Privacy Policy

Introduction 

This policy document applies to Vitti Capital Pty Ltd (ABN 13 670 030 145), CAR No. 001306367 of Point Capital Group Pty Ltd (AFSL 518031 ABN 41 625 931 900), collectively referred to as “us”, “we” or “our”, and to all of our authorised representatives who provide financial services on our behalf. 

We understand the importance of privacy to our customers and as such are committed to protecting your privacy and personal information.  

In our privacy policy, “personal information” has the same meaning as in the Privacy Act; 

(namely, information about an identifiable individual). 

This privacy policy has been created to set out how we will collect, hold, secure, use and disclose personal information about you, and rights you have to opt out of direct marketing, and access and correct your personal information Separate terms apply to residents of the EU and are set out towards the end of this document. 

From time to time this policy may be updated, with or without notice to you. Our most up-to-date version of this policy will always be available on our website and our authorised representatives’ websites. If unable to access the internet, a hardcopy of this policy can be provided to you free of charge by contacting us on the details below: 

compliance@pointcap.com.au 

The Privacy Officer 

Point Capital Group Pty Ltd 

GPO Box 673 

Sydney NSW 2001

You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy. If you do not consent to this, or if you wish to withdraw your consent you can do this by contacting the Privacy Officer via the contact details listed above.

What personal information we collect 

Clients and prospective clients: 

Personal information is collected by us when you either enquire about our service or when you use our products and/or services. The types of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

  • personal details such as your name, e-mail, date of birth, postal address and other contact details;
  • (To the extent applicable) information about your employer or an organisation who you represent;
  • (To the extent applicable) your professional details; and
  • any additional personal information you provide to us, or authorise us to collect, as part of your interaction with us.

Prospective employees or applicants 

We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you. 

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions which involve working with children). 

Other individuals 

We may collect personal information about other individuals who are not clients. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to us, and other individuals who interact with us on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with us. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you. 

If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.

Visitors to our websites 

The way in which we handle the personal information of visitors to our websites is discussed below. 

How we collect your personal information 

Personal information will be collected directly and indirectly. Personal information obtained directly from you will mostly be collected by telephone, when you subscribe for our services online, when you email us, over the internet or social media, via our website or in person. 

We will not collect any information that you have not voluntarily provided to us or that we do not believe has been authorised for release to us by a third party. 

When we collect personal information about individuals from various third parties, we must make the individual aware that we have collected such information and from where it was sourced unless impracticable.  The sorts of third parties we may collect personal information from include our authorised representatives, third party referrers and organisations that provide services to you. We will take all reasonable steps to ensure the information we collect and use is accurate, up to date and complete 

Any unsolicited information about you, provided to us by you or any third parties will be purged from our systems. 

If you refuse to provide us with personal information, we may not be able to offer you our products and services or deal with you any further. 

Why we collect your personal information 

Quite simply, we collect and retain your personal information as reasonably necessary to carry out our business, identify you and to provide you with our services. Collection of much of this information is to ensure we meet our legal and regulatory requirements. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing 

client relationships. 

The way your personal information may be used depends on the nature of your interaction with us, but may include responding to requests for information and other general inquiries,  to open and maintain an account, communicate with you on products and services you may use, to send you information on other products and services, researching, developing and expanding our services, recruitment processes, training staff, contractors and other workers, responding to complaints, responding to regulatory enquiries, or other legal orders and obligations. 

We will only collect information about you that enables us to perform our business functions and activities.  

How your information is kept secure 

We are committed to the secure storage and use of your personal information. All information is stored on a third-party server which is regularly maintained by our IT contractors. Our IT systems have the appropriate safeguards in place to protect your information. Access to personal information stored on our systems is strictly limited to personnel who have been authorised to access it. We take reasonable steps to protect your personal information from misuse, interference, and loss and from unauthorised access, modification, or disclosure. 

Information that we no longer deem necessary or is not legally required for us to retain is destroyed. We review our files on a regular basis to identify any such information. 

Direct marketing 

We may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you.  If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us via our website or contacting the Privacy Officer whose details have been provided earlier in this document. 

If you opt-out of receiving marketing material from us, we may still contact you in relation to our ongoing relationship with you. 

We do not trade, rent or sell personal information to third parties for marketing purposes. 

Disclosure 

Domestic 

During the normal course of business, it may be necessary to share your personal information with third parties within Australia. These entities may have a direct or indirect relationship with us relating to our business functions. Some examples could include:

  • our employees, contractor’s representatives and authorised representatives that provide services on our behalf
  • Third-party providers of products or services that you have requested
  • Third-party identification verification systems and services
  • For provision of any services that we outsource to third parties, including information technology services and support, website maintenance/development
  • Our insurers, auditors, contractors, or agents
  • Stock exchanges
  • Share registries
  • Options clearing house

We may also be required to disclose your information by law. An example of this could be to the Australian Taxation Office (ATO), Australian Securities and Investments Commission 

(ASIC) or to a law enforcement agency. 

