The following Privacy Policy is applicable to all clients, users of this website, or any persons from whom the Goldman Sachs Group (as defined below) has collected or collects personal information, in connection with the collection, use and disclosure of personal information by the Goldman Sachs Group in Australia and New Zealand.
Unless stated otherwise, in this Privacy Policy, the ‘Goldman Sachs Group’, ‘us’, ‘we’ or ‘our’, means any of:
• Goldman Sachs Holdings ANZ Pty Limited;
• Goldman Sachs Australia Group Holdings Pty Ltd;
• Goldman Sachs Australia Pty Ltd;
• Goldman Sachs Financial Markets Pty Ltd;
• Goldman Sachs Asset Management Australia Pty Ltd;
• Goldman Sachs Australia Services Pty Ltd;
• Goldman Sachs New Zealand Limited; and/or
• any of their related bodies corporate or related companies wherever incorporated in Australia or New Zealand.
This Privacy Policy may change from time to time. Please visit our website regularly for the latest version.
The Goldman Sachs Group understands and appreciates that the privacy of personal information the Goldman Sachs Group may collect about you is important. The Goldman Sachs Group is committed to providing you with high quality financial services in a secure and confidential manner. The Goldman Sachs Group is bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) in Australia, and its obligations under the Privacy Act 1993 in New Zealand, when handling your personal information.
By providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.
Our Privacy Policy sets out, for your information:
• what personal information we may collect about you;
• to whom your personal information may be disclosed;
• the purposes for which your personal information may be used and disclosed;
• whether any information is disclosed (or stored) outside of Australia;
• our arrangements for the security of any personal information we hold about you;
• how you may access and correct your personal information;
• how you may make a complaint in relation to your privacy; and
• how you can contact us.
In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy provisions that apply to certain products and services provided by the Goldman Sachs Group, The Goldman Sachs Group, Inc. or any of its affiliates worldwide. These specific and additional provisions may also relate to your privacy protection and you should review them carefully. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail (to the extent permitted by law).
What personal information we collect about you
The term “personal information” in this Privacy Policy, has the meaning given to it in the Privacy Act 1988 (Cth) of Australia or the Privacy Act 1993 of New Zealand, as applicable to you. The personal information that we collect about you will depend on the Goldman Sachs services and products that you use, or which are used by entities that you are associated with. The types of information the Goldman Sachs Group has collected, or may collect, and hold will include (but are not limited to) information we use to identify you, your financial position and any other information that may be necessary to enable the delivery of services and products you (or entities associated with you) use. We may collect the following types of personal information:
• contact details, including your name, postal or street address, email address, telephone numbers and other contact details;
• identification information, including age or date of birth, gender, tax file number;
• financial information, including bank account numbers, credit card information or other information about your financial circumstances;
• details relating to your employment history;
• details relating to your investment profile;
• other identity verification information, including driver’s licence number, copy of driver’s licence, motor vehicle registration number, vehicle plate number, birth or citizenship certificate, passport number, and photographs;
• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
• details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
• any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or accounts from which you permit us to collect information; and
• any other personal information that may be required in order to facilitate your dealings with us.
We may collect sensitive information about you (being information about a person’s race or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, health information, genetic or biometric information). Unless required or authorized by law, we will only collect sensitive information if it is reasonably necessary for our functions or activities, and we will always obtain your consent (either directly from you or through a third party).
We may collect your personal information from you directly, or from third parties. Circumstances in which we may collect your personal information from third parties include:
• for payment purposes at your direction;
• to verify identity and for customer due diligence purposes;
• for the prevention and detection of money laundering and terrorism financing;
• background checking and verification in connection with recruitment;
• where you have consented to the collection of your personal information from third parties;
• where you have defaulted on payment or delivery of securities;
• where we are required or authorised by law to do so; and
• for the purposes of providing you with products, services or information in accordance with your requests or reasonable expectations.
