Privacy Policy

Neochain recognises the importance of your privacy and understands your concerns about the security of your personal information. We are committed to protecting any personal information that we hold. This Privacy Policy details how we generally collect, hold, use and disclose personal information and your rights in relation to the personal information that we hold about you.

This document outlines why Neochain may gather personal information from you, how it will be handled and how you may request access to the personal information we have on file. Neochain adheres to the National Privacy Principles, as described in the Privacy Act 1988 (amended).

Where this Privacy Policy refers to a party that may be either an individual or an organisation (such as our clients or service providers), the reference includes individuals who are employees, directors, or principals of an organisation or its associates.

Personal Information

‘Personal information’ is defined in the Privacy Act 1988 (Cth) to mean any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

We collect and hold a range of personal information in carrying out our business and functions as a services provider. The kinds of personal information that we collect and hold about you will depend upon the nature of our relationship with you.

Our clients

We typically collect and hold the following kinds of personal information about our clients:

• name, job title, address, date of birth, and contact details;
• Company details, including branches, area of operations, jurisdictions, structure, details of directors and beneficial owners;
• information the company’s structure, source of funds, source of wealth; and
• other information that you provide to us or that we collect in the course of our relationship with you.

To the extent that it is relevant to the service we are providing for a client or our general relationship with a client, we may also collect and hold personal information about clients that is sensitive information under the Privacy Act.

Details of a Clients AML/CTF program and certain operational details, including results of any reviews.

The amount and type of information we collect from you when you use of our website or contact us online will depend upon your use of the facilities and services available through our website or otherwise available online. However, the only personal information which we collect about you when you use our website or contact us online is what you tell us about yourself, such as when you complete an application form or information you provide to us when you send us an email.

What are the purposes for which we collect personal information?

We collect from you and from other persons described below personal information for the purposes of:

• assessing and processing any application you make for our products or services and any related proposal;
• providing you the products and services we offer in the course of our business;
• administering and managing all products or services we provide to you;
• performing other administrative tasks including, risk assessment, undertaking planning, research and statistical analysis, systems development and testing;
• answering an enquiry you make or responding to a complaint made by you in respect of a product or service;
• conducting data analytics to help us improve our products and services;
• verifying your identity and complying with our legal and regulatory obligations;
• facilitating our internal business operations, including audits, record-keeping, and account reviews;
• analysing products and customer needs to develop new products;
• informing you of products and services provided by us, our related bodies corporate or our preferred providers which we consider may be of value or interest to you, unless you tell or have previously told us not to;
• managing overdue payments and recovering overdue amounts you owe us;
• undertaking fraud prevention measures;
• contracting out some of our functions to external service providers and suppliers (such as mailing houses and printing companies, IT, advertising and marketing);
• assessing and considering applications from prospective contractors and service providers;

We are required to collect certain personal information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. If you do not provide us with your personal information, or consent to its collection, use or disclosure, we will not be able to do the things set out in this document.

Disclosure of Personal Information

Neochain will only use your personal information for the purposes listed in this statement or any directly related purpose. Neochain will not trade, sell or lease your information. In some circumstances, we may be required to pass on information about you to particular third parties. The most likely entities to which we may provide information include:

• Regulators and
• Government authorities

You have a right to request access to personal information that we hold about you and request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. You may do so by contacting us as privacy.officer@neochain.com.au. We will respond to all requests for access to or correction of personal information within a reasonable period.

In some cases, in accordance with the Privacy Act, we may charge you a fee for access to personal information we hold about you or refuse to give you access to personal information we hold about you.

Complaints

If you would like to complain about a breach of the Australian Privacy Principles, you may contact our Privacy Officer at privacy.officer@neochain.com.au

We will respond to complaints within a reasonable period of time (usually 30 days).

If you disagree with our decision, you may refer your complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, calling 1300 363 992 or by emailing enquiries@oaic.gov.au.

If you would like more information about the way we manage personal information, would like to request access to or correction of personal information that we hold about you, or wish to make a complaint, please contact our Privacy Officer by email – privacy.officer@neochain.com.au

Changes to our privacy policy

From time to time it may be necessary for us to review and revise our Privacy Policy. We encourage you to check our website from time to time to ensure you are familiar with our latest Privacy Policy.

Our Privacy Policy was last updated on 23rd of January 2023.