Copyright 2019

1. Intent

This Privacy Policy describes how Eastern & Allied Pty Ltd (E&A), collects and uses your personal information when you visit one of our branches or Affiliates, use our online form found on our websites, or use our online platform. The services we and our Affiliates provide, are bound by the Australian Privacy Principles under the Privacy Act 1988 (Commonwealth) and other privacy-related legislation.

2. Scope

This policy applies to all E&A and its Affiliates. This includes any person or business engaged in work for E&A on a full-time, part-time, casual, contract or volunteer basis, and includes executive and non-executive members of the board. Affiliates as defined by the Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Act 2006, are subject to the same Privacy Policy as E&A for the services they provide.

3. Information we collect

We collect and hold your information directly from you and from different sources to provide you with money transfer and foreign exchange services (services).

The types of Personal Information we collect may be an individual’s name, mailing or residential address, email address, telephone number, mobile phone number, age, date of birth, gender, nationality, residency status, passport number, driver’s licence number, profession, occupation, job title, credit report information and income and financial information provided to assist with our obligations under the AML/CTF Act.

By using our services, you agree to the collection, transfer and storage of this information on our system database and storage devices, and to service providers, partners and Affiliates to fulfil the transaction.

We may collect and update information through these means:

• When you wish to use our services when you visit one of our branches or Affiliates and provide information in person;
• When you submit information online to us or our Affiliates;
• Through other means of communication such as mail, over the phone, via email, and via SMS;
• From a third-party source including public sources, credit reporting bodies, entities that can verify the information you provide in order to carry out a transaction.

If someone other than you provides us with personal information about you, that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you, as soon as practicable. This notice will be given unless doing so would be in breach of an obligation of confidence. If we determine we could not have collected the information from you, we will take reasonably practicable steps to de-identify or destroy the information if it is lawful and reasonably practical to do so.

We will only collect personal information that is reasonably necessary for or directly related to, one or more of our functions. If we are unable to collect the required personal information, we may not be able to do business with you or the organisation in which you are authorised to act for.

4. Privacy Disclosure and Consent

We will use your personal information to provide you with our services, to meet our AML/CTF and other regulatory requirements. We may also use your information for other reasons including sending you updates about our services, products and special offers by post, telephone or any form of electronic communication. We may use any email address, other personal information or contact information you provide to us at any time for this purpose.

We will not disclose your information to any third party other than as set out in this Privacy Policy. In order for us to provide you with our products and services, we may disclose your personal information to other organisations. We take reasonable steps to ensure that these organisations are bound by privacy obligations in relation to protecting your personal information.

4.1 Disclosure to other organisations for service providing purpose

We may disclose your personal information to our service providers, partners and Affiliates to successfully complete and fulfil a transaction. This disclosure may be to entities within Australia and overseas. These include example, organisations to help us verify your identity and a corresponding international party we partner with to fulfil your transfers overseas. While we take appropriate measures to protect personal information before disclosure, these overseas recipients are not required to comply with the Australian Privacy Principles and may have different disclosure requirements under local laws. The countries we disclose your information to will depend on the details of the transaction you ask us to carry out. In providing us with your personal information, you consent to the transfer of your personal information overseas for the purposes outlined in this privacy policy.

4.2 Disclosure to the Australian Transaction Reports and Analysis Centre (AUSTRAC) and government agencies:

Under the AML/CTF Act, we are required to disclose information to AUSTRAC. From time to time law enforcement agencies, and other government agencies may request information which we are obliged to provide this information,

4.3 Disclosure to you or your Attorney:

Our privacy disclosure and consent process is as follows. The customer or a person authorised under a valid Power of Attorney of the customer has personal information disclosed to them only once they have been properly identified and verified with approved identification and documentation. Information may be given to a customer’s Power of Attorney when they have been identified as such with an original or a certified copy of appropriate documentation. We reserve the right not to disclose any information until we are satisfied with the identity of the customer or the Attorney of the customer.

4.4 Disclosure to your authorised person:

We may allow your information to be disclosed to an authorised person. For this to happen, we would need a written authorisation from you. The customer and the authorised person must first be properly identified and verified with approved identification documentation. In addition to this, we would need confirmation in person that this disclosure is allowed. We reserve the right not to disclose any information until we are satisfied with the identity of the authorised person and the customer.

