Outlining the collection, use, and storage of Personal Information by us and other companies within our group.

We may obtain some information from public registers, public administration, or third-party sources like wealth screening services, credit reference agencies, etc. Your consent is assumed if a third party provides us with your Personal Information unless stated otherwise by you.

Privacy Law
Compliance

For institutional or corporate clients, we may collect information about directors, representatives, employees, shareholders, or beneficial owners. You should provide a copy of this Policy to those individuals before providing their information to us.

What Credit Information and Credit Eligibility Information does GIM Trading collect?

GIM Trading and its affiliated entities may collect, use, hold, and disclose credit information and credit eligibility information in accordance with the terms of this policy. The terms "Credit Information," "Credit Eligibility Information," "Credit Reporting Information," and "Personal Information" are as defined in the Privacy Act.

If you apply for commercial credit or provide a guarantee for commercial credit, the types of credit information and credit eligibility information that GIM Trading may collect, hold, and derive about you may include:

  • Identification information such as name, date of birth, gender, addresses, employment details, and driving licence number.
  • Details of credit applications, including the amount and type of credit applied for.
  • Information about your current and previous credit providers, credit limits, terms and conditions of credit arrangements, and repayment history.
  • Records of requests made by credit providers to credit reporting bodies for information about you.
  • Default information, including any overdue payments, payment arrangements, or adverse court judgments.
  • Sensitive information such as membership of associations, religious beliefs, or health information, collected with your consent or as permitted by law.
  • Information obtained from credit reporting bodies and derived credit scores, ratings, and assessments.

GIM Trading may gather credit information and credit eligibility information about you from third parties or publicly available sources, including credit reporting bodies, financial advisors, and fund managers. By providing your Personal Information to GIM Trading, you consent to the collection, use, holding, and disclosure of your credit information and credit eligibility information as outlined in this policy.

For which purposes do we process your personal information?

We process your personal information for specific purposes within applicable legal limitations, including:

  • Client Onboarding: Verify your identity and assess your application, including compliance checks for anti-money laundering regulations and fraud prevention.
  • Client Relationship Management: Manage our relationship with you, handle customer service queries, and learn more about your preferences.
  • Product Implementation and Execution: Provide products and services, ensure proper execution, and perform underwriting.
  • Engaging in Prospecting and Business Development: Evaluate offering products and services, contact you for direct marketing, and facilitate competitions and promotions.
  • Compliance and Risk Management: Comply with legal and regulatory obligations, receive and handle complaints, and prevent and detect crime.
  • Supporting, Enhancing, and Maintaining Technology: Improve products and services, test and upgrade systems, and conduct market research.
  • Other Purposes: Prudent operational management, facilitate business transfers or mergers, ensure security, undertake analysis and research, and exercise our duties and rights.

How will GIM Trading use your Credit Information and Credit Eligibility Information?

GIM Trading may use credit information and credit eligibility information to assess credit applications, determine creditworthiness, offer further services, and comply with regulatory or legal requirements. If you do not provide the requested Personal Information or consent to its use in accordance with this policy, we may be unable to provide you with the products or services you require.

How do we protect Personal Information?

All GIM Trading employees accessing Personal Information must adhere to our internal rules and processes regarding the processing of your Personal Information to safeguard them and ensure their confidentiality.

GIM Trading have implemented robust technical and organisational measures to safeguard your Personal Information against unauthorised access, accidental or unlawful destruction, loss, alteration, misuse, disclosure, or any other form of unlawful processing.

Who has access to Personal Information and with whom are they shared?

Within GIM Trading:

We typically share Personal Information with other GIM Trading entities to maintain a consistent service standard across our group and to deliver services and products to you as indicated above.

Outside GIM Trading:

Third Parties

We may share Personal Information with other credit and financial services institutions, comparable institutions, and our professional advisors and consultants to manage our business relationship with you. This includes sharing Personal Information with individuals acting on your behalf or involved in your transactions, such as:

  • Insurers or parties assuming risk in the transaction.
  • Credit card associations and payment providers for credit card-related services.
  • Issuers of securities and their appointed third parties.
  • Payment recipients, beneficiaries, intermediaries, and correspondent banks.
  • Financial institutions, credit reference agencies, or credit bureaus.
  • Third-party fund managers providing asset management services.
  • Introducing brokers to whom we provide introductions or referrals.
  • Legal, audit, consultancy, accounting, or insurance service providers.
Service Providers

In some cases, we share Personal Information with contracted suppliers, such as IT providers, logistics services, marketing agencies, and others. These service providers are contractually obligated to maintain confidentiality and adhere to our data security standards to ensure the security of your Personal Information.

