Regulatory requirements governing our products and services make it necessary for 4xHub to collect certain information from you. If you complete the Application Form; trade online with us; or communicate with us (which includes the use of our website, speaking to us on the telephone or sending us correspondence or information by post or email to us), you will be supplying 4xHub with, and 4xHub will be collecting, information that is “Personal Information”.
In Australia, 4xHub will deal with your personal information in accordance with the Australian Privacy Principles issued in accordance with the Privacy Act 1988 (Cth) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) (collectively, “Privacy Act”) with the Australian Privacy Principles (“APPs”). Personal information is defined under Section 6 of the Privacy Act as “information or an 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 material form or not.”
Common examples of personal information are an individual’s name, signature, photo, address, telephone number, date of birth, medical records, bank account details and commentary or opinion about a person. 4xHub may also need to collect other personal details (such as financial information, gender and marital status) and other information from which you can be identified.
Unless required by law or where you consent for us to do so, we generally do not collect sensitive information about you. We will not collect sensitive information about you where this is expressly prohibited by local law. Sensitive information includes information relating to:
- Biometric and health information;
- Criminal convictions;
- Membership of professional or trade associations or unions;
- Political affiliations or views;
- Religious beliefs;
- Sexual orientation and sexual life;
- Information about your affiliation with certain organisations, such as professional associations.
Additional material Information required for fulfilling most financial requests and applications includes:
- Information establishing your identity, such as your name, address, phone number, title, business phone number, email address, date of birth, social insurance number or social security number (for tax purposes), and account numbers;
- Information to authenticate your identity, such as knowledge-based information (i.e. username, password and account information), biometric information (i.e. signature, fingerprint and voiceprint), device information (i.e. device model, browser type, IP address, security cookie and approximate physical location of device);
- Information related to transactions arising from your relationship with and through us, and from other financial institutions, including point of sale details;
- Information you provide on an application for the provision of our products and services, such as your annual income, place of employment, investments, account balance, financial liabilities, transaction history;
- Information you provide during communication with us which may include family details, life events, goals and your opinions and issues you may have encountered;
- Information about financial behaviour such as your payment history and credit worthiness;
- Information about your health may be collected for insurance products and services;
- Information pertaining to business clients will include your business name, address, phone number, email address, industry type, financial status and detail(s) on the owner(s), operator(s) and director(s);
- Collection and disclosure of personal information
We may collect and use your Personal Information for the following purposes:
- Identification and verification of certain persons to comply with anti-money laundering and counter-terrorism financing (“AML/CTF”) obligations;
- Assessing your application; assessing the credit and other exposure that 4xHub has to you (see below for more details regarding the use of your Personal Information for credit checking purposes);
- Marketing of similar products and services; determining future product and business strategies and to develop 4xHub’s products and services; communicating with you in relation to 4xHub’s products and services including in relation to any Transaction made and/or your Account;
- Providing products and services to you;
When we communicate with you for the above purposes, you consent to receiving communications from us in any form, including email. Your Personal Information may be disclosed to entities associated with 4xHub, 4xHub’s counterparties or third party product or service providers for the above purposes. It may also be disclosed to any financial institution nominated by you and may be disclosed to your financial adviser if you request so in writing. Your personal information may be transmitted through, stored or processed in countries other than your region, in which case the information is bound by the laws of these countries.
These countries may include, but are not limited to, Australia, Canada, European Union member states, New Zealand, South Africa, and the United Kingdom.
We will not disclose your Personal Information to any other third party except where required to or permitted to by law, where you have authorised us to do so, or where disclosure is connected to the purposes for which the information was collected. You can, by contacting us, instruct us not to disclose your Personal Information to companies related to us. If you do not wish to be kept informed of 4xHub’s marketing or promotional activities electronically, please contact us via email.
We may use service providers to perform specialised services on our behalf such as marketing, mail distribution or data processing. Our service providers may at times be responsible for processing or handling personal information. They are only provided with the information necessary to perform the services. In addition, we require them to protect the information in a manner that is consistent with our privacy policies and security practices.
We do not sell Personal Information to other organisations.
