Frazis Capital Partners is committed to protecting your privacy and the confidentiality of your personal information and sensitive information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).
1. What kinds of information do we collect and/or hold?
What kinds of information do we collect?
- The types of personal information that Frazis Capital Partners, or a third party contractor, may collect and hold includes the following:
- full name, postal address, e-mail address, telephone and fax numbers;
- date of birth, gender and marital status;
- bank account details and credit card details;
- any other information you provide to us by any means; and
- information associated with web browsing, such as your IP address.
- Generally, the kinds of information that Frazis Capital Partners will collect and/or hold will depend on the kind of project or development we are concerned with – essentially, the purpose of the activity we are conducting. Accordingly, the kinds of information we record will usually simply extend to your name, applicable contact details and minimal financial details (such as your tax file number).
- On occasion we may collect and/or hold other kinds of information – such as when we run a promotional event or a competition. When we do this, we will disclose our intention to do so to you.
- Further, the kinds of information we collect and/or hold may extend to other things, such as the composition of your family, marital status and/or your specific needs or interests. For example, with respect to a housing development, this may include the number of rooms you require, the location of the house with respect to educational facilities and the availability of parking.
- At all times, Frazis Capital Partners will take reasonable steps to inform you of the kinds of personal information it collects and holds when you are engaged with it, and how this may vary from project to project.
What kinds of information can we hold?
- We are permitted to collect and/or hold, with your consent, the following kinds of information:
- Personal information, being information or an opinion about an identified individual, or an individual who is reasonably identifiable.
- Sensitive information, being information or an opinion about an individual’s personal preferences or characteristics (such as race, ethnicity, political views, memberships, religious or philosophical beliefs and sexual preference), health information and/or biometric information.
- Sensitive information is afforded a higher level of protection than other kinds of information under the Privacy Act. We collect and hold sensitive information only when you knowingly and voluntarily submit it. We will rarely collect and hold this kind of information.
2. How do we collect your personal information and how do we hold it?
How do we collect your personal information?
- Frazis Capital Partners may collect personal information from or about you in a number of circumstances, including:
- from publicly available sources of information;
- when you use our services or contact us directly;
- when you sign up to receive information from us;
- when you use our website and/or via software, such as cookies and web/tracking pixels (also known as “web beacons”);
- when you provide or offer services to us;
- from a third party entity engaged to collect the personal information from you on behalf of Frazis Capital Partners;
- from our own records at Frazis Capital Partners; and
- when legally required to do so.
Means of collection
- We will only collect your personal information when the information is reasonably necessary for, or directly related to, one or more of Frazis Capital Partners’s functions or activities.
- We will only collect your sensitive information when you consent to the collection of the information and the information is reasonably necessary for, or directly related to, one or more of the Frazis Capital Partners’s functions or activities.
- Frazis Capital Partners will, at all times, take reasonable steps to collect your personal information directly from you, unless:
- it is unreasonable or impracticable for us to do so; or
- we have contracted with a third party entity to collect the information from you and to store the information for us; or
- you consent to the collection of the information from someone other than you; or
- we are required or authorised by or under an Australian law, or a court/tribunal order, to collect the information from someone other than you.
- In the event we receive your personal information from a third party, via referral and/or via a purchase list, we will take reasonable steps to inform you of that and seek your consent to our collection of that information. Should you refuse to consent to that collection, we will take reasonable steps to destroy or de-identify that information.
What are cookies?
A cookie is a small text file stored on your computer’s browser. Many cookies from websites will be visible from your browser. You will usually find information on cookies and how to manage them under “options” or “settings” in your browser. You can choose to see cookies before deleting them and to keep cookies from some sites.
There are several different types of cookies (some of which are used on Frazis Capital Partners’s website):
- First party cookies: A “first party” cookie is sent from a website to your web browser when you visit that site. This is how websites “record” or “remember” things like your customised settings (such as your location), your shopping cart contents and your log in details.
- Temporary cookies: Temporary cookies generally only last for one browsing session (until you close your web browser).
- Persistent cookies: Persistent cookies remain on your computer after you close your browser and will be sent back to the applicable website each time you visit it.
