Privacy Policy

Privacy Policy

Windsor Capital Holdings Pty Ltd(ABN [Insert Windsor Capital Holdings Pty Ltd ABN]) is a corporate authorisedrepresentative (CAR No. 001320479) of FB Corp Limited (ABN 16 675 876 490)(AFSL 557810) ("we", "us", "our").

We are bound by the Privacy Act1988 (Cth), its Amendment (Enhancing Privacy Protection) Act, and its PrivacyAmendment (Notifiable Data Breaches) Act, and will protect your personalinformation in accordance with the Australian Privacy Principles (APPs). Theseprinciples govern how we can collect, use, hold and disclose your personalinformation, and how we respond when a data breach (including cyber and datasecurity breaches) is likely to result in serious harm to any individuals whosepersonal information is involved in the breach.

This Privacy Policy applies toany stakeholders we engage from time to time, and is included on our websitehomepage under the title 'Privacy Policy'.

It is important that allstakeholders read this policy, together with any privacy related information wemay provide on specific occasions when we are collecting or processing personalinformation about a stakeholder, so that they are aware of how and why we areusing this information.

What kinds of personal information do we collect and hold?

When you speak to us about ourprovision of financial services to you (for example, financial advice orapplying for an interest in a fund), we may collect information that isnecessary to be able to provide you with financial services. For instance, we mayask for identification information such as your name, address, and date ofbirth. Any unsolicited personal information we may collect will be promptlydestroyed.

Why do we collect, hold, use and disclose personal information?

The main reason we collect, use,hold and disclose personal information is so we can service your request forfinancial services. This may include:

●     Checking your eligibility for our financial services;

●     Providing you with financial services; and

●     Helping you manage our financial services.

How do we collect personal information?

We collect most personalinformation directly from you. Sometimes we collect personal information aboutyou from other people such as publicly available sources of information.

How do we hold personal information?

Much of the personal informationwe hold will be stored electronically and securely by us at the offices of thefund administrator. We use a range of security measures to protect the personalinformation we hold.

Who do we disclose your personal information to, and why?

Sometimes we may disclose yourpersonal information to organisations outside our operations. For example, withthe administrator of a fund, so that it may perform its duties for the fund andour financial services.

What is an eligible data breach?

In accordance with theNotifiable Data Breaches scheme under the Privacy Act, we (along with ourservice providers) are required to notify you of any unauthorised access,disclosure or loss of personal information.

In these circumstances, weperform an assessment to determine if there has been an 'eligible data breach'.To do so, we consider if the access or disclosure of personal information islikely to result in serious harm to the individuals affected by the suspecteddata breach.

If we determine there has beenan 'eligible data breach', then you will be notified as soon as practicable. Wewill notify the affected party with the details of the breach and therecommended steps to take to mitigate any concern. As required, we will reportan 'eligible data breach' to the Office of the Australian InformationCommissioner (OAIC).

In summary, subject to certainexemptions, the scheme requires us to:

●     carry out a reasonable and expeditious assessment ifthere are reasonable grounds to suspect that there may have been an eligibledata breach (and to take reasonable steps to complete that assessment within 30days); and

●     make the prescribed notifications (to the OAIC, and ifpracticable, to affected individuals) as soon as we are aware that there arereasonable grounds to believe that there has been an eligible data breach. Thenotifications must include a description of the data breach, the kinds ofinformation concerned and recommendations about the steps individuals shouldtake in response to the data breach.

Who do we notify when there is a data breach of your personal information?

We are obliged to notifyindividuals whose personal information is involved in a data breach that islikely to result in serious harm (i.e. 'eligible data breaches'). Thisnotification must include recommendations about the steps individuals shouldtake in response to the breach. The OAIC must also be notified of eligible databreaches.

Do we disclose personal information overseas?

We may disclose your personalinformation to recipients located outside Australia. These entities may includeour service providers.

Do we use or disclose personal information for marketing?

We may use your personalinformation to offer you further financial services that we believe mayinterest you. We will not do this if you tell us not to.

If you don't want to receivemarketing offers from us, please contact us on the details listed at 'Contactus'.

Access to and correction of personal information

You can request access to thepersonal information we hold about you. You can also ask for corrections to bemade. To do so, please contact us on the details listed at 'Contact us'.

Resolving your privacy concerns and complaints — your rights

If you are concerned about howyour personal information is being handled or if you would like to make acomplaint, please contact us on the details listed at 'Contact us'.

If you are not satisfied by ourresponse to an error or complaint about our privacy practices, you may refer tothe OAIC (see www.oaic.gov.au).

Contact us

If there is anything you wouldlike to discuss, please contact us. If you have any questions or concerns aboutour privacy policy or practices, please contact us at:

●     1300 346 782

●     info@windsorcapital.com.au

●     Level 14, 333 Collins Street Melbourne VIC 3000

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This information is providedfor information only. It does not constitute an offer or invitation to enterinto any legal agreement of any kind of financial services.

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