Access to your information is restricted to authorised employees who have a legitimate business purpose for using it. Unauthorised use and or disclosure of client information by an employee of 4xHub is strictly prohibited. All employees are required to maintain the confidentiality of client information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
In the event of a corporate sale, merger, reorganisation, dissolution or similar event, Personal Information may be part of the transferred assets.
While the information we ask you to supply is not required by law, we may not be able to assess your application if the information is not supplied.
Anti-money laundering and Know Your Client information
In accordance with the Anti-Money Laundering and Counter-Terrorism Act 2006 (Cth) (“AML Act”), 4xHub has an obligation to collect information about and verify the identity of its clients and certain individuals, this includes any directors, members and ultimate beneficiary owners of a company. This information is referred to as Know Your Client information or KYC information which may include your full name, address, date of birth, email address and contact details. 4xHub will carry out its customer identification and verification procedures in accordance with the Privacy Act 1988 (Cth).
Information verification and database checks
4xHub may use the services of a third-party identification verification service provider (such as a credit reporting agency or government database) to conduct a verification check on you which will be used for verification of the identification information that you have provided. The third-party verification service providers used to verify your identification details include:
- Credit data files held by a credit reporting agency (for identification purposes only, and not a credit check).
- Publicly available information such as the electoral roll
- Information held the official record holder via third party systems, such as Commonwealth and State government departments
As a result of 4xHub’s enquiry to that/those credit reporting agencies and databases:
- That/those credit reporting agencies may provide 4xHub with information, including Personal Information, about you;
- 4xHub may provide Personal Information to the credit reporting agencies and the credit reporting agencies will hold the Personal Information on their systems and use it to provide their credit reporting service, which may include providing the Personal Information to third parties that may use the credit reporting agencies’ services; and
- 4xHub may use one or more credit reporting agencies’ services in the future for purposes related to the provision of 4xHub’s services to you. This may include using that/those credit reporting agencies’ monitoring services to receive updates if any of the information held about you changes.
If you fail to perform your obligations under the Client Agreement or any transaction, information about that default may be given to one or more credit reporting agencies and/or databases, and the credit reporting agencies may give information about your default to other customers of that/those credit reporting agencies.
4xHub will not provide any credit reporting agencies with information regarding the specific Transactions that you enter into.
When you visit our website, we (or our service providers in connection with the website) may use technology to collect information to assist us with administering the website and with enhancing the content and facilities on the website. An example of the technology that we use is “cookies”.
A “cookie” is a packet of information placed on a user’s computer by a website. The purposes for which cookies are used on this website may include:
- Enabling access to online services;
- Managing advertising – we may use advertising companies to deliver our online advertising. When you see one of our ads on a third party website, cookies are sometimes used to collect information about what pages you visit and the type of software you are using; and
- Monitoring web traffic – we may use tracking companies to gather information about how people are using the 4xHub website, this information includes time of visit, pages visited, and some system information about the type of computer you are using.
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
Our Website may contain links to and from the websites of our advertisers and/or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please familiarise yourself with these policies before you submit any Personal Information to these websites.
4xHub takes steps to ensure that appropriate standards of privacy practice and security are applied when we handle personal information. Regardless of our your jurisdiction, you have rights to access and to correct the Personal Information we hold about you.
As a 4xHub client you will receive periodic access to information in the form of transaction activity records, including account statements and trade confirmations. This information is routinely available to you through mailings, secure online sites and smart phone application.
You can contact us by phone or email including requesting access to your information. In normal circumstances, we will give you full access to your information. However, there may be some legal or administrative reason to deny you access, in which case we will tell you of that reason. Further, we may impose a charge to give you full access where your request requires the compilation of information that has been archived or is significant in volume.
If you have any concerns about the accuracy of your Personal Information, please contact our Compliance team in your local jurisdiction.
Under the Privacy Act you have rights to access and to correct the Personal Information we hold about you.
Your Personal Information will be held by us and the firms’ registered and physical address is 4xHub Pty Ltd, Level 1, 320 Pitt Street, Sydney, NSW, 2000, Australia. Your Personal Information will be retained only for as long as necessary to fulfil the purposes for which it was collected.
Phone: +61 (0) 288 665 300