- Tracking / web pixels (also known as “web beacons”): Tracking pixels are clear picture files used to keep track of your navigation through a single website or a series of websites. Tracking pixels are normally used by websites that use third party traffic monitoring and tracking services.
- Local Stored Object cookie or “flash cookies”: Flash cookies contain more information than the other kinds of cookies referred to above and are not generally cleared when you clear cookies in your web browser.
- your server address;
- your top-level domain name (eg. .com, .gov, .uk, etc);
- the date and time of your visit to Frazis Capital Partners’s site;
- the pages accessed and documents downloaded by you;
- the previous site(s) visited by you; and
- the type of browser used by you.
Most of the information collected by cookies will not be sufficient to identify you – this is because the information collected will be very “general” in nature, relating to your interests (i.e. the products you have looked at) and the websites you have visited previously. Information collected via cookies will only be deemed to be “personal information” for the purposes of the Privacy Act or the Australian Privacy Principles if it makes you or any other individual reasonably identifiable.
Frazis Capital Partners will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through any cookies, tracking/web pixels or Google advertising products or features, unless it has robust notice of and the relevant party’s consent to that merger.
Third party cookies
- Third party cookies are sent by different organisations (such as businesses which provide content such as advertising) to the owner of the website you are visiting – so in this instance this means by organisations other than Frazis Capital Partners.
- Third party cookies are used on Frazis Capital Partners’s website to enable remarketing and reporting for impression assisted visits, website conversions, user demographics and user interests.
- The third party cookies we may use on our website include (but are not limited to):
- Google Analytics: Frazis Capital Partners uses Google Analytics, a web analytics service provided by Google Inc. Reports obtained from Google Analytics are used to help improve the efficiency and usability of Frazis Capital Partners’s website.
Google will use the information transmitted to it for the purposes of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may transfer this information to third parties where it is required to do so by law or where such third parties process the information on Google’s behalf.
- Google Analytics Advertising Features: Frazis Capital Partners also uses Google Analytics Advertising Features. By enabling the Advertising Features, Frazis Capital Partners enables or permits Google Analytics to collect data about the traffic to Frazis Capital Partners’s website via the use of Google advertising cookies and identifiers, in addition to the data collected through the standard Google Analytics feature.
The Google advertising cookies are used to, among other things, select advertising for users based on what is relevant to them, to improve reporting on campaign performance and to avoid showing ads the user has already seen.
- YouTube: We embed videos or insert links to videos from YouTube from time to time on our website. As a result, when you visit a page with content embedded from or linked to YouTube, you may be presented with cookies from these websites.
- Facebook tracking / web pixel: The Facebook tracking / web pixel is a piece of code provided by Facebook that is placed on or within a website to alert Facebook when a “conversion” is complete – that is, when a party clicks on a Facebook advertisement and then connects with website(s) of the party responsible for the advertisement.
For example, if an e-commerce company wishes to pay affiliates based on how many items are purchased on their site, they would need some way to correlate the purchases on their site with the advertisements that were viewed or clicked on the affiliate site – the pixel enables the e-commerce company to do this.
Frazis Capital Partners makes use of this tracking / web pixel to run and facilitate the campaigns and competitions it runs via Facebook. The tracking / web pixel allows Frazis Capital Partners to track the “conversions” that happen as a result of Frazis Capital Partners’s Facebook advertisements.
How can I manage, reject and/or delete cookies?
- If you want to control or opt out of the operation or application of Google Analytics and/or the Google Analytics Advertising Features, you should refer to Google’s guide(s) on opting out of those features at:
Frazis Capital Partners records all information posted to its social media pages and uses that information for the purposes of administering the pages, for record keeping, for considering and/or addressing any comments made and for running competitions and campaigns. No attempt will be made to further identify social media subscribers except where requested and authorised by law.
Notification of collection
- Frazis Capital Partners will take reasonable steps to provide this notification before, or at the time it collects your personal information. If it is not possible for it to do so, Frazis Capital Partners will take reasonable steps to provide notification as soon as practicable after collection.
- If you choose not to provide certain personal information to us, we may not be able to provide you with access to parts of the Frazis Capital Partners website or to certain content, products and services available on the Frazis Capital Partners website or generally from Frazis Capital Partners.
How do we hold and store your information?
