Privacy Policy – Australia and New Zealand

The following Privacy Policy is applicable to all clients, users of this website, or any persons from whom R-Spectrum has collected or collects personal information, in connection with the collection and use of personal information by R-Spectrum in Australia and New Zealand.

Unless stated otherwise, R-Spectrum on this page, means any of:

  • Halberd Bastion Pty Ltd trading as R-Spectrum; and/or
  • any of their related bodies corporate or related companies wherever incorporated in Australia or New Zealand.

R-Spectrum understands and appreciates that the privacy of personal information R-Spectrum may collect about you is important.  R-Spectrum is committed to providing you with high quality consultation services in a secure and confidential manner.  R-Spectrum complies with the Australian Privacy Principles as required under the Privacy Act 1988 (Cth) in Australia and its obligations under the Privacy Act 1993 in New Zealand when handling your personal information.

You may be reading this Privacy Policy because you have provided, or may soon be providing, your personal information to a member of R-Spectrum with whom you have established or will establish a relationship with.  By providing us with such personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, handling and disclosure of your information in the manner and for the purposes described in this Privacy Policy and as may be indicated on the document (including any online forms), through which you provide such information to R-Spectrum.

Our Privacy Policy sets out, for your information:

  • what personal information we may collect about you;
  • to whom your personal information may be disclosed;
  • the purposes for which your personal information may be used and disclosed;
  • our arrangements for the security of any personal information we hold about you;
  • how you may access and correct your personal information;
  • how you may make a complaint in relation to your privacy; and
  • how you can contact us.

In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy provisions that apply to certain products and services provided by R-Spectrum or any of its affiliates worldwide.  These specific and additional provisions may also relate to your privacy protection and you should review them carefully.  In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

What Personal Information We Collect About You

The term ‘personal information’ in this Privacy Policy, is as that term is defined in the Privacy Act 1988 (Cth) of Australia or the Privacy Act 1993 of New Zealand, as applicable to you.  The personal information that we collect about you will depend on the R-Spectrum services and products that you use.  The types of information R-Spectrum has collected, or may collect, and hold will include (but are not limited to) information we use to identify you, your financial position and any other information that may be necessary to the services and products you use.  Such information may include details such as your name, date of birth, address, contact details, bank account and tax file numbers, employment history and investment profile.

Where possible, we will collect your personal information from you directly.  Circumstances in which we may collect your personal information from third parties include:

  • for payment purposes at your direction;
  • to verify identity and for customer due diligence purposes;
  • for the prevention and detection of money laundering and terrorism financing;
  • background checking and verification in connection with recruitment;
  • where you have consented;
  • where you have defaulted on payment or delivery of products
  • where we are required or authorised by law to do so; and
  • for the purposes of providing you with products, services or information in accordance with your requests or reasonable expectations.

Use and Disclosure of Personal Information

The purposes for which R-Spectrum uses your information will vary depending on the R-Spectrum services and products you have applied for or use, and the relationship which you have with us.  By providing your personal information to R-Spectrum, you consent to our use of your personal information for any purpose which is related to the purpose for which such information has been provided to R-Spectrum.

Your personal information may be disclosed to third parties for purposes related to the purposes for which your personal information was collected, with your consent or as authorised or required by law.

We may disclose your personal information to the following third parties (as distinct from the member of R-Spectrum to whom you have provided your personal information):

  • any member of R-Spectrum or any of its affiliates worldwide;
  • any third party service providers carrying out functions for or on behalf of R-Spectrum or any of its affiliates worldwide;
  • any person acting on your behalf including your solicitor, accountant, executor, administrator, trustee or guardian;
  • government agencies, courts of law, tribunals or regulators (examples include in connection with a subpoena or order with which a member of R-Spectrum must comply, or a regulatory investigation conducted by an Australian or New Zealand regulator of R-Spectrum); and/or
  • any other third party with your consent or where authorised or required by law.

Depending on the connection which a member or members of R-Spectrum has/have with you, we may use and disclose your personal information for the purposes of:

  • providing you with products, services or information in accordance with your requests or reasonable expectations;
  • administering any accounts, you hold with R-Spectrum or any of its affiliates worldwide;
  • enabling R-Spectrum or any of its affiliates worldwide to ascertain whether or not they have other services or products which may foreseeably meet your needs or may be of interest to you, and to notify you about these;
  • the research, planning, product development, risk assessment, risk modelling and marketing conducted by R-Spectrum or any of its affiliates worldwide;
  • where you have not requested that any marketing communications sent to you, direct marketing of any products or services which R-Spectrum decides may be of interest to you;
  • identity verification and customer due diligence purposes;
  • the prevention and detection of money laundering and terrorism financing;
  • determining whether you have any history of defaulting on payment or delivery of products;
  • background checking and verification in connection with recruitment;
  • compliance with laws including but not limited to the Corporations Act 2001 (Cth), the Anti-Money Laundering and Counter Terrorism-Financing Act 2006 (Cth), the Proceeds of Crime Act 1987 (Cth), the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (New Zealand), and any associated Acts and Regulations enacted pursuant to those Acts named above;
  • any other purpose to which you have consented; or
  • disclosure where required or authorised by law.

