This Privacy Policy applies to the collection, storage, use and disclosure by BFX Australia Pty Ltd (ABN 89 611 376 820) (BFX, we, us) of personal information in respect of individuals (you). It also provides information on how you can obtain access to, or seek correction of, your personal information. BFX is committed to the protection of personal information and has developed this Privacy Policy in line with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act).

You agree that providing us with your personal information as defined below implies your consent to the collection and use of your personal information in accordance with this Privacy Policy. We may change this Privacy Policy from time to time. BFX encourages you to periodically review this page for the latest information on our privacy practices. Your use of our website following any such change to our Privacy Policy will confirm your acceptance of the changes. You may request BFX to provide you with this Privacy Policy in hard copy.

1. Personal Information

Personal information is any information or opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in material form or not. Personal information commonly includes a person’s name, occupation, signature, residential address, email address, telephone number, bank account details, date of birth, passport number, driver’s licence number etc. (Personal Information)

2. Method of collection

2.1. BFX collects Personal Information when you:

• complete the form on the “Start Now” portal on the www.bfxaustralia.com.au website (Website)
• complete the BFX corporate registration form;
• send information in emails or correspondence to BFX;
• speak to a staff member of BFX.

2.2. BFX may access third party electronic databases to identify you and may collect Personal Information in this process. These databases may contain information about your creditworthiness, including consumer credit reports from a credit reporting body.

3. The type and scope of collection

3.1. Every visit to our Website and each inquiry made from our Website is logged by the IP address of the computer from which it was requested. This information is saved by us for internal system-related and statistical purposes. The following information is logged: the name of the inquirer, the date and the time of the inquiry, the IP address, the notification of a successful inquiry.

3.2. BFX is required to collect certain Personal Information for purposes of complying with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and related legislation (AML legislation). For all corporate clients (including without limitation, registered domestic and foreign companies, registered associations, registered cooperatives, trusts, partnerships, government bodies or other statutory bodies (Corporate Clients) this may include requesting Personal Information of individuals (being a natural person or persons) who ultimately own or control (whether directly or indirectly) the Corporate Client. Where such Personal Information is obtained from you or your authorised representative(s), you are taken to have informed such persons of its contents.

4. Purpose of Collecting Your Personal Information

4.1. The collection of Personal Information is required to enable us to provide our services and to ensure the highest quality of service provision. Individuals do not have to supply BFX with their Personal Information, however, if the individual chooses not to do so BFX may be unable to provide the services required or sought.

4.2. BFX collects Personal Information for the following purposes: • to provide its services and products and undertake associated business processes and functions;
• to process registration with BFX;
• to administer and manage registration with BFX;
• to identify you;
• to monitor, develop and improve the quality of its services;
• if you are registered with BFX, to send you information that is relevant to the provision of its services;
• to answer or process inquiries or complaints, and provide information or advice;
• to notify you of any products, services and benefits BFX provides and may be of interest to you;
• to comply with any law, rule or regulation or binding determination, or to cooperate with any governmental authority; and
• any other purpose disclosed to you at the time BFX collects your Personal Information.

5. Direct Marketing

BFX may use Personal Information for the purpose of direct marketing where you would reasonably expect BFX to use or disclose the information for the purpose of direct marketing, unless you have requested not to receive such direct marketing communications. At any time you may opt-out of receiving direct marketing communications through the unsubscribe function that will be made available with direct marketing communications that BFX sends. Alternatively, you may opt-out of receiving direct marketing communications by emailing us at accounts@bfxaustralia.com.au.

6. Storage and Security of Your Personal Information

6.1. From time to time we may hold Personal Information in any combination of data storage facilities, such as for example G-remit, GBG software, cloud computing facilities or paper based files which may be operated or held by us. We will use all reasonable endeavours to maintain the security of your Personal Information from unauthorised access, modification, or disclosure. We cannot ensure or warrant that your Personal Information will always be secure during transmission or protected from unauthorised access during storage therefore you provide your Personal Information to us at your own risk. Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your Personal Information held by BFX

6.2. Unless otherwise required by law, BFX will store Personal Information for a long as it is required to provide a service requested of BFX or to which you have given consent. BFX is obliged to retain information relating to personal identity for 7 years under relevant AML legislation.