4.5 Security Incident regarding privacy risks

In the event of a security incident involving unauthorised access, use or disclosure of personal information where we may need to share personal information with a third party (such as a forensic specialist), we will seek to work cooperatively with them to protect the personal information. We may disclose further information for the purpose of investigating a security incident.

We reserve the right not to disclose information to you, other than the personal and sensitive information that you are entitled to access that we hold on or about you.

In doing business with us, we also may use your personal information for direct marketing, with your consent. If you wish to be taken off the subscription list, please contact us (see below).

5. Confidentiality and Security

We will use all reasonable endeavours to keep your personal information in a secure environment and to ensure that records of customer information are protected from unauthorised access. However, this security cannot be guaranteed. We implement industry-accepted standards in protecting your information provided to us in person or on our websites. Additionally, we adopt Secure Socket Layer (SSL) encryption technology to protect your sensitive information transmitted on our websites. Your information is securely stored on our transaction process platform backed up to the cloud via Amazon Web Services. We also require a username and password and/or a customer verification from each user who wants to access his or her information.

We maintain physical, electronic and procedural safeguards that comply with applicable government regulations to protect your personal information. We use up-to-date technology and procedures to ensure customer data is protected from unauthorised access, misuse, and/or loss.

Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident, we have put in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information. and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Act requirements.

Our organisation, our employees and Affiliates are the only people allowed to have access to customer information and, within the organisation, only those employees who need to access this information as part of their job will be able to do so.

If we no longer need your personal information, unless we are required under Australian law to retain it, we will take reasonable steps to destroy or de-identify your personal information, in accordance with our document retention policy.

6. Direct Marketing

We will use your personal information primarily for providing you with our products and services, and also for marketing purposes. This includes sending you information about new developments, products, services and special offers by post, telephone or any other form of electronic communication. You authorise us to use any email address or other contact information you provide to us at any time for this purpose.

You can, at any time, opt out of receiving marketing material by contacting us. You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are legally required to send you relating to the services we provide. Once you request to opt out from receiving our marketing material, you agree and acknowledge that this removal from our distribution lists may take several business days after the date of your request to take effect.

7. Accuracy of Information

We take all reasonable steps to ensure that your personal information held by us is accurate, up-to-date, complete, relevant and not misleading. If you believe that any of your personal information is not accurate, up-to-date, complete, relevant or is misleading, please contact us (see below) and we will take all reasonable steps to correct it within a reasonable time.

You may request details of information we hold and request us to correct or erase any erroneous or out-of-date Information by using the contact methods listed at the end of this statement. To protect your privacy, we will need to verify your identity before making details or corrections.

8. Your Consent

By your use of our services you consent to the collection, storage, use and disclosure of your personal information in accordance with this Privacy Policy and as otherwise permitted under the Privacy Act.

9. Changes

We may vary the terms of this Privacy Policy at any time. Updated Privacy Policy documents will be posted at our website when amendments occur. We urge you to review our Privacy Statement online when you wish to obtain the most current statement.

10. Complaints

We work to ensure that we operate in the manner outlined here however if you have any issues or concerns, please do not hesitate to contact us so we can resolve your issues.

If you believe your privacy may have been interfered with by us, you have the right to make a complaint about the matter by contacting our Privacy Officer at the contact details below. We will investigate the complaint, respond to you promptly and attempt to resolve it.

If we receive a request in writing from you seeking resolution of a dispute concerning our services, we will respond to you in writing within 30 days of receipt of the request.

If you are dissatisfied with our handling of the complaint, or the outcome, you may take your complaint to the Office of the Australian Information Commissioner (OAIC). Further information is available by phoning: 1300 363 992 or at: http://www.oaic.gov.au/about-us/contact-us-page.

11. Access to Information We Hold About You

If you request access to the personal information, we hold about you, we will respond to your request within a reasonable period of time and. We will give access to information after identification and verification through approved identification documentation, in a manner you request, where possible. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by writing to via email or post to:

The Privacy Officer
Eastern & Allied Pty Ltd
Address: 56 John Street, Cabramatta, NSW 2166
Telephone: +61 2 9728 7928
Email: info@hhmt.com.au

We may charge a reasonable fee for providing that information. When contacting us you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is not practicable for us to communicate with you that way, and we can only provide our financial services to individuals who have identified themselves as required under Australian Law.

For more information or complaints, please contact +61 2 9728 3581 or send an email to us at info@hhmt.com.au.