WSFX is responsible for all personal information you provide to it and will deal with that information in accordance with the following Privacy Principles.
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WSFX has implemented procedures to implement its Privacy Principles and to deal with complaints and enquiries. Our Compliance Manager has overall responsibility for ensuring that WSFX and its employees, agents and subsidiaries comply with our Privacy Principles. Our Compliance Manager may be contacted in relation to any enquiry or complaint at: admin@wallstreetfx.com.au
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WSFX will not disclose any of your personal information to a third party, or in a foreign country, unless the recipient is subject to legislation, or a contract, that safeguards your personal information in a manner that is substantially similar to our Privacy Principles.
Privacy Principles
Purpose
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WSFX will collect personal information only for the purpose of providing its services to you or for any purpose that is directly incidental to the provision of those services. In the event that WSFX wishes to use your personal information for any other purpose, it will identify such purpose and obtain your consent before doing so, unless the new purpose is required by law.
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WSFX is always willing to explain to you the purposes for which your information is being collected.
Consent
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WSFX will seek your consent to the use of your personal information either expressly or impliedly, depending on the circumstances and the type of information collected. For example, WSFX will rely on your implied consent when you give us your name, address, telephone number and other details necessary for us to verify your identity in accordance with the provisions of the Client Agreement. We will seek your express consent if the information is of a financial nature or concerns your personal credit.
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Your consent may also be given by an authorised representative or a person having Power of Attorney.
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You may withdraw your consent at any time, subject to any legal restrictions and subject to any contractual restrictions you have already entered into with us, and provided that you give us reasonable notice in writing. We will explain to you the implications of such withdrawal.
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If you are registered with WSFX, we may from time to time send you information that is relevant to the provision of our services. If, at any time, you do not wish to receive that information, you may by sending us an email opt-out and request that you are not included in any future mail-outs.
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There may be circumstances in which WSFX is obliged to collect, use, or disclose certain personal information without your consent. Such circumstances include:
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a serious and imminent threat to someone's life, health or safety;
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a serious threat to public health or public safety;
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unlawful activity has been, is being or may be engaged in;
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disclosure is required or authorised by law;
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WSFX reasonably believes that the use or disclosure is necessary for the prevention, detection, investigation, prosecution or punishment of:
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criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;
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the enforcement of laws relating to the confiscation of the proceeds of crime;
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the protection of the public revenue;
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the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
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the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.
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If WSFX is obliged to use or disclose your personal information under paragraph 5, it will create a written report of the use or disclosure.
Limiting Collection and Retention of Information
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WSFX collects your personal information in order to provide our products and service’s to you and satisfy our regulatory obligations under relevant anti-money laundering laws, for example, in Australia the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), rules and other subordinate instructments (AML/CTF Laws).
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In order for us to satisfy our regulatory obligations under relevant AML/CFT Laws, for example the obligation that WSFX takes reasonable steps to verify the identity of its clients, WSFX may disclose your personal information to our external credit providers.
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[In some circumstances, WSFX may also disclose your personal information to intermediary banks in order to process certain transactions on your behalf, for example, by disclosing your name and address.]
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The amount and type of information collected by WSFX will be limited to that which is necessary to provide our services.
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WSFX will make reasonable efforts to inform you if we have collected personal information about you from someone else.
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Personal information shall be retained only for as long as may be necessary for the fulfilment of the purpose for which the information is collected. However, you should be aware that WSFX is obliged under relevant anti-money laundering and counter-terrorism legislation to retain information relating to personal identity for 7 years.
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Subject to any legislative requirements, WSFX will destroy, erase, or make anonymous your personal information when it is no longer required to fulfil the purpose for which it has been collected.
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If you refuse or fail to provide any requested information, WSFX may not be able to process any transaction/s for you.
Accuracy
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WSFX will make reasonable efforts to ensure that your personal information is sufficiently accurate, complete, and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you.
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WSFX will not routinely update your personal information, unless such a process is necessary to fulfil the purposes for which the information was collected. In accordance with the Client Agreement, you must notify us as soon as possible if any of the information you have provided to us has changed.
Safeguards
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WSFX has in place a range of security safeguards to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which it is held.
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The methods of protection may depend on the sensitivity of the information and the format in which it is contained. Security measures employed by WSFX include:
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technological measures including SSL 128 bit encryption for all data transfers over the Internet ;
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physical measures such as Secured filing and restricted access to offices; and
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strategic measures such as security clearances and limiting access to a "need-to-know" basis.
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WSFX ensures that its staff are aware of the importance of maintaining the confidentiality of personal information.
Access
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WSFX will upon request [and within 10 days of any such request] allow you access to your personal information. The requested information shall be provided or made available in a form that is generally understandable.
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In circumstances where you point out to WSFX that any information held by us is inaccurate or incomplete, we will take appropriate action to amend the information as required and, if necessary, notify any third party of the correction.
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There may be circumstances which preclude WSFX from providing access to some or all of your personal information. Those circumstances could be:
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the information may contain references to other individuals;
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legal, investigative, security, or commercial proprietary reasons; or
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the information is subject to solicitor-client or litigation privilege.
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WSFX may be prohibited by law from providing you with access to your personal information. For example, when the disclosure could:
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threaten the safety or physical or mental health of an individual other than you;
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reasonably be expected to cause immediate or grave harm to your safety;
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reveal personal information about another individual; or
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contravene another law that prohibits the disclosure.
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Complaints
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WSFX has procedures in place, to receive and respond to, complaints or inquiries about our policies and practices relating to the handling of personal information. WSFX takes all complaints seriously and will investigate all complaints.