Use and disclosure of personal information
The purposes for which the Goldman Sachs Group uses your information will vary depending on the Goldman Sachs services and products you have applied for or use, and the relationship which you have with us. By providing your personal information to the Goldman Sachs Group, you consent (where consent can be given under applicable law) to our use of your personal information for any purpose which is related to the purpose for which such information has been provided to the Goldman Sachs Group.
Your personal information may be disclosed to third parties for purposes described in this Privacy Policy or described in any other specific and additional privacy provisions that apply to certain products and services provided by the Goldman Sachs Group, The Goldman Sachs Group, Inc. or any of its affiliates worldwide. We may disclose your personal information to the following third parties (as distinct from the member of the Goldman Sachs Group to whom you have provided your personal information):
• your financial adviser, margin lending facility provider, other financial services provider providing services to you, your custodian or investment manager where applicable;
• any member of the Goldman Sachs Group, The Goldman Sachs Group, Inc. or any of its affiliates worldwide (including background checks and identity verification services);
• any third party service providers carrying out functions for or on behalf of the Goldman Sachs Group, The Goldman Sachs Group, Inc. or any of its affiliates worldwide;
• any person acting on your behalf including your solicitor, accountant, executor, administrator, trustee or guardian;
• Financial Services Protection Limited and its members;
• government agencies, courts of law, tribunals or regulators (examples include in connection with a subpoena or order with which a member of the Goldman Sachs Group must comply, or a regulatory investigation conducted by an Australian or New Zealand regulator of the Goldman Sachs Group); and/or
• any other third party with your consent or where authorised or required by law.
We may collect, hold, use and disclose your personal information for the purposes of:
• providing you with products, services or information in accordance with your requests or reasonable expectations;
• administering any accounts you hold with the Goldman Sachs Group, The Goldman Sachs Group, Inc. or any of its affiliates worldwide;
• enabling the Goldman Sachs Group, The Goldman Sachs Group, Inc. or any of its affiliates worldwide to ascertain whether or not they have other services or products which may foreseeably meet your needs or may be of interest to you, and to notify you about these services or products;
• conducting research, planning, product development, risk assessment, risk modelling and marketing by the Goldman Sachs Group, The Goldman Sachs Group, Inc. or any of its affiliates worldwide;
• sending you marketing, promotional messages and other information that may be of interest to you;
• conducting identity verification and customer due diligence;
• preventing and detecting money laundering and terrorism financing;
• determining whether you have any history of defaulting on payment or delivery of securities;
• considering your employment application and verifying your suitability to work with us;
• complying with our legal obligations including but not limited to our obligations under the Corporations Act 2001 (Cth), the Anti-Money Laundering and Counter Terrorism-Financing Act 2006 (Cth), the Proceeds of Crime Act 1987 (Cth), the United States’ Foreign Corrupt Practice Act, the United Kingdom’s Bribery Act, ASIC Market Integrity Rules, the Financial Markets Authority Act 2011 (New Zealand), the Financial Markets Conduct Act 2013 (New Zealand), the Financial Advisers Act 2008 (New Zealand), the Financial Service Providers (Registration and Dispute Resolution) Act 2008 (New Zealand), the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (New Zealand), any rules of relevant stock exchanges in Australia and New Zealand, and any associated Acts and Regulations enacted pursuant to those Acts named above;
• resolving any disputes that we may have with any of our users, and enforce our agreements with third parties;
• any other purpose to which you have consented; or
• disclosure where required or authorised by law.
We may use or disclose information about you in order to combine the information that we hold with information collected from or held by external sources. We do this in order to enable the development of customer insights about you so that we can serve you better. This includes being able to better understand your preferences and interests, personalise your experience, enhance the products and services you receive, and to tell you about products and services that may be of interest to you. Where those insights are provided to others, such insights are based on aggregated information and do not contain any information that identifies you. We may also use service providers to undertake the process of creating these consumer insights.
