In this policy, “us”, “we” or “our” means The Trading & Risk Education Company trading as The Full FX and its related bodies corporate, partnerships and joint venture entities.
This policy sets out:
- what is considered personal information;
- what personal information we collect and hold;
- how we collect, hold, use or disclose personal information;
- the purposes for which we collect personal information;
- what happens if we are not able to collect personal information;
- how to seek access to and correct your personal information;
- whether we disclose personal information outside Australia; and
- how to contact us.
We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (subject to exemptions that apply to us under that Act). However, due to the nature of some of our business activities, from time to time, we will handle personal information relying on the media exemption in the Act where appropriate. Where we do so, we will ensure that we comply with the Australian Press Council Privacy Standards. We may also rely on related bodies corporate, employee records and other exemptions in the Act. If you require more information on the collection and use of personal information in the course of journalism, please visit the Australian Press Council Privacy Standards at www.presscouncil.org.au/privacy-principles.
We may, from time to time, review and update this policy, including taking account of new or amended laws, new technology and/or changes to our operations. All personal information held by us will be governed by the most recent updated policy.
What is Personal Information
When used in this policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card or direct debit account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
What Personal Information Do We Collect and Hold
We may collect the following types of personal information:
- mailing or street address;
- email address;
- telephone number;
- job title;
- details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
- any additional information relating to you that you provide to us directly through our websites or indirectly through use of our website or online presence through our representatives or otherwise;
- information you provide to us through, customer surveys or visits by our staff.
We may also collect anonymous data (which is not personal information) relating to your activity on our websites (including IP addresses) via cookies, or we may collect information from you in response to a survey. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services. To the extent this information does not constitute personal information because it does not identify you or anyone else, the Australian Privacy Principles do not apply and we may use this information for any purpose and by any means whatsoever.
How We Collect Personal Information
We collect your personal information directly from you unless it is unreasonable or impractical to do so. We do this in ways including:
- through your access and use of our website;
- through someone else who has provided us with your information;
- during conversations between you and our representatives; and
- when you complete an application or purchase order.
We may also collect personal information from third parties including:
- mailing lists;
- contractors and business partners.
Why Do We Collect, Hold, Use and Disclose Personal Information
The primary purpose for which we collect information about you is to enable us to perform our business activities and functions and to provide the best possible quality of customer experience. We collect, hold, use and disclose your personal information for the following purposes:
- to provide products and services to you;
- to provide you with news, information or advice about our existing and new products and services;
- to communicate with you, including but not limited to, email or telephone;
- to manage and enhance our products and services;
- to personalise and customise your experience;
- to provide as part of business data to third parties if you have authorised us to do so;
- to conduct business processing functions for operation of our websites or our business;
- for our administrative, marketing (including direct marketing), promotional, planning, product/service development, quality control and research purposes, or those of our contractors or external service providers;
- to provide your updated personal information to us, our contractors or external service providers;
- to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
- as required or permitted by any law (including the Privacy Act).
What Happens if We can’t Collect Your Personal Information
If you do not provide us with the personal information described in this policy, some or all of the following may happen:
- we may not be able to provide you with the products or services you requested;
- we may not be able to provide you with information about products and services that you may want,; or
- we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
How Do We Disclose Your Personal Information
We may disclose your personal information to:
- our employees, related bodies corporate, partnerships, joint venture entities, contractors or external service providers for the operation of our websites or our business, fulfilling requests by you, and otherwise provide products and services to you, including without limitation, web hosting providers, IT systems administrators, mailing houses, newsagents, couriers, payment processors, photographic analysers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors and consultants;
- our existing or potential agents and/or business partners;
- our sponsors;
- specific third parties authorised by you to receive information held by us;
- the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary;
- as required or permitted by any law (including the Privacy Act).
Direct Marketing Materials
We may send you direct marketing communications and information about products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail or email, in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth).
In addition, at any time, you may opt-out of receiving marketing communications from us by contacting us (details below) or by using the opt-out facilities provided (e.g. an unsubscribe link), We will then ensure that your name is removed from our mailing list. We do not provide your personal information to other organisations for the purpose of direct marketing unless expressly authorised by you.
If you receive communications from us that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us using the details provided below.
Accessing and Correcting Your Personal Information
You may request access to any personal information we hold about you at any time by contacting us (details below).
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
How You can Complain about a Breach of Privacy
Disclosure of Personal Information Outside Australia
We may disclose personal information to our related bodies corporate, partnerships, joint venture entities and external service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We may disclose your personal information to entities located outside of Australia, including the following:
- our related bodies corporate partnerships and joint venture entities, located in the UK and the EU;
- our data hosting and Cloud-based IT service providers;
- other third parties operating in other jurisdictions including the United States where you have authorised us to do so.
We will take all reasonable steps to protect the personal information that we hold from misuse, loss or unauthorised access, including by means of firewalls, password access, secure servers and encryption of credit card transactions.
If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
Tracking and Targeting