Overseas 

From time to time we may need to transfer your personal information to third parties outside Australia, such as UK and Europe. If the third party is not subject to or does not comply with equivalent privacy laws, we will seek your consent prior to doing so, unless where the APP does not require us to do so.

Third parties that we may disclose your information to may be a service provider that performs certain functions of its business overseas. Another could be if you have an international portfolio that is held by an overseas custodian. 

Rights and choices 

Anonymity and pseudonyms 

Where lawful and practical we will allow customers to deal with us without requiring them to specifically identify themselves.  This will usually be limited solely to providing simple product quotations and general queries. Generally, it is not practicable, and in some cases not lawful for us to deal with individuals anonymously or pseudonymously on an ongoing basis. 

Accessing your information 

At any time, you may contact us to submit a subject access request for the information we hold about you. In some circumstances there may be a legal or administrative reason for why we cannot approve your request. If we are unable to approve your subject access request, you will be provided with the reasons why. Subject access requests can only be made for personal information you have provided us and will not include any of our record keeping that has been created by us. 

Whilst we will not charge you for making a subject access request for your personal information, we may charge you a reasonable fee to compensate us having to collate and make the information available (if you are not a resident of the EU). 

All requests must be made to the Privacy Officer whose details have been provided earlier in this document. 

Correcting your information 

You have the right to rectify (i.e. correct) your personal data should you believe it is inaccurate, misleading, or incomplete. Once we verify the information, we will ensure it is corrected. If we deem your information to be inaccurate, we may refuse your request to amend it. In this unlikely event we will advise you of our decision and our complaints policy. 

To avoid any incorrect or out of date information, we ask that you advise us of any change in circumstance which may render your information incorrect or inaccurate. This may be a change of address, telephone number or surname. 

All requests must be made to the Privacy Officer whose details have been provided earlier in this document. 

Where we receive information about others from you 

If you provide us with personal information about someone else, you must ensure that you have their consent to do so (including their consent for contacting them), so that, without us taking any further steps required by applicable data protection or privacy laws, we may collect, use and disclose such information for the purposes we have described in this policy. 

This means you must take reasonable steps when providing personal information so that the individual concerned is aware of and/or consents to this policy, including that:

  • their personal information is being collected;
  • the purposes for which that information is being collected;
  • the intended recipients of that information;
  • the individual’s right to obtain access to that information; and
  • our identity, and how to contact us.

Adoption, use or disclosure of government assigned identifiers 

Although at times we might request details regarding certain government assigned identification numbers, we will only do so where it is necessary and lawful, for example: 

  • To the trustee of any superannuation fund to which we contribute on behalf of employees,
  • To the Tax Office in relation to the preparation of group certificates or tax stamps sheets under the PAYE/PAYG system.

Using our website 

You should be aware that there are risks associated with sharing information over the internet.

When you visit our website your web browser may send requests to our server for web pages and/or other content. These requests are recorded and provide us with information such as your IP address, Internet Service Provider, and geographic location. We use this information purely to assess the performance of our website. This information is not used to try and identify you. 

Any provision of data or collection of data on any external website that you may visit using the hyperlinks on this website is not covered by this privacy policy. 

Cookies 

We may use cookies when you are on the website. Cookies are small blocks of text stored on your device. They allow us to recognise you (or rather, your internet browser) as you move around our site, and if you return to our site later. Cookies cannot read your hard drive or command your computer to perform any action.

Cookies may be used for security to help us identify you, to provide you with personalised features and for tracking traffic on our site. Any information we collect and share with thirdparties through cookies is aggregated and therefore anonymous (when shared with third parties, it does not include personal information which is likely to identify you). 

You can prevent new cookies from being installed and delete existing cookies. The procedure depends on which browser you are using. For information on how to remove cookies check your internet browser. You may be unable to access certain pages on our website unless you accept cookies

General Data Protection Regulation (GDPR) For the European Union (EU) 

If we know that you are based in the EU, we will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.

We will only collect personal information with your express consent for the purpose of providing services to you and any data collected will be to the extent necessary and not excessive for its purposes. We will not collect or process any personal information that is considered “Sensitive Personal Information”, and we will not knowingly collect or process personal information from a person under the age of sixteen.

We will also process personal information if it is necessary for our legitimate interests, or to fulfill a contractual or legal obligation.  Except as otherwise provided in the GDPR, individuals based in the EU have the following rights: 

Request free access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.  

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.  

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.

You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing. 

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object if we were ever to process your personal information for direct marketing purposes. 

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 

Request the transfer of your personal information to another party. 

How to make a complaint 

If you have a complaint about how we have handled your personal information you should inform us in writing, as required by the Privacy Act. All complaints should be addressed to the Privacy Officer whose details have been provided earlier in this document. We suggest you retain a copy of the complaint and all correspondence in relation to the complaint. 

Once the Privacy Officer receives your complaint you will receive a written response within thirty (30) days. We are committed to resolving disputes through our complaints handling process. If you are not satisfied by the outcome, then you have the right to contact the Office of the Australian Information Commissioner (OAIC). 

This Privacy Policy was last updated on [4/01/2021] and is version number [2]