Privacy Policy

XT VENTURES PTY LTD

(ABN 16 651 652 149)

This Privacy Policy outlines how XT Ventures manages the personal information about clients it may collect, hold, use and disclose. XT Ventures are committed to protecting your privacy and the confidentiality of your personal information in accordance with the Privacy Act 1988 of Australia, Privacy Amendment (Enhancing Privacy Protection) Act 2012 of Australia and the Australian Privacy Principles (collectively “Privacy Act”), which this policy is based on. Unless advised otherwise, all references to “XT Ventures”, “we”, “us”, or “our” in this Privacy Policy includes, individually and collectively the following XT Ventures entities:

XT Ventures Pty Ltd;
XTV Sports Advisory Pty Ltd;
XTV High Performance Pty Ltd;
XTV High Performance Fund I, ILP
All other related entities including foreign entities within the XT Ventures Group including those added from time to time (other than those who maintain an individual privacy policy).

Personal Information XT Ventures collects

XT Ventures collects Personal Information that we believe is necessary to deliver our financial products and services (including other professional services), or otherwise for our business functions or activities. Most of this information we are required to obtain in order to satisfy Government requirements. For instance, we are required to confirm your identity for the purposes of complying with Anti-Money Laundering and Counter Terrorism Financing regulations.

The types of “personal information” (Personal Information) we may collect can include but is not limited to:

Name;
Date of birth;
Address;
Identification details
Contact details;
Bank account details;
Occupation and employment details;
Financial needs and objectives;
Investment preferences and aversion or tolerance to risk;
Current financial circumstance, including assets and liabilities;
Income and expenditure;
Family structure, including dependents;
Tax file number.

We will only collect personal information from you where you have provided your consent for us to do so.

Some Personal Information we collect is “sensitive information”. XT Ventures will only collect sensitive information about you where it is reasonably necessary for us to receive and we have your consent. Sensitive information is Personal Information that relates to your race, ethnicity, political stance, membership in trade or professional association, criminal records and health records.

Most of the Personal Information that we collect is obtained directly from our clients through application or other forms, and from maintaining records of information obtained in the course of providing our products and services. We may also obtain other information about you (not Personal Information) from third parties to supplement the Personal Information we have obtained from you. In the event of you not providing sufficient information required (or if you chose to use a pseudonym or remain anonymous) to fulfil your request for the provision of a product or service, we may be unable to provide you with the product or service that you requested.

Use and disclosure of Personal Information

XT Ventures will generally only use your Personal Information in relation to the provision of financial products and services or other professional services to you. If considered appropriate we may also use your Personal Information for internal communication purposes such as sending you research and notifying you of new products and services that may be suitable in meeting your financial or other objectives, unless you have notified us that you do not wish to receive such communications. You authorise XT Ventures to disclose necessary information to related companies, affiliates and any agents or contractors who provide services to us in connection with the provision of the products or services. XT Ventures will only enter these types of arrangements or disclose such information where we reasonably believe that the relevant party will only use your Personal Information for the specific purpose for which we supply it to them. Subject to what is permitted at law, the types of third parties we may disclose your Personal Information may include:

Service providers (customer relationship management system vendors, external administrators, custodians and responsible entities)
Entities that provide licensing and operational support services to XT Ventures, including Aura Capital Pty Ltd (ACN 143 700 887, AFS Licence 366230) and its related entities;
Organisations that are involved in managing or administering your finances, investments, superannuation, insurances etc, such as third party suppliers, printing and postal services, call centres;
Associated businesses that may want to market products to you;
Companies that provide information and infrastructure systems to us;
Anybody who represents you, such as finance brokers, lawyers and accountants, advisers, insurers investment/super providers;
Anyone, where you have provided us consent;
Where we are required to do so by law, such as under the Anti-Money or Laundering and Courter Terrorism Financing regulations;
Investors, agents or advisers, or any entity that has an interest in our business; or
Your employer, referees or identity verification services.

These disclosures may involve overseas storage and other overseas transfer, processing and use of your Personal Information. Further, your data may be disclosed by us to associated firms and vendors which conduct operational, technology and customer service functions in the USA, Australia, Singapore and other jurisdictions. Prior to transferring your data offshore, we will take appropriate steps to ensure the recipient of the personal data is bound by legally enforceable obligations to provide a standard of protection of the personal data that is at least comparable to the protection under the Privacy Act.