Consequences If You Do Not Consent to the Collection or Use of Some or All Your Personal Information

Where you do not consent or do not provide the relevant member(s) of R-Spectrum with some or all of your personal information, depending on your relationship with such member(s) and the products or services for which you are applying, R-Spectrum may not be able to process your application or provide you with any of the requested products or services.  Where such failure to provide personal information constitutes suspicious activity under relevant law, R-Spectrum may be required to report such failure to the relevant authorities.

Transferring Your Information Outside Australia or New Zealand

Given the global nature of R-Spectrum’s business, depending on the products or services being provided by R-Spectrum to you, your information may be disclosed to third party service providers carrying out functions on behalf of R-Spectrum or any of its affiliates worldwide or as required by law.

By providing us with your personal information, you acknowledge that the parties above may be located outside of Australia or New Zealand (as relevant to you), including in Singapore, Hong Kong and other countries in which R-Spectrum has an office.

If we disclose your personal information outside Australia or New Zealand, we comply with transborder data flow privacy standards under the relevant Privacy Act, for example, by taking reasonable steps to:

  • ensure that the recipient does not breach the Australian Privacy Principles;
  • protect the information being held, used or disclosed by the recipient; and
  • ensure that the recipient is subject to substantially similar privacy laws as Australia or New Zealand (or where that recipient is not – that you have consented to such disclosure).

Employee Record Exemption

In Australia, this Privacy Policy does not apply to personal information provided to, held, or used by R-Spectrum where that information forms part of an employee record for the purposes of the Privacy Act 1988.

Use of the R-Spectrum Website

By using a R-Spectrum web site with your browser settings adjusted to accept cookies, you consent to our use of cookies and other tools to provide or improve the products and services available on those sites.  For more information about cookies, please see our Cookies Policy.

Security of Your Personal Information

R-Spectrum takes reasonable steps to preserve the security of personal information it collects.  Personal information of clients, applicants and any other individuals are held in a secure environment in writing, electronically, or both.  We have implemented security procedures, controls and protocols across all of our physical premises and electronic environments to ensure that personal information is protected from interference, loss, misuse, unauthorized access, modification, or disclosure.  All stored client information is protected from unauthorised access through the use of secure passwords and user log ons or other security procedures.

Access and Updating of Information

R-Spectrum takes reasonable steps to make sure that the personal information which we collect, use and disclose is accurate, complete and up-to-date.

You are able to make a request to access and update the personal information that we hold about you.  Please provide us with as much detail as possible to assist us to retrieve the personal information which you have requested.  In accordance with privacy laws a reasonable fee may be charged to cover our costs of providing access to you.  To access or amend personal information that R-Spectrum holds you should write to:

Privacy Officer
Halberd Bastion Pty Ltd
58 Latrobe Terrace
Paddington, Queensland
Australia, 4051

or via email:
[email protected]

The Australia and New Zealand Privacy Officer will respond to your request within a reasonable period after your request is made and, if it is reasonable and practicable to do so, provide you with access to your personal information in the manner you requested.

Please be aware, in certain circumstances, R-Spectrum may not be required to provide you with access to, or the ability to correct, your personal information.  If such a decision is made, we will provide you with a written notice setting out our reasons and other available options for you.

How You Can Contact Us

If you have any questions or feedback about this statement or any complaints about our collection, storage or handling of your personal information, please contact the Privacy Officer in Australia in writing at any time by using the contact details set out above.

If you are located in Australia, where you have made a privacy-related complaint, we will respond to your complaint by no later than 45 days after receipt.  If you are not satisfied with our response to your complaint or your concerns are not satisfactorily resolved, you may contact the independent statutory agency:

Office of the Australian Information Commissioner
GPO Box 5218 
Sydney NSW 2001

Tel: 1300 363 992
Fax: +61 2 9284 9666
Email: [email protected]

This Privacy Policy was last updated in October 2016. R-Spectrum may, at our discretion and without any prior or subsequent notice to you, amend or remove any part of this Privacy Policy at any time.