Privacy Policy

This policy explains how PAC Partners Securities Pty Ltd (PAC Partners or PPS) and PAC Asset Management Pty Ltd (PAM) handle personal information in connection with PAC Partners’ business. We, us and our refer to those entities for their respective activities. PPS is a Corporate Authorised Representative of PAM, holder of Australian Financial Services Licence number 335374.

We handle personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and other applicable requirements. This policy covers clients, investors, business contacts, subscribers, website users and job applicants. Read it with our Website Terms and Conditions and relevant collection notices. It does not limit your privacy rights or constitute blanket consent.

Depending on your dealings with us, we may collect and hold:

- Identity and contact details, including name, date of birth, address, occupation and verification information.

- Banking, financial, tax residency, holdings and transaction information, including information to assess wholesale client status and identify beneficial owners and authorised representatives.

- Correspondence, instructions, subscription preferences, event and website interactions, and relevant employment application information.

We collect information directly through applications, enquiries, communications, meetings and our website, and where lawful from representatives, advisers, referrers, issuers, registries, clearing providers, verification services and public sources. We provide collection notices where required and do not assume consent merely because a third party supplies information.

We only collect sensitive information where reasonably necessary and with consent, unless otherwise permitted by law. Government identifiers are not used as our own client identifiers. Tax file numbers and identity document copies are collected, used and retained only as permitted by applicable law. Quoting a tax file number is generally optional, although withholding tax consequences may apply.

We use information to administer relationships and accounts; verify identity, authority and eligibility; arrange trading, settlement and capital raisings; provide advisory services, research and events; manage communications, recruitment, risk and security; and comply with applicable financial services, AML/CTF, tax and market requirements.

Other uses or disclosures must be permitted by law, including a related purpose you would reasonably expect or valid consent. For sensitive information, a secondary purpose generally must be directly related and reasonably expected, unless another lawful basis applies.

include PAM and PPS, your representatives, issuers, registries, brokers, banks, custodians, clearing and settlement providers including FinClear, identity verification services, professional advisers and providers of IT, cloud storage, backup, client management and communications services.

We may also disclose information to ASIC, AUSTRAC, the ATO, markets, courts and other authorities as required or authorised, and to confidential advisers or prospective purchasers in a lawful business transaction. Provider access is limited to what is needed, with appropriate privacy and security arrangements.

Service providers and authorised overseas transactions may involve information being stored, processed or accessed outside Australia.

We take the reasonable steps required by APP 8 to ensure overseas recipients do not breach the APPs in relation to disclosed information, unless a permitted exception applies. This policy does not seek consent to waive those protections.

Where permitted by law, we may send research, market updates, invitations and service information. You can opt out of marketing without charge through the unsubscribe facility or by contacting us. We action requests within applicable legal timeframes. Essential account, transaction and legal communications may continue. We do not use sensitive information for marketing without consent. You may request the source of marketing information where the law provides that right.

Subscriptions do not establish wholesale client status or eligibility for restricted research or offers. Our Website Terms and Conditions explain those restrictions.

Our website and communications may use cookies and similar technologies to collect IP addresses, device details, usage and interaction data for operation, security and analytics. You can manage cookies through browser and available website settings. External services have their own privacy policies. We remain responsible for our own information handling.

We hold electronic and, where necessary, physical records and take reasonable technical and organisational steps to protect them against misuse, interference, loss and unauthorised access, modification or disclosure. No system is completely secure.

We retain information for lawful business and legal purposes, including applicable record keeping obligations. Periods vary by record type; a seven-year requirement for some records does not mean all identity document copies must be kept for seven years. When no longer needed and retention is not legally required, we take reasonable steps to securely destroy or permanently de-identify information.

Contact our Privacy Officer to request access to, or correction of, personal information. We may verify your identity or authority. We respond within a reasonable period, generally within 30 days. Requests and corrections are free; any permitted reasonable charge for providing access will be explained beforehand.If access or correction is refused as permitted by law, we will explain the reasons and complaint options where required. You may ask us to attach a statement of a disputed correction, and to notify other recipients of corrections where required.

We promptly assess suspected breaches, contain incidents and reduce harm. Where an eligible breach is suspected, we take all reasonable steps to complete a reasonable and expeditious assessment within 30 calendar days of becoming aware of the grounds for suspicion.

Where required under the Notifiable Data Breaches scheme, we notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as soon as practicable. This generally applies where unauthorised access, disclosure or loss is likely to cause serious harm and remedial action has not prevented that likelihood. Notifications include protective steps individuals can take. We separately assess other reporting obligations, including PAM’s obligations to ASIC.

Contact our Privacy Officer with questions, requests or complaints, including the outcome sought. We can assist you to make a complaint. We acknowledge complaints promptly and aim to respond within 30 days, explaining any delay.

Privacy Officer
PAC Partners Securities Pty Ltd
Email: enquiries@pacpartners.com.au
Post: Level 8, 360 Collins Street, Melbourne VIC 3000