Effective Date:  18 October 19, 2024   V1.0

Introduction
XCHEQER Pty Ltd (referred to as “we,” “us,” or “our”) provides investment administration and consulting services. We are committed to protecting your privacy and ensuring compliance with the Australian Privacy Principles (APPs) as outlined in the Privacy Act 1988 (Cth) (the “Privacy Act”). This Privacy Policy explains how we collect, use, disclose, and store your personal information and how you can access or update this information.

1. What is Personal Information?

“Personal Information” refers to information or an opinion about an identified individual or an individual who is reasonably identifiable. This includes your name, contact details, financial information, and other sensitive data.

2. Types of Personal Information We Collect

We may collect the following types of personal information:

• Identification Details: Name, date of birth, gender, address, email address, telephone numbers.
• Financial Information: Bank account details, tax file numbers (TFNs), Australian Business Numbers (ABNs), investment preferences, risk profiles, and account transaction history.
• Sensitive Information: We may collect sensitive personal information (such as health information or criminal record) if required and permitted by law.
• Other Information: Information collected through our website such as IP addresses and cookies.

3. How We Collect Personal Information

We collect personal information in various ways, including:

• Directly from you: When you provide personal information via forms, email, phone, or through interactions with our website.
• Through your representatives: Including financial advisors or brokers.
• From third parties: Including public sources, government bodies, or external service providers.
• Automatically via our website: Using cookies, tracking tools, or similar technologies.

4. Purpose of Collecting Personal Information

We collect and use your personal information for the following purposes:

• To verify your identity and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations.
• To provide investment administration services, including account management, transaction processing, reporting, and communication.
• To comply with regulatory and legal obligations, including those under the Corporations Act, Taxation Laws, and Superannuation Laws.
• For administrative purposes such as managing investor relations and responding to inquiries.
• To assess and manage risk, including monitoring your investment portfolio.
• For marketing and promotional purposes where consent has been provided.
• To improve our services and customer experience.

5. Disclosure of Personal Information

We may disclose your personal information to the following entities for the purposes outlined above:

• Third-party service providers: Including custodians, auditors, consultants, IT service providers, payment processors, and other entities involved in the operation of our services.
• Regulators and government agencies: Including the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO), the Australian Transaction Reports and Analysis Centre (AUSTRAC), and other regulatory bodies as required.
• Professional advisors: Including legal, financial, and compliance consultants.
• Related entities: As part of our corporate structure for business administration purposes.
• Third parties with your consent: In specific cases, where you have consented to the disclosure.

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

6. Cross-Border Disclosure

We may transfer your personal information to service providers or related entities located outside Australia. In these instances, we will take all reasonable steps to ensure that the overseas recipient complies with Australian privacy law and protects your personal information in accordance with the Australian Privacy Principles.

7. Data Security and Storage

We are committed to ensuring the security and protection of your personal information. We employ a variety of security measures, including encryption, firewalls, access controls, and secure storage systems to protect against unauthorized access, misuse, alteration, or disclosure.

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal, accounting, or regulatory obligations.

8. Accessing and Correcting Your Personal Information

You have the right to access the personal information we hold about you and to request correction of any inaccurate or incomplete information. To request access or correction, please contact us using the details provided below. We will respond to your request within a reasonable time frame, usually within 30 days, in accordance with the Privacy Act.

9. Complaints and Dispute Resolution

If you have a concern about the way we handle your personal information, please contact our Privacy Officer in the first instance at info@xcheqer.com

To help us complete a quick and effective investigation, please include your name, email address, and/or telephone number and describe your complaint in as much detail as you can.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner.

If you believe we have not adequately dealt with your complaint, you may contact the Privacy Commissioner, details of which can be found at www.oaic.gov.au

10. Cookies and Website Tracking

We may use cookies and other tracking technologies to collect information about your use of our website. This information helps us understand website usage patterns and improve your experience. You can disable cookies through your browser settings, though this may affect the functionality of our website.

11. Direct Marketing

We may send you marketing communications related to our services, including information about promotions or updates. You can opt out of receiving marketing communications at any time by contacting us or using the “unsubscribe” function in electronic communications.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our legal or regulatory obligations or changes to our business practices. Any updates will be posted on our website, and we encourage you to review the Privacy Policy periodically.

13. Privacy Officer Contact

Our Privacy Officer’s contact details are:

Email: info@xcheqer.com

Mail: 5 Medici Place, Glenwood. NSW2768

Phone: +612 8859 9000

Disclaimer: This Privacy Policy has been prepared based on general Australian legal requirements and is not intended as legal advice. For specific advice, please consult with a legal professional or privacy specialist to ensure compliance with applicable laws and regulations.