Our commitment

Our privacy policy explains how we collect, use, disclose, manage and otherwise protect your personal information. Please note that we treat all information that you provide to us in confidence and will take all reasonable steps to ensure appropriate standards of privacy and security are applied. We treat all personal information in accordance with the provisions of the Privacy Act 1988 (Cth) (Privacy Act), Australian Privacy Principles and registered privacy codes.

Information we collect

DNR Capital collects and holds personal information from clients, investors, employees, contractors and service providers. As a financial services organisation we are subject to certain legislative and regulatory requirements, such as those relating to Anti Money Laundering and Counter Terrorism, financing (AML/CTF), which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“personal information”). In addition, our ability to provide you with quality products and financial service(s) is dependent on us obtaining certain personal information about you, information including:

  • name, address, phone number, email address, date of birth and bank account number;
  • employment details and history;
  • details of your current financial circumstances, needs and objectives, including your assets and liabilities (both actual and potential), income, expenditure, insurance and superannuation;
  • your Tax File Number
  • records of our interactions with you including your enquiries or complaints.

If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, have requested from us.

We may also collect sensitive personal information, such as:

  • if you are a DNR Capital employee, details of any allergies or dietary requirements you have or other medical conditions which you consider important for us to be aware of; and
  • criminal record information obtained through our screening processes before you commence, or during the course of, your business or employment relationship with us.

We recommend that you do not provide such information to us unless specifically requested by us.

The privacy laws impose greater obligations on us regarding any collection, use or disclosure of your sensitive information. We will only collect your sensitive information if:

  • you have expressly consented to us doing so
  • the information is reasonably necessary for, or directly related to our business activities or functions
  • we are required or authorised to do so by law, or
  • a permitted health or general situation exists.

Method of collection

We generally collect personal information from you in the following way:

  • Directly from you, either in person, or from documents that you provide us, or over the telephone, by email or by your access to our website.
  • From third parties, such as your employers, financial adviser, accountant or other professional service provider.
  • From information service providers such as AML/CTF screening databases.
  • From publicly available sources.

Where we receive unsolicited personal information about you, we will determine within a reasonable period whether we may retain it or are required to destroy or de-identify it and take appropriate action.

How we use your information

We will only use personal information about you for the purpose for which it was provided to us, including:

  • processing your applications
  • establishing your identity; where you are required to provide identifications documents (ID), our ID will be scanned and a copy saved;
  • administering and managing our products and services including monitoring, auditing and evaluating our products and services;
  • providing you with marketing information about other services that we, our related entities and other organisations that we have affiliations with offer that may be of interest to you. However, you may, by contacting us be any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow 2 weeks for your request to be actioned.
  • maintaining our relationship with you;
  • complying with any legal or regulatory requirements; and
  • dealing with any complaints or enquiries.

We may also:

  • anonymise your data for our own purposes including system testing or new product development.
  • use personal information about you for the prevention and mitigation of fraud or other financial crimes.
  • With your consent, we may also disclose your personal information to other third parties and for other purposes. That consent may be written, verbal or implied from your conduct depending upon the nature of the disclosure at that time.

Disclosure of your information

We will not only disclose personal information for the purposes for which it was collected, including:

  • To our service providers, who provide services in connection with our products and services (including our sub custodian, archival, auditing, accounting, legal, business consulting, data processing, insurance, and identity verification services.)
  • To your nominated financial adviser with your authorisation.
  • For the prevention and mitigation of fraud and other financial crimes.
  • Superannuation fund trustees, insurance providers, and product issuers for the purpose of giving effect to your financial advice and the recommendations made by your adviser;

We may also be required to disclose your personal information:

  • to comply with any legal or regulatory obligations including those under AML/CTF laws or the Corporations Act, 2001 or reasonably arising in connection with legal proceedings. 

Cross-border disclosure of personal information

In some circumstances the parties with whom we share personal information, may operate outside of Australia. This includes Canada, Malaysia and the United Kingdom. Where this occurs, we require the recipient to take steps to protect personal information against loss, misuse and unauthorised access, modification or disclosure.

