Privacy Policy

Non Correlated Group Pty Ltd (“NC Group”, “we”, “us”) is committed to protecting your personal information and ensuring its security. This Privacy Policy outlines how we collect, use, disclose, and safeguard the personal information you provide to us.

NC Group complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
This policy is available upon request and can also be accessed on our website. For any inquiries, please contact us using the details provided below.

1. Scope of this Policy 
This Privacy Policy applies to all NC Group companies, including Non Correlated Advisors Pty Ltd, Primary Securities Ltd, and Non Correlated Capital Pty Ltd. It covers the personal information of:

• Clients
• Employees and contractors
• Representatives (including authorised representatives)

2. What Information We Collect

2.1. Personal Information
We collect personal information necessary to provide you with our services and comply with legal and regulatory requirements. This includes:

• Identifying details: name, date of birth, address, email, phone number, and Tax File Number (TFN).
• Financial information: bank account details, income, investment preferences.
• Transactional and historical data: records of your engagement with us.

2.2 Non-Personal Information
We may also collect information not directly submitted by you, such as:

• Browser type, IP address, referring URL, and timestamps.
• Statistical data for website analytics.

We may collect information directly from you or authorised third parties (e.g., credit reporting agencies, regulatory bodies).

3. Why We Collect Information
We use the information you provide for purposes including:

• Verifying your identity and assessing your suitability for our services.
• Providing financial products, managing accounts, and administering services.
• Improving our products, services, and marketing strategies.
• Complying with regulatory obligations, such as anti-money laundering and counter-terrorism financing laws.
• Detecting and investigating fraud or other misconduct.

If you do not provide the necessary information, we may not be able to provide our products or services to you.

4. How We Use and Disclose Information

4.1. Use of Personal Information
We use your information to:
Respond to inquiries and manage our relationship with you.
Inform you about products and services that may interest you.
Conduct administrative tasks such as record-keeping and account management.

4.2. Disclosure to Third Parties
We only disclose your personal information:
When required by law (e.g., to regulatory bodies such as AUSTRAC or the Australian Taxation Office).
To trusted third-party service providers who assist us in delivering our services (e.g., IT support, auditors).
In connection with business transactions, such as the sale or transfer of NC Group assets.

4.3. Cross-Border Data Transfers
Your information may be disclosed to entities located overseas, including the United States, Europe, and Asia, where privacy laws may differ. We ensure that any overseas recipient adheres to the Australian Privacy Principles.

5. Direct Marketing
We may use your personal information to provide you with direct marketing communications. If you do not wish to receive these communications, you can opt out by emailing us at investorrelations@noncorrelatedgroup.com

6. Data Security
We take the security of your personal information seriously and implement:

• Physical security measures: Restricted access to facilities and hardcopy records.
• Electronic security measures: Firewalls, secure cloud storage, and encryption.
• Employee training: Ensuring all staff comply with confidentiality and data protection policies.

While we strive to safeguard your data, no system can guarantee complete security. By using our services, you acknowledge and accept these inherent risks.

7. Accessing and Updating Your Information

7.1. Access Requests
You have the right to access the personal information we hold about you. We will provide this information within 30 days of receiving your request. If your request is complex, we may charge a reasonable fee, which will be communicated to you in advance.

7.2. Corrections
If you believe your information is inaccurate or outdated, you can request corrections. If we disagree, we will explain our reasons in writing. You can also ask us to include a statement about the inaccuracy.

7.3. How to Make a Request
Please direct your requests to:

• Email: investorrelations@noncorrelatedgroup.com
• Phone: 1300 034 093
• Mail: Director, NC Group, 3 Shuffrey St, Fremantle, WA 6160

8. Retention of Personal Information
We retain personal information for as long as required by law (e.g., seven years for financial records) or to resolve disputes. After this period, your information is securely de-identified or destroyed.

9. Handling Privacy Complaints
We are committed to addressing your privacy concerns promptly. If you have a complaint:

1. Contact Us: Email investorrelations@noncorrelatedgroup.com or call 1300 034 093.
2. Response Timeframes: We will acknowledge your complaint within 7 days and aim to resolve it within 30 days.
3. External Escalation: If unresolved, you can contact:

• Office of the Australian Information Commissioner (OAIC):
• Phone: 1300 363 992
• Online: www.oaic.gov.au
• Mail: GPO Box 5218, Sydney NSW 2001.
• Financial Ombudsman Service (FOS):
• Phone: 1300 780 808
• Online: www.fos.org.au
• Mail: GPO Box 3, Melbourne VIC.

10. Updates to this Policy
We review and update this policy regularly to ensure compliance with evolving laws and business practices.
The latest version will always be available on our website at  www.noncorrelatedgroup.com

11. Contact Us

If you have any questions about this policy, please contact:

• Email: investorrelations@noncorrelatedgroup.com
• Phone: 1300 034 093
• Mail: Director, NC Group, 3 Shuffrey St, Fremantle, WA 6160

This version of the Privacy Policy is designed to provide a comprehensive overview of our practices while remaining clear and accessible to the public.