Privacy Policy

YOUR PRIVACY COMES FIRST
Participant Capital  considers customer privacy to be a fundamental aspect of our relationship with clients. We are committed to maintaining the confidentiality, integrity, and security of our current, prospective and former clients' personal information. We have developed policies that are designed to protect this confidentiality, while allowing client needs to be served.

SOURCE OF INFORMATION
In the course of providing you with products and services and in our other dealings with you, we and certain of our service providers may obtain non-public personal information about you. This information may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from your transactions, from your brokerage or financial advisory firm, financial adviser or consultant, and/or from information captured on our internet websites. In some circumstances we may be required and authorized by law to collect your personal information, for example under the Anti-Money Laundering and Counter-Terrorism Financing Act.

PERSONAL INFORMATION WE COLLECT
We collect personal information including, but not limited to:

  • your full name, date of birth and gender;

  • your contact information (including address, phone number and email address);

  • any other information that may be obtained from your account application form;

  • information to verify your identity and comply with our anti-money laundering obligations.
     

It is up to you to choose the information that you give to us. If you choose not to provide us with particular information that has been requested, we may not be able to provide the service that you have requested.

HOW WE COLLECT AND STORE PERSONAL INFORMATION
Websites maintained by us or our service providers may use a variety of technologies to collect information that help us and our service providers understand how the website is used. Information collected from your web browser (including small files stored on your device that are commonly referred to as “cookies”) allow the websites to recognize your web browser and help to personalize and improve your user experience and enhance navigation of the website. In addition, we or certain of our service providers may use third parties to place advertisements for our products on other websites, including banner advertisements. Such third parties may collect anonymous information through the use of cookies or action tags (such as web beacons). The information these third parties collect is generally limited to technical and web navigation information, such as your IP address, web pages visited and browser type, and does not include other personally identifiable information such as name, address, phone number or email address. You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies. If you delete or reject cookies, some website pages may not function properly.

INFORMATION SECURITY
We aim to keep all personal information secure from any misuse, loss or unauthorized access, modification or disclosure. If we find that we have no further need for your personal information, we may remove it from our systems and destroy all record of it.

We take seriously the obligation to safeguard your personal information. In addition to this policy, we have implemented procedures that are designed to restrict access to your personal information to our personnel who need to know that information to perform their jobs. Physical, electronic, and procedural safeguards are in place to guard your personal information. We employ firewalls, encryption technology, and user authentication systems, where appropriate to assure the security of data.


USE OF PERSONAL INFORMATION
We may use your personal information for our business functions and activities, which may include the following:

  • communicate with you and provide you with information, products or services you have requested;

  • assist you by providing you with information and support;

  • manage and administer any account or product you hold with us, including processing transactions;

  • personalize and customize your experiences on our website;

  • conduct research for the purposes of improving existing products or services or creating new products or services;

  • promote and market our products and services, and products and services of our business partners, to you or provide you with information that we believe may be of interest to you. We will only use your personal information for this purpose if you have opted-in to receiving marketing communications from us and have not subsequently opted-out;

  • other purposes disclosed to you at the time of collection.


DISCLOSURE OF YOUR PERSONAL INFORMATION
As is common in the industry, Participant Capital engages non-affiliated companies to provide certain services, such as preparing and mailing investor correspondence including reports, account statements and other information and conducting research on client satisfaction.

We may disclose your personal information provided by you or gathered by us to other Participant Capital entities and non-affiliated third parties, as required or permitted by law or for one or more of the purposes described above. We may provide your personal information to:

  • your nominated financial advisory firm, your nominated financial adviser or their service providers;

  • Participant Capital's agents, professional advisers, contractors or our service providers.

  • Participant Capital's fraud prevention and tokenization service providers;

  • Government bodies, regulators or law enforcement authorities as required or authorized by law;

  • affiliated companies for purposes consistent with this Privacy Policy;

  • other non-affiliated third parties for one of the purposes described above.
     

We take reasonable steps to ensure that any third party we disclose your personal information to is bound by privacy obligations to protect information about you.

CHANGES TO POLICY; PERSONAL INFORMATION
We may change our Privacy Policy from time to time and will publish changes on our website.

If you would like to access the personal information we hold about you, obtain more information or make a complaint about the way we manage this information, you can do so by contacting investor.relations@participantcapital.com.

In the event of a complaint, we will strive to provide you with written notice of our response and any action we take in respect of your concern or complaint within 30 days, where possible. Please note that in certain circumstances, we may also need to consult another party in order to respond to you. If you are not satisfied with the outcome of our investigation in relation to our handling of personal information or an access or correction request relating to personal information you may take your complaint to the Privacy Commissioner.

You can also request that we correct personal information we hold about you if it is inaccurate, incomplete or out-of-date or request that we remove all personal information that we hold about you. Such request will be subject to any legal or regulatory requirement requiring us to retain such information as part of our business or otherwise in compliance with record keeping requirements. Please note that any request to remove your personal information may restrict, wholly or partly, our ability to provide or to continue to provide services to you.