Privacy Policy

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If you have any questions relating to this privacy statement or your privacy rights, please contact us. This Privacy Statement sets out the policy of ACY Capital for handling and protecting your personal information. We are committed to ensuring the privacy of your information and recognise that you, as a customer, are concerned about your privacy and about the confidentiality and security of information that ACY Capital may hold about you. This Policy is designed to inform customers of – - The ACY Capital Privacy Policy; - What information we collect and the purposes for which we collect it; - Use and disclosure of information collected; - Security of your personal information; - Gaining access to information we hold about you; - What to do if you believe the information, we hold about you is inaccurate; - Complaints in relation to privacy; and - How to contact us. ### 2\. Personal Information Personal information is information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. ACY Capital will also collect any personal information necessary for the purposes of complying with Anti-Money Laundering and Counter Terrorism Financing laws and regulations. ### 3\. Open and Transparent Management of Personal Information ACY Capital seeks to ensure that personal information we hold about an individual is managed in an open and transparent manner. We have implemented procedures to ensure compliance with applicable codes, and to deal with any complaints relating to our compliance therewith. ACY Capital has a clear and up-to-date privacy policy outlining our management of personal information, including details regarding the kind of personal information we collect and hold; how and why we collect and hold this information, and how an individual may access and seek correction of the information we hold about them. We further provide details regarding our complaints handling process, our policy on disclosure of information to overseas recipients (and if so, which countries). ### 4\. Collection of Personal Information ACY Capital predominantly collects personal information directly from individuals, although information may sometimes be provided by a client’s professional adviser on their behalf and with their consent. ACY Capital only collects personal information which is reasonably necessary for the provision of our services, and only by lawful and fair means. Information is generally sought through our account application forms, in which the purpose is articulated. Accordingly, we will always ensure you are apprised of our purpose in collecting information, and your right to gain access to such information. If you do not provide the information requested, we may be unable to provide you with our services. Please note that generally we will only use the personal information (e.g. postal address, e-mail address, telephone numbers, facsimile number, date of birth, bank account details, details related to the provision of verification and identification documentation) we collect for the main purposes disclosed at the time of collection such as to provide financial services. Where possible we will collect the information directly from you via our application form. We may also collect information about you from our website, but this information will only identify who you are if you provide us with your details (e.g. if you e-mail your contact details to us). When you visit our website 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 website; - 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 ACY Capital website may contain links to the websites of third parties. If you access those third- party websites they may collect information about you. ACY Capital does not collect information about you from the third parties. You will need to contact them to ascertain their privacy standards. ### 5\. 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 website. Cookies also allow us to provide you with more personalised service when using our website. ACY Capital may use cookies to: - determine whether you have previously used the ACY Capital website; - identify the pages you have accessed; and - 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 ACY Capital website. ### 6\. Email Address If you provide us with your e-mail address during a visit to our website, 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. ### 7\. Unsolicited personal information Where we receive personal information about an individual which is unsolicited by us and not required for the provision of our services, we will destroy the information (provided it is lawful and reasonable for us to do so). ### 8\. Notification of the collection of personal information When we obtain personal information about you, we ensure that you have our contact details and that you are aware of the collection of information and our purposes for doing so. As per above, we are unable to provide certain services if the requested information is not provided. We do not disclose your information to third parties, unless they are related entities or services providers, in which case they are required to conform to our procedures. ### 9\. Use and disclosure of personal information ACY Securities collects and holds personal information about an individual for the purpose of providing financial services. We collect this information with your consent as per our application form or other documentation, for the primary purpose disclosed to you at the time of collection. However, in some cases ACY Securities will use or disclose personal