Details of Sonray Capital Markets

Sonray Capital Markets
Level 25, 367 Collins Street
MELBOURNE VIC 3000

Telephone: 61 3 9993 9700

Facsimile: 61 3 9993 9799

email: info@sonray.com.au

Privacy Officer contact details

Chelsea Turner

Telephone number: 61 3 9993 9700
Facsimile number: 61 3 9993 9799

email: compliance@sonray.com.au

Sonray Capital Markets Group of related companies

(Sonray Capital Markets)

This privacy statement is made on behalf of Sonray Capital Markets (ABN 18 104 482 993). All references to “Sonray Capital Markets”, “we”, “us” or “our” in this policy are references to Sonray Capital Markets its related bodies corporate.

Our information handling policies

At Sonray Capital Markets we are committed to ensuring the privacy of your information. Sonray Capital Markets recognises that you, as a customer, are concerned about your privacy and about the confidentiality and security of information that Sonray Capital Markets may hold about you.

Sonray Capital Markets is committed to its privacy obligations under the National Privacy Principles contained in the Privacy Act 1988 (Cth). The Privacy Act and general law place strict requirements on us to treat any information that we hold about you as confidential. This privacy statement details how we manage personal information that we collect from you, its use and disclosure and your rights to contact us if you have any further queries about our managment of your personal information.

If you have any questions relating to this privacy statement please contact our Privacy Officer (contact details provided above).

Collection

The information we collect

The information we collect from you will depend on what services we provide to you and may include the following:

• your name, address and contact details;
• your e-mail address;
• your tax file number;
• Bank account details;
• details about your financial position which would include information about your assets and any debts you may have;
• details of any securities you have given us; and
• details of specific transactions.

To the extent required by the Privacy Act, Sonray will:

• Have measures in place to eliminate Tax File Numbers received
• Collect information by lawful and fair means
• Collect the information directly from you where it is reasonable and practical to do so
• Limit the collection of information to that which is necessary for us to perform one or more of our functions or activities
• Take reasonable steps to ensure that at or before the time of collecting your personal information, you are made aware of certain key matters, such as the purposes for which we are collecting the information, the organisations to which we would normally disclose information of that kind, the fact you are able to access the information and how to contact us

Where we collect information

In most instances information about you will be collected from you either in an application form, during an interview or from telephone contact.

We may also collect information about you from our web site but this information will only identify who you are if you provide us with your details (eg. if you e-mail your contact details to us or if you use a logon and password to access a particular service).

When you visit our web site our web server collects the following types of information for statistical purposes:

• your Internet service provider's address;
• the number of users who visit the web site;
• the date and time of each visit;
• the pages accessed and the documents downloaded;
• the type of browser used.

No attempt is made to identify individual users from this information.

The Sonray Capital Markets web site contains links to the web sites of third parties. If you access those third party web sites they may collect information about you. Sonray Capital Markets does not collect information about you from the third parties. You will need to contact them to ascertain their privacy standards.

Cookies

A cookie is a small text file placed on your computer hard drive by a web page server. Cookies may be accessed later by our web server. Cookies store information about your use of our web site. Cookies also allow us to provide you with more personalised service when using our web site.

Sonray Capital Markets uses cookies to:

• determine whether you have previously used the Sonray Capital Markets web site;
• identify the pages you have accessed;
• facilitate administration of the site and for security purposes.

Most web browsers are set to accept cookies but you may configure your browser not to accept cookies. If you set your browser to reject cookies you may not be able to make full use of the Sonray Capital Markets web site.

They do not identify you individually nor do they contain personal information about you, unless you have identified yourself or provided the information by, for example, opening an account or registering for an on-line service.

Uses and disclosure of information

We will only use or disclose the information collected about you for the purpose for which it was collected, for related purposes which you would reasonably expect us to use or disclose the information for, or where you have consented to us using or disclosing the information.

