SCAR Privacy Policy

Last updated – 13 June 2022

SCAR Global (“SCAR”) has a commitment to respecting your privacy and believes that privacy is an important individual right.

This Privacy Policy (“Policy”) applies in relation to SCAR’s operations in Australia and explains how SCAR complies with the Privacy Act 1988 (Cth) (“the Privacy Act”).

This Policy relates to the collection, storage and use of personal information that is covered by the Privacy Act, being information or an opinion relating to an individual, which can be used to identify that individual. This Policy is not intended to cover information that is not covered by the Privacy Act.

General

SCAR requires its employees to protect and preserve personal and other confidential information held by SCAR and, in addition, are bound by any specific confidentiality undertakings made by SCAR to its clients.

Collecting personal information

SCAR generally collects personal information directly from you. For example, SCAR may collect personal information about you when you deal with us over the telephone, send us correspondence or provide information in relation to a claim. This process may be via the SCAR client portal through your request for our services via SCAR’s website or when a representative of SCAR meets with you. If you contact us, SCAR may keep a record of that contact.

Generally, the type of information SCAR collects and holds about clients, service providers and other business contacts will include your name, mailing and email addresses, telephone number, job title and organisation/employer name. This information is collected in order to provide clients with our services.

SCAR does not collect sensitive personal information (such as information about your health, religion, or membership of a professional /trade association) unless it is reasonably necessary for the services SCAR provides to you and you consent to the collection.

If you do not provide SCAR with the information requested, SCAR may not be able to provide you with our services.

SCAR may also source information from a third party or source, such as from a publicly maintained record or from the public domain generally (e.g. internet or media). SCAR will take reasonable steps where necessary to notify you when it collects your personal information from a third party or source.

Using and disclosing personal information 

SCAR collects, holds, discloses and uses your personal information to:

  • provide our services and products to you;
  • market our services and products to you (unless you have notified us that you do not wish to receive marketing material);
  • keep you informed of things that may be of interest to you;
  • generally communicate with you;
  • help us manage or improve our services;
  • comply with legal obligations; and/or
  • other purposes related to any of the above.

If you are a client or are employed by a client, SCAR may disclose your personal information to:

  • other companies or individuals who assist us in providing services or who perform functions on SCAR’s behalf;

  • solicitors, barristers or any other experts engaged to provide you with services; and/or
  • anyone else to whom you authorise us to disclose it.

If SCAR engages third parties to perform services for us, which involves the third party handling personal information that SCAR holds, SCAR prohibits the third party from using personal information about you, except for the specific purpose for which SCAR supplies it.

SCAR does not disclose any personal information it collects to third parties for the purpose of allowing them to directly market their products and services. SCAR does not sell or trade personal information.

Disclosure of personal information outside Australia 

SCAR may disclose your personal information to overseas persons or entities if it is required for SCAR to perform its services for you. The countries in which such overseas recipients are located will depend on the circumstances of the services SCAR provides you.

SCAR will take reasonable steps to ensure that any overseas persons or entities to whom any personal information is disclosed do not breach the relevant Australian Privacy Principles.

Accessing and correcting personal information SCAR holds about you

You can contact SCAR at any time to request access to your personal information or for your personal information to be corrected or updated.

Unless an exception applies, SCAR will, upon request and within 28 days, provide you with access to the personal information SCAR holds about you. SCAR will provide you with access to your personal information in a manner requested by you (providing it is reasonable and practicable to do so).

If SCAR is unable to provide you with access to the information, SCAR will provide you with reasons and inform you of any exceptions relied upon under the Privacy Act (e.g. if your request is unreasonable or relates to legal proceedings including privilege or is otherwise unlawful). SCAR will also provide you details of the process for making a complaint about the refusal to grant you access.

SCAR will take appropriate steps to verify your identity (or verify that you act as a legal guardian or authorised agent of the individual concerned) before granting a request to access your personal information.

SCAR will take reasonable steps to ensure that the personal information SCAR collects about you is accurate, up-to-date, complete and relevant. Upon request, SCAR will correct your information within 28 days of the request. SCAR will take reasonable steps to notify any relevant third parties of the correction.

Commercial information

As with the use of personal and disclosure of personal information, SCAR primarily collects and uses commercial information to provide services to its commercial clients. Types of commercial information includes (but is not limited to) contact information, investment trade data, related trading processes and policies. Specific commitments are made by SCAR as part of its commercial agreements with clients.

Information storage and security

SCAR takes all reasonable steps to ensure that your information is kept secure. Your information may be stored in hard copy documents but most likely as electronic data in SCAR’s software or systems. SCAR maintains physical security over its premises and also maintains computer and network security.

Where SCAR uses cloud data storage services, SCAR only uses physically secure data storage services located in Australia.

SCAR seeks to continually improve its security measures and related processes such as access control limits, authentication measures and access history logs for the better protection of its clients.

SCAR’s website and use of cookies 

A cookie is a small data file that a website may write to your hard drive when you visit. A cookie file can contain information (such as a user ID) that the website can use to track the pages you have visited and your preferences. The only personal information a cookie can contain is information you personally supply. A cookie cannot read data from your hard disk or read cookie files created by other websites.

SCAR does not use cookies to track user traffic patterns through its website. 

Spam Act 

SCAR complies with the Spam Act 2003 (Cth), which regulates the sending of emails and other commercial electronic messages.

Effect of the Policy 

This Policy does not form a contract between an individual and SCAR. This Policy may change to reflect SCAR’s business and technology. Whenever you need to refer to this Policy you should refer to SCAR’s website – https://scar.global– or contact us for the most up to date version.

Please note that SCAR’s website may contain links to other websites. When a user has clicked on a link to another site, they leave the SCAR site and are no longer protected by this Policy.

Complaints 

If you believe that SCAR has breached a term of this Policy or the Australian Privacy Principles you may submit a written complaint to the Senior Officer by contacting us. You must include contact details for us to contact you regarding your complaint. Your complaint will be addressed in accordance with SCAR’s Complaints Resolution Procedure, which is available to clients.

Contacting SCAR

If you wish to gain access to your personal information, amend your personal information, have any query regarding the Policy or wish to obtain a hard copy of the Policy, please contact us.