Privacy Policy

OUR PRIVACY POLICY

At Westar Capital Ltd we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth).
This Privacy Policy describes our current policies and practices in relation to the collection, handling, use and
disclosure of personal information. It also deals with how you can complain about a breach of the privacy laws, how
you can access the personal information we hold about you and how to have that information corrected.

What personal information do we collect, hold and how do we use it?

When we advise you about your financial affairs we ask you for the information we need to understand your financial
situation, needs and objectives. This can include a broad range of information ranging from your name, address,
contact details and age to other information about your personal affairs including your assets, liabilities, financial
situation and health. We provide any information needed to those with whom we deal with, on your behalf, to
implement your financial, investment and insurance strategies and or manage your financial affairs.

We also use your information to enable us to manage your ongoing requirements, e.g. financial affairs, our related
entities services and or our relationship with you, e.g. invoicing, additional services, client surveys etc. We may do
so by mail or electronically unless you tell us that you do not wish to receive electronic communications.

From time to time we will use your contact details to send you direct marketing communications including offers,
updates, events, articles or newsletters that we think will be of interest to you. We may also send you regular
updates by email or by post on financial, investment, insurance and finance matters. We always give you the option
of electing not to receive these communications in the future. You can unsubscribe at any time by notifying us and
we will no longer send this information to you.

We may also use your information internally and or share it with our related entities to help us improve and provide
our services to you and help resolve any problems.

What if you don’t provide some information to us?

We can only fully advise you about your financial affairs if we have all the relevant information. If you do not provide
us with some or all of the information that we ask for, we may not be able to advise or assist you.

You can contact us without using your name or by using a pseudonym. However, we may need your name or contact
details to respond to you.

How do we store/hold and protect your personal information?

We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information
we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably
necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or
document retention requirements.

We hold the information we collect from you in our client files, on our internal computers and servers. Our
information technology service providers may use external servers for offsite backup and we may keep external
hard-drives stored offsite. In some cases, your file is archived and sent to an external data storage provider for a
period of time.

We ensure that your information is safe by limiting access to your data to authorised personnel only with password
login access to electronic files. We maintain physical security over our paper and electronic data and premises, by
using locks and security systems.

Web and Mobile Data

We may collect personal and other information from you directly or via your use of our services on our web pages.
We will only collect personal information which is reasonably necessary for, or directly related to, our functions or
activities.

Our website may also contain links to the websites of other third party providers of goods and services (Third Party
websites). If you have accessed Third Party websites through our websites and if those third parties collect
information about you, we may also collect or have access to that information as part of our arrangements with those
third parties.

Whether you access a Third Party website from our website, cookie information, information about your preferences
or other information you have provided about yourself may be shared between us and the third party.

Other data

We may use technology such as cookies, beacons, tags, scripts and tracking pixels to collect, store and use anonymous
data about how you use our website / mobile technology. This includes your server address, the date and time of
your visit, the pages and links accessed, the type of browser used and other information about your browsing
activities. This data is used to increase functionality and can also enable us to display information and content that is
tailored to our understanding of your interests. This information alone cannot be used to discover your identity.

We may collect personal and other information from you directly or via your use of our services on our web pages.
We will only collect personal information which is reasonably necessary for, or directly related to, our functions or
activities.

Our website may also contain links to the websites of third party providers of goods and services (Third Party
websites). If you have accessed Third Party websites through our website and if those third parties collect
information about you, we may also collect or have access to that information as part of our arrangements with
those third parties.

Where you access a Third Party website from our website, cookie information, information about your preferences
or other information you have provided about yourself may be shared between us and the third party.

Disclosure to overseas entities – We do not generally disclose personal information obtained from cookies to
overseas entities in the course of our activities.

Anonymous data – We may use technology to collect anonymous information about the use of our website, for
example when you browse our website our service provider may log your server address, the date and time of your
visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use
this information for statistical purposes and to improve the content and functionality of our website, to better
understand our clients and markets and to improve our services.

Cookies – In order to collect this anonymous data we may use “cookies”. Cookies are small pieces of information
which are sent to your browser and stored on your computer’s hard drive. Sometimes they identify users where the
website requires information to be retained from one page to the next. This is purely to increase the functionality
of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your
computer and you can set your browser to notify you when you receive a cookie so that you can decide if you want
to accept it. Once you leave the site, the cookie is destroyed and no personal or other information about you is
stored.

Will we disclose the information we collect to anyone?
We do not sell, trade, or rent your personal information to others. We may disclose your information to recipients
in the United States of America for the purpose of required transaction notifications (E.g. Form W-8 BEN). We may
also store your information in the ‘cloud’ for the purposes of data storage and file backups. These ‘cloud’ service
providers may be in countries not regulated by laws, which protect your information in the way that is similar to the
Privacy Act. If a recipient is not regulated by laws, which protect your information in a way that is similar to the
Privacy Act, we will seek your consent before disclosing your information to them. We will not be accountable for
any recipient’s breach of Australian privacy laws and you will not be able to seek redress under those laws.

We will disclose your information to any lenders or service providers that you choose to deal with and may need to
provide your information to contractors who supply services to us, e.g. to handle mailings on our behalf, external
data storage providers or to other companies in the event of a corporate sale, merger, reorganisation, dissolution
or similar event. However, we will take all reasonable steps to ensure that they protect your information in the
same way that we do.

We may provide your information to others if we are required to do so by law or under some unusual other
circumstances which the Privacy Act permits.

How can you check, update or change the information we are holding?

If you wish to access or correct your personal information, please write to us and contact our Privacy Officer.

Upon receipt of your written request and enough information to allow us to identify the information, we will disclose
to you the personal information we hold about you. We will also correct, amend or delete any personal information
that we agree is inaccurate, irrelevant or out of date.

We do not charge for receiving a request for access to your personal information or for complying with a correction
request.

In some limited cases, we may need to refuse access to your information or refuse a request for correction. We will
advise you as soon as possible after your request if this is the case and the reasons for our refusal.

What happens if you want to complain?
If you have any concerns about whether we have complied with the Privacy Act or this Privacy Policy when collecting
of handling your personal information, please write to our Privacy Officer.

Your complaint will be considered by us through our internal complaints resolution process and we will try to
respond with a decision within 30 days of you making the complaint.

Your consent
By asking us to assist with your financial affairs and needs or accessing our web pages, you consent to the collection
and use of the information you have provided to us for the purposes described above.

Updating this policy
This Privacy Policy was prepared on 21 February 2023. We may update it at any time. The new version will be
published on our website.

Tell us what you think
We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact
us.

Westar Capital Limited

Last Updated February 2023

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