Privacy Statement

This Statement was last updated on 3 September 2024.

Walsh Bay Partners Pty Ltd (ACN 160 258 097) (‘we’, ‘our’, ‘us’, or ‘WBP’) is committed to protecting the personal information that we collect and hold about you. This Privacy Policy (Policy) sets out how we collect, use and share your personal information and how to contact us with any queries or concerns. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and we adhere to the Australian Privacy Principles (APPs).

While we may update our Policy from time to time, the most recent version of our Privacy Statement will always be available on our website. If we change the Policy in any material way, we will post a notice on our website along with the updated Statement. We may also contact you via your contact information on file, for example by email, notification or some other equivalent measure.

If you have any queries, concerns or complaints about how we handle your personal information, please contact out Privacy Officer in the first instance:

Privacy Officer Contact: William Cottam
Email: william.cottam@wbpartners.com.au

Postal address
Attention: Privacy Officer
Walsh Bay Partners Pty Ltd
P.O. Box Q239 QVB NSW 1230

Note: Our website may contain links to other websites. When you click on a link to another site, you are no longer subject to this Policy.

1. What types of information do we collect and why?
As necessitated in the course of providing our services to our clients, we collect personal and other information. We collect personal information through a number of mechanisms, including:

Collection from you: we collect and store information you provide directly to us (either in person, by email, by phone, or by any other direct means) in order to deliver our services. This includes:

  • Contact information: such as your name, address, email address, telephone number;
  • Personal information: such as date of birth, passport and driver’s licence details & tax file number/s:
  • Financial and credit information: such as your bank account/s information;
  • Business details: such as your Australian Business Number, Company and other entity details (trusts etc); and/or

1.1 Communications: when you communicate with us, we collect information such as your contact details (email address or phone number). You can elect to not receive communications from us by contacting our Privacy Officer.

1.2 Through other sources: where necessary, we also collect your information from publicly available records. Where appropriate and necessary to do so we collect information from public records such as those maintained by the Australian Securities and Investments Commission, Australian Financial Security Authority (such as the Personal Property Securities Register), and land titles offices in each state. We may do this where it is unreasonable or impractical to collect this information from you.

You have the option of not identifying yourself or interacting with us using a pseudonym. However, this may not be practicable when engaging our services. If you provide us with information about another person, you represent that you are authorised to do so and agree that you have obtained the necessary consent from that person for us to use and disclose their personal information.

How we use your information

We will only use your information for the purposes for which it was collected (primary purpose) or a purpose related to that primary purpose if it would be reasonably expected by you or where we have separately obtained your consent. We use personal information for the primary purposes of providing investment research & advice and investment product information to you and your related parties, including associated entities. We will only disclose your personal information to other parties (that may include overseas investment managers) where such disclosure is for the primary purpose and you have consented to such disclosure.

We do not sell your personal information to any party.

We are obliged to disclose personal information when required by law to do so.

If you would like to restrict how your personal information is handled beyond what is outlined in this Policy, please contact our Privacy Officer.

We store your personal and related information on computer servers with appropriate back
up and security systems.

1.3 Security and management of personal information

We will take reasonable steps to protect the personal information we hold from misuse, loss, and unauthorised access, modification or disclosure. We do this by:

    • putting in place physical, electronic and procedural safeguards in line with industry standards;
    • requiring any third party providers (such as data storage services) to have acceptable security measures to keep personal information secure;
    • limiting access to the information we collect about you;
    • imposing confidentiality obligations on our employees; and
    • only providing access to personal information once proper identification has been given.

While we take all steps reasonable in the circumstances to protect your information, in the unlikely event a data breach occurs, we will notify you in accordance with our obligations under the Privacy Act.

If we no longer require your personal information, and are not legally required to retain it, we will take reasonable steps to destroy or de-identify the personal information.

1.4 Sending information overseas

We do not disclose or store personal information overseas.

2. How to access and control your information

2.1 Accessing the information we hold about you

Under the APPs you may be able to obtain a copy of the personal information that we hold about you. To make a request to access this information please contact us in writing. We will require you to verify your identify and specify what information you wish to access. If eligible, we will grant you access to the information within 30 days.

2.2 Updating your personal information

We endeavour to ensure that the personal information we hold about you is accurate, complete and up-to-date. Please contact our Privacy Officer if you believe that the information we hold about you requires correction or is out of date. We endeavour to process any request within 30 days and will provide written reasons if your request is rejected, as well as providing details for making a complaint about the refusal if necessary.

3. Complaints

If you are concerned that we have not complied with your legal rights or the applicable privacy laws, contact our Privacy Officer in the first instance. Please contact our Privacy Officer with a thorough description of your concerns and a response will be provided within a reasonable period. All complaints must be in writing.

When processing a compliant, we will require you to provide us with information to confirm your identity before processing a request related to information we may hold about you.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:

Director of Compliance Office of the Australian Information Commissioner
GPO Box 5288
Sydney NSW 2001

For more information on privacy see the Australian Information Commissioner’s website

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