Storage of Personal Information collected

XT Ventures stores all Personal Information collected in secure computer storage facilities, paper-based files and other records, and take steps to protect your Personal Information that we hold from misuse, loss, unauthorised access, modification or disclosure. Organisations who provide support services to us and process your Personal Information on our behalf are required to appropriately safeguard the privacy of the Personal Information provided to them. We may be required by law to maintain records for a significant period of time. However, when we consider information is no longer required or relevant and any legal obligations that may apply to the information held have been met, we will remove details that identify you or we will securely destroy the records.

Direct marketing from XT Ventures

XT Ventures will directly communicate to you with regards to business updates, investment updates, business offers, publicity, changes to the organisation, offers you may find of interest and to introduce and offer new products and services. You have the option to opt out of receiving any XT Ventures marketing material, which is communicated via Email across the XT Ventures. The option to ‘unsubscribe’ from the emails will be available as a function at the bottom of the email. If you require any assistance please contact us at [email protected].

Updating Personal Information

XT Ventures aims to maintain up-to-date and accurate personal information. If you believe the personal information that XT Ventures holds is inaccurate, incomplete or out-of-date and XT Ventures agrees, the information will be amended. We will also take such steps (if any) as are reasonable in the circumstances to give notification of this correction to any third parties to whom it has been previously disclosed by XT Ventures. If we are unable to accept the changes requested, we will provide you with a written response outlining the reasons for not accepting your request to alter your personal information.

You should keep XT Ventures informed of any changes to your personal information and promptly advise us of changes when they arise.

Data Breach

We have obligations to notify you, the relevant privacy commissioner and other regulatory bodies in Australia of any notifiable data breaches, particularly if the breach may result in significant harm to you or is a wide scale data breach.

Access to Personal Information held by XT Ventures

XT Ventures may provide you with access to the personal information held about you, upon your request. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorised disclosure of your personal information. XT Ventures reserves the right to charge an appropriate fee for retrieving and supplying you with the information that you request. If a fee is chargeable we will advise you of the likely fee in advance. Certain circumstances may restrict XT Ventures from providing you with access to your personal information and we will provide you with a written response outlining the reason for denying you the access to the personal information we hold about you.

XT Ventures Websites

If you visit an XT Ventures Website to browse, read or download information, our system will log these movements. These website logs are not personally identifiable and XT Ventures makes no attempt to link them with the individuals who browse the website. XT Ventures may collect Personal Information from you when you enter our website www.xtventures.com. Cookies are used on our website to give you access to certain pages without having to log in each time you view the page. We may also use independent external service providers to track our website traffic and usage and serve you relevant content and advertising on third party digital assets.

Links to third party websites

From time to time we may place links on our website to external third party websites that we consider may be of interest to you. You should note that third party websites are not covered by our Privacy Policy. If you elect to link to the website of a third party, you may be asked to provide registration or other information. Please note that the information you are providing may be collected. You should familiarise yourself with the Privacy Policy adopted by that third party.

Using government identifiers:

XT Ventures does collect information in the form of government identifiers where appropriate. These can be in the form of Government issued identity documents, Tax File/Tax Identity Numbers. These identifiers are used for identification under Anti-Money Laundering Rules, or to determine what jurisdiction you reside in, or for required regulatory or tax reporting purposes. However, we will not use these identifiers as unique identifiers in our own systems.

Not identifying individuals:

Most of the XT Ventures entities require full client disclosure and access to some information which may be personal as described above. Identifying individuals is a general requirement of the law for many of the XT Ventures entities and is required to conduct our general business operations. Where possible we will accept your request to remain anonymous.

Privacy related enquiries or complaints

XT Ventures takes the required care when dealing with your personal information. However, if you have any questions or you are dissatisfied with how we have dealt with your Personal Information or our compliance with this Privacy Policy please contact our Privacy Officer on the details below. The Privacy Officer will respond as soon as possible confirming receipt of your compliant. Your complaint will be investigated in accordance with our complaints handling policy.

Privacy & Data Protection Officer

XT Ventures

223 Liverpool Street

Darlinghurst NSW 2010

Email: [email protected]

If you are not satisfied with our response to your complaint, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC), www.oaic.gov.au.

Please note we are always monitoring and reviewing our policies in place at XT Ventures, in order to keep up to date with market and legal expectations. We may be required to make amendments to this privacy policy.

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