Privacy Policy

Otsana Pty Ltd Trading As Otsana Capital (Otsana) is committed to providing professional services and respecting the privacy of your personal information. We are bound by the Enhancing Privacy Protection Act 2012

This policy explains how Otsana will collect, store, verify, use and disclose the information we hold about you and the conditions under which your information may be accessed.

Our Privacy Policy is reviewed from time to time to take into account new laws, changes to our operations and practices and to make sure it continues to remain appropriate to the changing environment. Any personal information we hold will be governed by the most recent Privacy Policy.

Collection of Personal Information

Otsana collects and maintains personal information that is necessary to enable us to deliver our services or products or otherwise for our primary business functions and/or activities.

In the normal course of our business we only collect information about you when you provide it to us or it is provided to us under your authority.

We will collect personal information directly from you when you apply for a product or a service which we are obliged by to do by law prior to providing you with a product or service.

On occasions we may collect personal information about you from third parties, for example credit reporting agencies, share registries or regulatory authorities. Information that we collect will be limited to that required to provide you with our services.

In the event of you not to providing sufficient information required to fulfill your request for the provision of a product or service, we may be unable to provide you with the product or service that you requested.

We may from time to time collect information voluntarily through market research, surveys or special offers. We may use this information to improve our product and service offerings and to consider the wider needs of our clients or potential clients.

What type of information does Otsana Capital Pty Ltd hold?

The type of information we collect and hold about you varies depending on the type of product or service you require. For example, Otsana will hold different information about you if you have a life insurance policy than we will hold if you have a managed investment.

The personal information we hold about you may include:

• details of your financial needs and objectives;
• details of your investment preferences and aversion or tolerance to risk;
• information about your employment history, employment circumstances, family commitments ;
• Any other relevant information that you provide to us to enable us to provide suitable recommendations.

Failure to provide the personal information referred to above may expose you to higher risks in respect of the recommendations made to you and may affect the adequacy or appropriateness of advice we give to you.

We will only collect, maintain and use your Personal Information to adequately provide the services you have requested including:

• the preparation of a financial recommendations;
• reviewing your financial position, risk management and objectives;
• reviewing your financial holdings.

In most circumstances, the information that we hold about you has been provided to us by you or under your authority. If we have received information that is not required to provide services to you, we will either advise you that we hold this information or destroy it.

Other purposes for which we may need to collect and use your personal information will include:

• To comply with legislative and regulatory requirements (including the AML/CTF 2006 Act,
• To enable us to perform administrative operations such as accounting, record keeping, and archival retrieval;
• To enable us to contact you when conducting marketing and inviting you to events that you may be interested in; and
• Tell you about new services and/or products we can offer (unless you tell us not to contact you with this type of information.)

You may choose not to provide us with your personal information. In this case we would not be able to deal with you including providing a financial product.  Under the AML/CTF laws we must be able to identify our clients and verify that identity.

How does Otsana use this information?

We use this information to provide you with products or services, and determine strategies and perform due diligence on potential corporate advisory deals as well as provide information about investment opportunities to you.

We may also use the information to send you material about other products or services. If you do not want to receive this type of material, tell us and we will stop.

Will Otsana disclose your personal information?

Otsana may share information with organisations or subsidiaries associated with Otsana, that assist us to administer your investments or provide you with products and services including our internal and external service providers such as administrators,  financial institutions, fund managers and insurance companies.  The organisations receiving this information are not permitted to use your information for any purpose other than the specific purpose it was provided.

There are circumstances under which Otsana may disclose your personal information such as

• When the disclosure is required by law (for example, disclosed to the Australian Taxation Office, AUSTRAC or Centrelink);
• Authorised by law (such as where disclosure is necessary in the public interest or to protect our interests);
• In the event that we propose to sell our business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations.  Any such disclosures will be made in confidence.  In the event that a sale of our business is affected, we may transfer your personal details to the purchaser of the business.  As a client you will be advised of any such transfer.

We will also disclose your personal information if you give your consent for us to do so.

We do not sell mailing lists or provide client information to parties other than those noted above.

How does Otsana handle a request for access to personal information?

Under the Australian Privacy Principles you are generally entitled to access the information we hold about you. Where you are entitled to access, the time we require to give you access will depend on the type of information requested. If we can we will answer your question immediately.

We will also try to answer you in the same way that you ask, for example, if you telephone to ask for the information we will if practicable, give you that information over the telephone. We will generally respond to a written request in writing.

Sometimes we will ask that you put your request in writing, for example, where you want copies of material or access to older information or files which are not current or it is necessary for us to retain record of your request.

We may also ask you to identify yourself to our satisfaction.

There are certain conditions under which we may refuse you access to your personal information, such as when your request may unreasonably impact upon another person’s right to privacy. If we are entitled under the Australian Privacy Principles to refuse to give you access, we will tell you and provide reasons for our decision.

We will not charge a fee for making a request to access your personal information however we may charge a fee for accessing your personal information.  If a fee is applicable, we will disclose this to you prior to providing you with the information.

Storage and Security

We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure.  At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential.  Your personal information is generally held in your client file which may be in hardcopy or electronic.

In the event you cease to be a client of Otsana any personal information which we hold about you will be maintained in a secure offsite storage facility for a period of seven years in order to comply with legislative and professional requirements, following which time the information will be destroyed.  Otsana will ensure that any documents that are destroyed are done so in a secure manner.

Email Communication

As electronic communication becomes more and more part of our daily business lives Otsana will use your email address that you have provided to contact you when necessary or to provide you with information you have requested.

We will also use your email address to alert you to marketing initiatives, newsletters, or events that may interest you.

If at any time you decide you do not wish to receive such marketing information you have the right to ask us not to send you any further such material.  You may do this by advising your adviser or by sending us an email with “Unsubscribe” in the subject line.

Please allow two weeks for this instruction to take effect.

Website

Otsana’s compliance with the Australian Privacy principles also applies to your access to our website.  Our privacy policy may be accessed from the website and other information is also posted there for your convenience.

Our website uses cookies which allows us to identify your browser while you are using our site.  Whilst cookies do not identify you, they allow us to track usage patterns.  If you do not wish to receive cookies, you can instruct your web browser to refuse them.

If you have objections to the Privacy Policy, you should not access or use the Site.

What if some of the information Otsana holds is wrong?

Please tell us. We want our records to be accurate, complete and up to date and we rely on the accuracy of the information to provide you with appropriate recommendations. Unless we disagree with you about the accuracy, currency or completeness of a record, we will generally correct it if requested, (or suggest alternative arrangements for updating our records). If we disagree with you, we will give you our reasons and record your objections on file.

How do I make further enquiries or complain about a breach of privacy?

If you wish to complain about any breach or potential breach of this privacy policy or the Australian Privacy Principles, you should contact us and direct your complaint to the Privacy Officer. We will respond to your complaint within 7 days. We will use our best endeavours to resolve any complaint to your satisfaction; however, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.

Name: To the privacy officer
PO BOX 1974
WEST PERTH WA 6872
Telephone: +61 8 94867244
Email: OCADMIN@OTSANA.COM
Website: www.Otsana.com

Changes to this Privacy Policy

We reserve the right to review and amend this Privacy Policy from time to time but will advise you of any material changes.

Contacting us

Should you wish to make a general enquiry about our privacy policy, update the personal information we hold about you or obtain an application form for access to your personal information you can contact us by either writing to us or calling us.