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Please note: This Privacy Policy has been formulated in compliance with and regard to both the Australian Privacy Act and the EU General Data Protection Regulation, both of which foster transparent information handling practices and business accountability to enable individuals to have confidence that their privacy is being protected.<\/p>\n
This Privacy Policy (Policy) explains how Rydon Capital Pty Ltd (\u201cRydon Capital\u201d) (ABN 84 640 099 467) processes, collects, stores, uses and discloses your personal information and the rights and options you have in this respect, including rights of access, and rights to correct, erase or object to that information. It applies to personal information that you provide to Rydon Capital or which are derived from your contractual relationship or interacting with Rydon Capital. Rydon Capital Pty Ltd is subject to the Australian Privacy Act 1988 (Cth) (Privacy Act) (inclusive of all subsequent amendments and the Australian Privacy Principles). Furthermore, Rydon Capital is also in scope of the EU General Data Protection Regulation (EU) 2016\/679 (GDPR) as we have affiliated entities located in the EU, offer goods and services to individuals in the EU or may conduct further processing activities which require compliance with GDPR.<\/p>\n
We, Rydon Capital of Level 1, 452 Flinders St, Melbourne VIC 3000 which is identified in our communication with you will be the responsible controller for any personal information you provide to us in connection with our business relationship.<\/p>\n
We may collect and process the following categories of personal information depending on the nature of our business relationship with you or your organization: Private or work contact information, such as full name, address, telephone number, mobile phone number, fax number and email address, mobile device unique identifier and the IP address of your computer or other online identifiers if you use our services online;
Payment related information, such as information necessary for processing payments and fraud prevention, including credit\/debit card numbers, security code numbers and other related billing information;
Further business information necessarily processed in a business or other contractual relationship with Rydon Capital or voluntarily provided by you, such as feedback and any other information you may provide to us;
Information about your interests and preferences and other information obtained by cookies or website analytics tools, in particular your activities when you use our websites or products or other services we offer to you online (such as downloadable content). This may include information about which content you download, click or view for how often and how long;
Information from publicly available resources, integrity databases and credit agencies;
Information we are legally required to collect to comply with our legal or regulatory obligations, which may include information about relevant and significant litigation or other legal proceedings against you or a third party related to you and interaction with you which may be relevant for antitrust purposes; and
Sensitive information. In certain circumstances, where required by law or where you have permitted us to do so, we may collect special categories of your personal information which are specifically protected under data protection law. In connection with the registration for and provision of access to an event or seminar, we may ask for information about your health for the purpose of identifying and being considerate of any disabilities or special dietary requirements you may have. Any use of such information is based on your consent. If you do not provide any such information about disabilities or special dietary requirements, we will not be able to take any respective precautions.<\/p>\n
Depending on the nature of our business relation, we may process, collect, hold, use and disclose your personal information for the following purposes (\u201cPermitted Purposes\u201c):<\/p>\n
Planning, entering into, performing, managing and administering the services we provide to prospective and current customers e.g. by maintaining our information technology systems, customer service and data storage;
Maintaining and protecting the security of our products and services and of our IT systems, databases, websites or other digital infrastructure, preventing and detecting security threats, fraud or other criminal or malicious activities;
Ensuring compliance with legal obligations and regulatory obligations. This may include sales and business record keeping obligations for tax or other purposes and sending required notices or other disclosures, compliance screening or recording obligations (e.g. under anti-money laundering (AML), know your customer (KYC), antitrust laws, export control laws, trade sanction and embargo laws or to prevent white-collar crimes). In this context we may be required to conduct automated checks of your contact data or other information about your identity against applicable anti-money laundering or sanctioned-party lists and to contact you to confirm your identity in case of a potential match, to record interaction with you which may be relevant for antitrust purposes and to report to or support investigations by competent supervisory, law enforcement or other public authorities;
Informing you, where permitted by applicable law about Rydon Capital products or services which are similar to products and services purchased or used by our within that or otherwise related to our business relationship with you or your organisation; or