- At this stage in time, Frazis Capital Partners does store personal or sensitive information through a third party local data storage cloud based system.
- When and where Frazis Capital Partners receives unsolicited information, Frazis Capital Partners will determine whether it could have collected the information under Australian Privacy Principle 3 (which governs the collection of solicited personal information). Where Frazis Capital Partners could not have collected the information consistent with Australian Privacy Principle 3, Frazis Capital Partners will destroy or de-identify the information as soon as practicable, so long as it is lawful and reasonable for it to do so.
Dealing with us via pseudonym or anonymously
- In most circumstances, it will not be possible or practicable for Frazis Capital Partners, in the course of conducting its activities, to deal with individuals who have not identified themselves or who have used a pseudonym.
- Frazis Capital Partners is required and/or authorised under Australian law, in certain circumstances, to deal only with individuals who have identified themselves.
- However, on the expiry of the purpose for which certain information was collected and/or on the request of the individual the subject of the information, Frazis Capital Partners will take reasonable steps to de-identify that information through the use of pseudonyms and/or to make the applicable personal details anonymous.
3. The purpose of our collection, holding of, use or disclosure of personal information
How and in what circumstances will Frazis Capital Partners use or disclose my personal information?
- Frazis Capital Partners may, in certain circumstances, collect, hold, use and/or disclose your personal and/or sensitive information.
By way of a guide, these terms are defined as follows in section 6 of the Privacy Act and in the Australian Privacy Principles Guidelines:
An entity “holds” personal information “if the entity has possession or control of a record that contains personal information”.
An entity “uses” personal information “where personal information is handled, or an activity is undertaken with the information, within the entity”.
An entity “discloses” personal information “when it permits that information to become known outside the entity and releases it from its effective control”.
- Frazis Capital Partners will use and disclose your personal information to provide our services to you or to fulfill administrative functions associated with these services. In general, we will use and disclose your personal information for any purpose for which the information was provided, or any related purpose.
- Frazis Capital Partners will disclose personal information when it permits that information to become known outside Frazis Capital Partners and where it releases it from its effective control. For example, Frazis Capital Partners would be said to have disclosed your personal information where:
- it shares you personal information with another entity;
- it publishes your personal information on the internet so it is accessible by others;
- where one of its staff reveals your personal information in the course of a conversation with a person who does not work for Frazis Capital Partners; or
- where one of its staff members sends a document containing your personal information to someone who is not you.
Primary purpose and secondary purposes
Definition pursuant to Australian Privacy Principles Guidelines:
Primary purpose refers to the particular purpose for which the information in question was collected.
Secondary purpose is any purpose other than the primary purpose for which we have collected your personal information.
- We will only make use of or disclose your personal information for a secondary purpose if:
- you have consented to the use or disclosure of that information; or
- you would reasonably expect Frazis Capital Partners to use or disclose the information for the secondary purpose; or
- the use or disclosure of that information is required or authorised by or under legislation or court/tribunal order; or
- a “permitted general situation” exists in relation to the use or disclosure of the information by Frazis Capital Partners; or
- Frazis Capital Partners reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
- In the event Frazis Capital Partners discloses information pursuant to clause 33(e), Frazis Capital Partners will make a written record of the use or disclosure.
- When collecting your information we will inform you of the primary purpose of our collection and/or any anticipated secondary purpose that may arise. The purpose of our collection will vary from project to project, depending on the nature of the project and the nature of your involvement and/or interest in the project.
Who can access my personal information and what conditions apply to their use of my personal information?
- As a general rule, your personal and sensitive information will only be accessed and/or viewed by Frazis Capital Partners and its third party contractors staff and officers, as and when it is appropriate or necessary.
- Where a party, other than an employee or officer of Frazis Capital Partners, has access to the personal information of individuals, they will be required to comply with the applicable Australian privacy legislation and, where appropriate, to enter into Privacy Agreements with Frazis Capital Partners.
- The access and use of your personal or sensitive information by a third party will be restricted to the purpose for which it was first collected and/or to a closely related secondary purpose.
Definition pursuant to the Australian Privacy Principles Guidelines:
Direct marketing involves the use and/or disclosure of personal information to communicate directly with an individual to promote goods and services. A direct marketer may communicate with an individual through a variety of channels, including telephone, SMS, postal mail, e-mail and online advertising.