Internet users

We use a tool called “Google Analytics” to collect information about use of our website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognising you on return visits to this site by disabling cookies on your browser.

Our website may contain links to other websites. We are not responsible for the content or material contained in, or obtained through, any third-party website or for the privacy practices of the third-party website.

Security

Your personal information may be stored on paper and in electronic form, at our premises and the premises of our service providers, which may include the processing or storage of information in the cloud.

We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, interference, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential. All paper files are kept in lockable storage. Access to our premises is controlled by allowing only authorised personnel to access the premises. All computer based information is protected through the use of access passwords on each computer and screen saver passwords. Data is backed up each evening and stored securely off site.

In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in a secure storage facility for a period of 7 years in order to comply with legislative and professional requirements, following which time the information will be de-identified or destroyed.

Access to your information

You may at any time, by contacting us by any of the methods detailed below, request access to your personal information and we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.

We may charge you a reasonable fee for providing access to your personal information (but not for making a request for access). 

There may be come legal or administrative reasons to deny these requests.

In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal which sets out the reasons (unless it would be unreasonable to provide those reasons) and we will take reasonable steps to (if any) give access in a way that meets your needs.

Correction of your information

We will endeavour to ensure that, at all times, the personal information about you which we hold is accurate, up to date and complete. In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate, incomplete or outdated, you may contact us by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness or out datedness and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.

If we do not agree that your personal information requires correcting, we will provide you with a written notice setting out our reasons (unless it would be unreasonable for us to do so) and the mechanisms available to you to make a complaint, and you also have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.

We will endeavour to respond to any request for access within 14–30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.

Data breach notification

In compliance with the data breach notification scheme, we have a process in place to investigate data breaches involving personal information. In the event of an ‘eligible data breach’ we will promptly notify the Office of the Australian Information Commissioner (OAIC) and any affected individuals. Generally speaking, this would be when we have reasonable grounds to believe that there has been unauthorised access or disclosure of personal information, or if that information has been lost in a way that is likely to give rise to unauthorised access or disclosure. Importantly, we are only required to make a notification where there is a likely risk of serious harm as a result of the unauthorised access or disclosure.

Complaints resolution

 If you wish to complain about any breach or potential breach of this privacy policy or the Australian Privacy Principles or a privacy code that applies to us, you should contact us by any of the methods detailed below and request that your complaint be directed to the Resolutions Officer. Your complaint will be considered within 7 days and responded to within a reasonable time. It is our intention to use our best endeavours to resolve any complaint to your satisfaction, however, if you are unhappy with our response, you are entitled to contact the Office of the Information Commissioner or the federal Information Commissioner who may investigate your complaint further.

If you have any queries or concerns about our privacy policy or the way we handle your personal information, please contact our Resolutions Officer at:

Postal address: Resolutions Officer
DNR Capital
GPO Box 3263
Brisbane QLD 4001
Phone: 07 3229 5531
Email: [email protected]

More information

For more information about privacy in general, you can visit the federal Information Commissioner’s website at www.oaic.gov.au.

Contacting us

If you wish to contact us regarding our handling of your personal information or any of the matters covered in this Privacy Policy, please contact the Chief Executive Officer:

Postal address: Chief Executive Officer
DNR Capital
GPO Box 3263
Brisbane QLD 4001
Phone: 07 3229 5531
Email: [email protected]

We welcome your questions and any suggestions you may have about our Privacy Policy.

Changes to this Policy

DNR Capital reserves the right to revise or supplement this Privacy Policy from time to time. Any updated version of this Privacy Policy will be posted on our website, dnrcapital.com.au and will be effective from the date of posting. You should bookmark and periodically review this page to ensure that you are familiar with the most current version of this Privacy Policy and so you are aware of the way we handle your personal information.

This Privacy Policy was updated in November 2024.