Solving disputes, enforcing our contractual agreements and to establish, exercise or defend legal claims.<\/p>\n
Where you have expressly given us your consent or where otherwise legally permitted, we may also process your personal information for the following purposes:<\/p>\n
Communicating with you through the channels you have approved to keep you up to date on the latest announcements, special offers and other information about Rydon Capital products, technologies and services (including marketing-related newsletters) as well as events and projects of Rydon Capital;<\/p>\n
Administrating and performing customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events; or
Profiling and automated processing: Collecting information about your preferences on the basis of your activities when you use our websites and any products or services we offer to you online (such as downloadable content). On the basis of this information (e.g. which content is downloaded, clicked or viewed for how often and how long), we create a user profile to personalise and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics). The logic behind our profiling activities is to identify areas which may be useful or otherwise of interest for you and to inform you about such areas in a more effective and targeted way. The algorithms used apply this logic and automatically deliver the targeted content or information to you.<\/p>\n
Please note:<\/strong> Under the European General Data Protection Regulation (Article 21 (2)) you have the right to object to the use of your personal information for direct marketing purposes, including the profiling described above. Please refer to \u201cYour data protection rights\u201d below for further explanation of your rights and how to exercise them.<\/p>\n Where your explicit permission is required for any marketing-related communication, we will only provide you with such information if you have opted in. You may opt out at any time if you do not want to receive any further marketing-related types of communication from us. We will not use your personal information for taking any automated decisions affecting you or creating profiles other than described above.<\/p>\n We will process your personal information for the above Permitted Purposes only: where it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into such a contract; where it is necessary for our or a third party\u2019s legitimate interests, always provided that such interests are not overridden by your interests or fundamental rights and freedoms. Our \u201clegitimate interests\u201d may include our commercial interests in operating our business in a professional, sustainable manner, in accordance with all relevant legal and regulatory requirements; for our compliance with our legal obligations; where it is necessary to protect your or another person\u2019s vital interests; where we have obtained your specific or, where necessary, explicit consent to do so. We will in each case inform you about the processing of your data and your related rights prior to obtaining your consent. The legal bases for processing of your personal information are set forth in Article 6 GDPR.<\/p>\n We will typically collect your personal information directly from you when you interact with us, e.g. when you visit our website, communicate with us in relation to our products and services, request a product or service, register to receive our newsletter or other specific marketing material or participate in our customer surveys. Where you have expressly given your consent, we may also obtain your personal information from third parties (including our contractors who supply services to us, our partner institutions or from a publicly maintained record) for communication and marketing purposes. In such cases, you will be informed about this in accordance with applicable law. [Otherwise, we do not obtain personal information from third parties.]<\/p>\n We may hold personal information electronically, or in paper files. We will maintain physical, electronic and procedural safeguards in accordance with the technical state of the art and legal data protection requirements to protect personal information against misuse, intrusion, interference, loss and unauthorised access, modification or disclosure. These safeguards include implementing specific technologies and procedures designed to protect your privacy, such as secure servers, firewalls and SSL encryption and depending on the information and the circumstances, this protection may in particular include:ON WHICH BASIS DO WE PROCESS YOUR INFORMATION?<\/h4>\n
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?<\/h4>\n
HOW DO WE HOLD AND PROTECT YOUR PERSONAL INFORMATION?<\/h4>\n
the use of confidential passwords for purposes of accessing such information on Rydon Capital\u2019s internal systems;
storing hard copies of documents containing personal or sensitive information in secure files created for this purpose;
imposing confidentiality requirements on our employees;
conducting reasonable due diligence on any third party service provider\u2019s security measures, and compliance with privacy laws, especially if they are located offshore; and
maintaining physical access controls over our premises.
Where Rydon Capital holds personal information that it no longer requires, Rydon Capital will take reasonable steps to destroy or de-identify such information, subject to any law or court order requiring retention.<\/p>\nWHERE DO WE PROCESS PERSONAL INFORMATION?<\/h4>\n