud based systems.
Loftus Group will take reasonable steps to ensure that any overseas third parties have processes in place to protect personal information from unauthorised use and disclosure.
By providing Loftus Group with personal information or through your use of Loftus Group’s website, you consent to the disclosure and transfer of your personal information to these overseas recipients and understand that they may not be subject to the Privacy Act and APPs (or equivalent laws). Accordingly, you understand that:
• the overseas recipient may use, disclose or otherwise handle your personal information in a manner that breaches the APPs;
• Loftus Group is not liable for any such breaches of the APPs by the overseas recipient (i.e. section 16C of the Privacy Act will not apply);
• you may not be able to seek redress in respect of any such breaches of the APPs by the overseas recipient; and
• you may not be able to access, correct or make a complaint in respect of, any of your personal information that is held by the overseas recipient.
If you wish to withdraw your consent to any future disclosures of your personal information to these overseas recipients, please contact us using the details below. Note that withdrawal of consent may mean that Loftus Group will be unable to provide services to you.
Access to and accuracy of personal information
Loftus Group will take reasonable steps to ensure that the personal information it collects, handles, uses, stores or discloses is accurate, up-to-date and complete.
You may access personal information that Loftus Group holds about you. You may also request Loftus Group to correct personal information that Loftus Group holds about you. Loftus Group will respond to a request for access or correction to personal information within a reasonable period. Where it is reasonable and practicable to do so, Loftus Group will provide access to the personal information in the manner requested by you. To make a request, please contact Loftus Group using the contact details below.
In some circumstances, Loftus Group may not be permitted by law to provide you with access to your personal information. If this is the case, Loftus Group will provide you with reasons for its decision.
Consequences if requested personal information is not provided
If you do not provide requested personal information, or if that personal information is incomplete or inaccurate, it may:
· contravene taxation and anti-money laundering legislation
· prevent Loftus Group from providing services, and/or
· prevent Loftus Group from being able to contact you.
Security
Loftus Group will take all reasonable steps to safeguard your personal information from loss, misuse, unauthorised access, modification, inappropriate disclosure or destruction.
Loftus Group’s Website
This website may contain links or references to websites to which this Privacy Policy may not apply. Loftus Group is not responsible for the privacy policies and practices of third party websites.
Certain personal information can be passively collected as you navigate through Loftus Group’s website through a variety of technologies. Passively collected personal information is not combined with personal information collected elsewhere on Loftus Group’s website unless you have consented to it.
Loftus Group’s website is not intended for children under the age of 16 years. Loftus Group will not knowingly collect personal information from website visitors of this age group.
Complaints about Privacy
If you consider that Loftus Group has breached this Privacy Policy or the Privacy Law or APPs, you may make a complaint by contacting Loftus Group as outlined below. Loftus Group takes privacy complaints extremely seriously and will act promptly in response to any complaint.
Where you are not satisfied with how your complaint has been handled by Loftus Group, you are entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC). You can make a complaint to the OAIC using any of the methods listed on their website (http://www.oaic.gov.au/about-us/contact-us-page).
Right to vary this Privacy Policy
Loftus Group reserves the right to vary this Privacy Policy from time to time. The updated Privacy Policy will be available through the Loftus Group website or you may contact Loftus Group at any time to obtain the latest copy of this Privacy Policy in either electronic or hard copy free of charge.
How to contact us
If you have any questions or concerns about this Privacy Policy, please contact Loftus Group via the Contact Us page on the website.