Public or
Regulatory Authorities

We may disclose Personal Information to public authorities, regulators, governmental bodies, or courts as required by applicable law, regulation, or under a code of practice. This may be done to safeguard our legitimate interests or in response to requests from such authorities or as part of legal proceedings.

Credit
reporting bodies

Credit reporting bodies, as permitted by the Privacy Act and the CR Code, handle credit information and use it to derive credit reporting information. However, these regulations limit our actions regarding this information.

If you apply for commercial credit or offer to act as a guarantor, we may disclose your credit information to a credit reporting body or collect credit reporting information about you. This assists in determining your credit eligibility and suitability.

Credit reporting bodies may include your credit information in reports provided to credit providers to assess your creditworthiness. Currently, we engage with Equifax Australia (formerly Veda Advantage).

For details on how these credit reporting bodies manage your information, please refer to their privacy policies available on their websites.

Credit reporting bodies offer a service called "credit pre-screening" to credit providers for direct marketing purposes. You have the right to opt out of this service by contacting the credit reporting body directly.

Additionally, you can request that a credit reporting body not use or disclose your credit reporting information if you believe you have been or are likely to be a victim of fraud.

Others

We may share Personal Information with potential buyers, merger partners, or sellers and their advisors in connection with business transfers or mergers. Additionally, we may disclose information to legitimate recipients as required by applicable laws or regulations.

Data transfers
to other countries

Personal Information transferred within or outside GIM Trading may be processed in other countries. We only transfer data to countries with adequate data protection laws or implement appropriate safeguards as required by local law.

You acknowledge and agree that your information may be transferred between related entities or to third parties providing services to GIM Trading.

How long do we
store your data?

We retain Personal Information for as long as necessary to fulfill its purpose or to comply with legal, regulatory, or internal policy requirements. Data retention periods are determined based on specific criteria.

We may retain your data for the duration of our banking relationship and beyond for compliance, risk management, or other legitimate interests. Your Personal Information is stored securely, either physically or electronically, with measures in place to protect against misuse or unauthorised access.

If you wish to have your Personal Information removed from our databases, you can make a request as outlined in Section 8 below, which we will review accordingly.

What are your rights
and how can you exercise them?

If you wish to access the information held by GIM Trading about you, you can request it by contacting our handling units at the following email addresses:

We will promptly investigate your inquiry and provide appropriate answers where required or permitted. If you find that any information is outdated, incorrect, or incomplete, you may request to have it corrected, and we will promptly update our records.

You can also contact the Group Data Protection Office at compliance@gimtrading.com if you have any questions about our compliance with the Privacy Act, or if you wish to make a complaint about our handling of your Personal Information, including any failure to comply with the Privacy Act or regarding your credit information and credit eligibility information.

Complaints should initially be made in writing to the GIM Trading as required by the Privacy Act. We aim to respond to complaints within 30 days. If your issue remains unresolved, you can lodge a complaint with the Australian Financial Complaints Authority (AFCA), which offers free and independent financial services complaint resolution for consumers. You can contact AFCA via their website, email, telephone, or in writing.

Website: www.afca.org.au Email: info@afca.org.au Telephone: 1800 931 678 (free call) In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001

If you're still dissatisfied with the outcome after AFCA's determination, you may lodge a complaint with the Office of the Australian Information Commissioner.

Their contact details are as follows:

Office of the Australian Information Commissioner
Telephone: 1300 363 992 Website: www.oaic.gov.au Address: GPO Box 5218, Sydney, NSW 2001

Changes to your
Personal Information

We are committed to maintaining the accuracy and currency of your Personal Information. Therefore, if your details change, please inform us promptly.

Updates to
this Policy

This Policy was last updated in January 2023, and we reserve the right to amend it from time to time. Any changes or updates will be made available on our website. We encourage you to check our website frequently to stay informed about the current Policy.

If you have any questions or comments about this Policy, please contact compliance@gimtrading.com.

When we collaborate on achieving your financial goals, success is well within your reach.

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GIM Trading


Level 10
440 Collins Street,
Victoria, Australia