- Frazis Capital Partners will not use or disclose your personal information for the purpose of direct marketing, unless:
- we collected the information from you;
- we obtained your consent to the use or disclosure of the information for that purpose (except where it was impracticable to do so); and
- you would reasonably expect Frazis Capital Partners to use or disclose the information for that purpose; and
- we provide you with an easy to use means of opting out of receiving any further direct marketing communications; and
- you have not requested that we cease sending you direct marketing communications.
- As mentioned above, Frazis Capital Partners makes use of a number of Google Analytics Advertising Features, including remarketing. The Remarketing feature allows Frazis Capital Partners to reach people who have previously visited its website and to match users with appropriate advertising.
If you would like to control or opt out of the application of the Google Analytics Advertising Features, you should refer to Google’s guide(s) on opting out of those features.
- Frazis Capital Partners will only make use of your sensitive information for direct marketing purposes if you have consented to the use or disclosure of that information for that purpose.
- If you receive direct marketing communications from Frazis Capital Partners or from an associated entity, you are entitled to:
- request that you receive no further direct marketing communications for Frazis Capital Partners
- and/or the associated entity; and
- request that Frazis Capital Partners disclose the source of the information.
- Frazis Capital Partners will take reasonable steps to facilitate a request by you to opt-out of receiving direct marketing communications. This may be a request to opt-out of receiving certain communications or to opt-out altogether.
- Frazis Capital Partners will not charge you for making such a request or for giving effect to such a request.
- Frazis Capital Partners will take reasonable steps to give effect to such requests within a reasonable period of time after the request is made and will reply to a request for the source of the information in a reasonable period of time (unless it is unreasonable or impracticable for us to do so).
- We may use your e-mail address to send you Frazis Capital Partners publications, newsletters, seminars or events. We may also contact you by e-mail to seek your opinion or comment on our website and our service offerings.
- Frazis Capital Partners, at all times, aims to comply with the terms of the Spam Act 2003 (Cth) and will not send unsolicited commercial electronic messages or “spam”.
- All commercial electronic messages sent by Frazis Capital Partners include information about the individual or organisation who authorised the sending of the message.
- You can unsubscribe from our e-mails at any time. You can also contact us if you would prefer not to receive this information and we will comply with your request.
4. How can you access you personal information and/or seek the correction of your personal information?
- You have a right to access the personal information we hold about you and to request the correction of any personal information we hold about you.
- Frazis Capital Partners will take reasonable steps to ensure that the personal information it collects and discloses is accurate, up to date, complete and relevant.
Requests for access to personal information
- You can make a request for access to your personal information informally, in writing, or pursuant to the terms of the Freedom of Information Act 1992 (WA) (FOI Act). Frazis Capital Partners aims to, whenever possible, facilitate informal requests for personal and/or sensitive information.
- Applications and enquiries should:
- be made in writing;
- give enough information so that the documents requested can be identified;
- give an Australian address to which notices can be sent; and
- be lodged at Frazis Capital Partners with any application fee payable.
- Frazis Capital Partners is not required to give you access to personal information to the extent that:
- Frazis Capital Partners reasonably believes that giving access would pose a serious threat to the life, health or safety of an individual, or to public health or public safety; or
- giving access would have an unreasonable impact on the privacy of other individuals; or
- the request is frivolous or vexatious; or
- the information relates to existing or anticipated legal proceedings between the entity and the individual, and would not be accessible by the process of discovery in those proceedings; or
- giving access would reveal the intentions of Frazis Capital Partners in relation to negotiations with you in such a way as to prejudice those negotiations; or
- giving access would be unlawful; or
- denying access is required or authorised by or under legislation or a court/tribunal order; or
- giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
- giving access would reveal evaluative information generated within Frazis Capital Partners in connection with a commercially sensitive decision making process.
- Should you experience difficulty in determining the correct route through which to request access to your personal information, please contact our Freedom of Information and Privacy Officer and they will provide you with assistance.
- Frazis Capital Partners will take reasonable steps to respond to a request for access within a reasonable period of time after the request is made (within 45 days) and to give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.