7. Use and Disclosure of Your Personal Information

7.1. BFX will use and disclose Personal Information to third parties only for the purposes described below. You hereby consent to BFX making your Personal Information available:
• to BFX contractors or service providers to conduct our business and to provide our services or products to you, including web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
• to any partners, agents or intermediaries who are a necessary part of the provision of BFX’s products and services;
• to intermediary banks engaged by BFX in the processing of certain transactions; • to international intermediaries to complete transactions;
• to credit reporting bodies;
• to any government body that requests such information or is required by law to obtain such information, as for example the Australian Transaction Reports and Analysis Centre with regulatory responsibility under the AML Legislation;
• to our related bodies corporate (if any).Contacting you to ask you to provide feedback about the services.

7.2. Where practicable we will endeavour to collect, hold, use and disclose personal information for the purposes described above on a de-identified basis.

7.3. You acknowledge that your personal information is likely to be disclosed to overseas recipients referred to in paragraph 7.1 of this policy. The location of such overseas recipient will depend on the country to which the relevant transaction relates. The likely countries that your personal information may be sent to include countries in Europe, the Middle East, Asia and America. For a full list of countries to which your personal information may be sent please refer to [insert link to BFX webpage] or request such list from accounts@bfxaustralia.com.au. You expressly consent to BFX disclosing your personal information to recipients located outside Australia and you acknowledge in respect of such disclosure that a) you will not be able to seek redress under the Privacy Act, b) the overseas recipient may not be subject to any privacy obligations or to any principles similar to the Australian Privacy Principles, c) you may not be able to seek redress in the overseas jurisdiction; and d) the overseas recipient may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority

8. Access, Amendment and Deletion of Your Personal Information

8.1. We will use all reasonable endeavours to keep your Personal Information accurate, complete, up-to-date, relevant and not misleading. Please contact us to examine your Personal Information if required and we will provide a complete list of your Personal Information within a reasonable period of receipt of your request. You may contact us to amend any of your Personal Information that is inaccurate, incomplete or out-of-date or request that your personal information be deleted. We will amend or delete your records as requested within a reasonable period of receipt of notice. If applicable, any legal requirement on us to maintain certain records of your personal information shall prevail over any of your requests. BFX may require identification to be provided before releasing copies of Personal Information.

8.2. If you wish to examine or amend your Personal Information, please contact our privacy officer at:

accounts@bfxaustralia.com.au
or
BFX Australia Pty Ltd
Level 23, 52 Martin Place
Sydney New South Wales 2000

8.3. There may be circumstances which preclude BFX from providing access to some or all of your Personal Information. For example, those circumstances could include:

• the information may impact on the privacy of other individuals;
• the information is commercially sensitive evaluative information;
• the information is subject to solicitor-client or litigation privilege;
• BFX is prohibited by law from providing you with access; or
• the disclosure could reasonably be expected to threaten the safety, physical or mental health or life of an individual.

8.4. If BFX decides that it cannot grant you access to your Personal Information, or grant access in the manner requested by you, it will set out the reasons for its decision in writing and the mechanisms available to complain about the refusal.

9. Making a Complaint

If you have any concerns about how we manage your personal information, you may write to our Privacy Officer at accounts@bfxaustralia.com.au. We will reasonably endeavour to provide a response within 30 days of receipt of your complaint.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by writing to the OAIC at GPO Box 5218, Sydney NSW 2001. For further information about the OAIC, please visit www.oaic.gov.au.

10. Web Tracking

BFX and its marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyse trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. BFX may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. The use of such technologies is for a variety of purposes and may include

• to assist us in providing services to you;
• to allow you to change pages during your visit to our Website without having to reenter your password;
• to temporarily track activity on our Website;
• to determine whether you came to our site from a banner ad or an affiliated website; or
• to identify you when you visit the Website, to personalize the content of the Website for you and to assist you in carrying out transactions

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