We may use your personal information to:

• open an account for you;
• maintain your account;
• process your investment application;
• enable us to assess any request from you for financial assistance;
• send research information to you;
• respond to any specific requests you may make of us;
• help us to assess products that may suit your financial needs;
• notify you of any products that may be of interest to you;
• audit and monitor the services we provide to you;
• update your personal files; and
• enable us to meet our obligations under law, for example, the Financial Transaction Reports Act 1988 (Cth) and Australian taxation laws.

We may disclose your personal information to:

• related companies within the Sonray Capital Markets group of companies when providing credit facilities, taking deposits and for marketing purposes;
• our agents, contractors or third party service providers to enable them to provide administrative and other support services to us; and
• where the disclosure is required by law, for example to government agencies and regulatory bodies as part of our statutory obligations, or for law enforcement purposes.

By using the website, you consent to the collection and use of information by Sonray Capital Markets. This privacy policy may change from time to time particulary as new rules, regulations and industry codes are introduced. If changes are made to our privacy policy we will post any changes on this page. This ensures that you are always aware of the information we collect, how we use it and under what circumstances we disclose it.

E-mail address

If you provide us with your e-mail address during a visit to our web site it will only be used for the purpose for which you provided it to us. It will not be added to a mailing list without your consent unless the mailing list is related to the purpose for which you provided your e-mail address to us. We may use your e-mail address, for example, to provide you with information about a particular service or respond to a message you have sent to us.

If you subscribe to one of our services and provide your e-mail address to us so that we may communicate with you through e-mail, we may also use your e-mail address to advise you of upgrades and changes to those services.

Sonray Capital Markets offshore offices and contractors

Sonray Capital Markets may send information about you to Sonray Capital Markets offshore offices that are responsible for approving credit facilities, processing transactions or providing administrative services. In such instances Sonray Capital Markets has taken reasonable steps to ensure that the information we send overseas has the same level of privacy protection as we provide here in Australia.

Sonray Capital Markets may use third party service providers to maintain some of our data systems and provide auxiliary services. We require any party that has access to personal information to conform to our privacy standards.

Direct marketing

We do not disclose information about you to third parties for marketing purposes.

Security and retention policies

Sonray Capital Markets is committed to ensuring the security of information that we hold about you. We take all reasonable steps to ensure that the information we hold about you is stored securely, whether in a physical or electronic form.

If you use the Internet to communicate with us, you should be aware that there are inherent risks in transmitting information over the Internet. Sonray Capital Markets does not have control over information while in transit over the Internet and we cannot guarantee its security.

Any personal information that we no longer require is destroyed. An exception to this may be where records are retained to comply with legal requirements.

Access and correction

We try to ensure that all information about you that we collect, use or disclose is accurate, complete and up-to-date.

You may at any time request access to personal information that we hold about you. If there is an error with our information or our information is incomplete, you can advise us and we will, if needed, correct or add information.

We will not charge you a fee for your access request but may charge you the reasonable cost of processing your request.

If you would like to request access to the information we hold about you, please contact our Privacy Officer (Chelsea Turner 03 9993 9700).

To the extent required by the Privacy Act, Sonray will take reasonable steps to protect the personal information that we hold from misuse, loss, unauthorised access, modification or disclosure; and destroy or permanently re-identify personal information that is no longer needed for any purpose that is permitted by the Privacy Act.

In the event you cease to be a client, any information we hold about you will be maintained and stored for 7 years in order to comply with legislative and regulatory requirements.

Disputes

If you have a complaint about our treatment of your privacy, please contact our Privacy Officer (contact details provided above). Our Privacy Officer will investigate your complaint and endeavour to resolve any issue to your satisfaction.

If we do not adequately answer your concerns, you have the right to make a complaint to the Privacy Commissioner. The Privacy Commissioner can be contacted by telephone on 1300 363 992.

Links to other websites

We are not responsible for the privacy practices or content of any other website that is linked to this website. It is your responsibility to investigate the privacy policies of those other sites.