- Frazis Capital Partners reserves the right to charge you a minimal fee for providing you with your personal information.
- In the event that Frazis Capital Partners refuses to give you access to the personal information requested by you, we will give you a written notice which sets out the reasons for the refusal (except to the extent that it would be unreasonable to do so) and the mechanisms available to you to complain about the refusal.
Request for correction of personal information
- You can make a request for the correction and/or amendment of your personal information informally, in writing, or pursuant to the terms of the Freedom of Information Act.
- Applications to have personal information held by Frazis Capital Partners corrected or amended should:
- be made in writing to the Freedom of Information and Privacy Officer;
- provide enough information to determine what changes are required; and
- provide you current contact details.
- In the event Frazis Capital Partners refuses to correct your personal information, Frazis Capital Partners will give you a written notice which sets out the reasons for the refusal (except to the extent it would be unreasonable to do so) and the mechanisms available to you to complain about the refusal.
- Frazis Capital Partners will take reasonable steps to respond to a request for access within a reasonable period of time after the request is made (within 45 days) and will not charge you for the making of the request or for the correction of the personal information.
Freedom of Information Charges
- A scale of fees and charges are set under the Freedom of Information Act Regulations. Apart from the application fee for non-personal information all charges are discretionary. The charges are as follows:
- Type of fee:
- Personal information about the applicant: no fee
- Application fee (for non-personal information): $30
- Type of charge:
- Charge for time dealing with the application (per hour, or pro rata): $30
- Access time supervised by staff (per hour, or pro rata): $30
- Photocopying staff time (per hour, or pro rata): $30
- Per photocopy: 20 cents
- Transcribing from tape, film or computer (per hour, or pro rata): $30
- Duplicating a tape, film or computer information: Actual cost
- Deliver, packaging and postage: Actual cost
- Advance deposit may be required for the estimated charges: 25%
- Further advance deposit may be required to meet the charges for dealing with the application: 75%
- For financially disadvantaged applicants or those issues with prescribed pensioner concession cards, the charge payable is reduced by 25%.
Freedom of Information and Privacy Officer
- Applications and enquiries should be addressed to Frazis Capital Partners
Address: Frazis Capital Partners
5. Notifiable data breaches
- We are committed to protecting information we hold about you, and to compliance with the Notifiable Data Breaches scheme.
- Where we become aware of a potential data breach which is likely to result in serious harm to any individuals about whom we hold information, we will:
- investigate the suspected breach and determine scope of any breach that has occurred and the risk of harm to affected individuals whose information may have been compromised;
- notify you and the Privacy Commissioner of the potential breach; and
- take steps to minimise any harm caused to affected individuals as a result of the breach.
6. How can I complain about a breach or give feedback on how Frazis Capital Partners deals with my personal information?
- Should you wish to provide Frazis Capital Partners with feedback with respect to its management of your personal information, to complain about a breach by Frazis Capital Partners’s in relation to their privacy obligations or the Freedom of Information Act, or to appeal a decision with respect to a request for access to or the correction of personal information, please contact [TBA] in the first instance.
- [TBA]— will take reasonable steps to respond to your complaint and/or feedback within 45 days.
- In the event that you wish to have a decision refusing access to your personal information and/or refusing to correct your personal information reviewed or to lodge a complaint with respect to the management of your personal information, please contact us.
7. Disclosure of personal information to overseas recipients
- Generally, Frazis Capital Partners does not disclose the personal and/or sensitive information of its customers to overseas recipients.
- However, there is a possibility that, on occasion, your personal information may be disclosed to an overseas recipient. The location of any recipients will vary depending on the purpose concerned.
- In the event that a particular project will or may involve the disclosure of personal or sensitive information to an overseas recipient, Frazis Capital Partners will take reasonable steps to inform you of that potential use or disclosure as soon as possible. As part of our notification process, Frazis Capital Partners will inform you of the location and/or identity of that recipient.
- Similarly with other third party recipients and/or partners of Frazis Capital Partners, we will take reasonable steps to ensure that any overseas recipients comply with privacy policies and regulations which are similar to or more strenuous than those required by the applicable Australian legislation.
- Should you have any queries about the potential disclosure of your personal information to an overseas recipient, please fill in the contact us.