Disclosure of Government related or unique identifiers
Government Related Identifiers (including tax file numbers) are defined in the Australian Privacy Act and unique identifiers are defined in the New Zealand Privacy Act. We are required to comply with laws relating to the collection, storage, use and disclosure of Government Related Identifiers or unique identifiers.
We may collect and hold Government Related Identifiers or unique identifiers, such as your tax file number. We will not disclose any Government Related Identifiers or unique identifiers other than as required or permitted by law.
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may use and disclose your personal information to offer you services or products that we believe may interest you. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Australian and New Zealand Privacy Acts. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).
We will only use or disclose sensitive information about you for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.
Consequences if you do not consent to the collection or use of some or all of your personal information
Where you do not consent or do not provide the relevant member(s) of the Goldman Sachs Group with some or all of your personal information, depending on your relationship with such member(s) and the products or services for which you are applying, the Goldman Sachs Group may not be able to process your application or provide you with any of the requested products or services. Where such failure to provide personal information constitutes suspicious activity under relevant law, the Goldman Sachs Group may be required to report such failure to the relevant authorities.
Disclosing your information outside Australia or New Zealand
Given the global nature of the Goldman Sachs business, depending on the products or services being provided by the Goldman Sachs Group to you, your personal information may be disclosed outside of Australia or New Zealand to our related body corporate, or to our third party service providers carrying out functions on behalf of the Goldman Sachs Group, The Goldman Sachs Group Inc. or any of its affiliates worldwide or as required by law. We will take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
Employee record exemption
In Australia, this Privacy Policy does not apply to acts and practices in relation to personal information provided to, held, or used by the Goldman Sachs Group where that information forms part of an employee record for the purposes of the Privacy Act 1988.
Use of the Goldman Sachs website
By using a Goldman Sachs web site with your browser settings adjusted to accept cookies, you consent to our use of cookies and other tools to provide or improve the products and services available on those sites. For more information about cookies, please see our Cookies Policy available here.
Security of your personal information
The Goldman Sachs Group takes reasonable steps to preserve the security of personal information it collects. Personal information of clients, applicants and any other individuals are held in a secure environment in writing or electronically, or both. We have implemented security procedures, controls and protocols across all of our physical premises and electronic environments to ensure that personal information is protected from interference, loss, misuse, unauthorized access, modification, or disclosure. All stored client information is protected from unauthorised access through the use of secure passwords and user log ons or other security procedures. However, we cannot guarantee the security of your personal information.
Access and updating of information
The Goldman Sachs Group takes reasonable steps to make sure that the personal information which we collect, use and disclose is accurate, complete and up-to-date.
You are able to make a request to access and update the personal information that we hold about you. Please provide us with as much detail as possible to assist us to retrieve the personal information which you have requested. In accordance with privacy laws a reasonable fee may be charged to cover our costs if we provide you with access to your personal information. To request access to, or amend, the personal information that the Goldman Sachs Group holds, you should contact:
in Australia:
Privacy Officer
GPO Box 2050, Melbourne, VIC 3001
Australia
in New Zealand:
Privacy Officer
PO Box 887
Shortland Street, Auckland 1140
New Zealand
or via email:
privacy-ANZ@gs.com
The Australian or New Zealand Privacy Officer (as relevant) will respond to your request within a reasonable period after your request is made and, if it is reasonable and practicable to do so, provide you with access to your personal information in the manner you requested.
Please be aware, in certain circumstances, the Goldman Sachs Group may not be required to provide you with access to your personal information, or may decide that it is not appropriate to correct your personal information. If such a decision is made, we will provide you with a written notice setting out our reasons and other available options for you.
How you can contact us
If you have any questions or feedback about this statement or any complaints about our collection, storage or handling of your personal information, please contact the Privacy Officer in either Australia or New Zealand in writing at any time by using the contact details set out above.
If you are located in Australia, where you have made a privacy-related complaint, we will respond to your complaint by no later than 45 days after receipt. If you are not satisfied with our response to your complaint or your concerns are not satisfactorily resolved, you may contact the Financial Ombudsman Service:
Financial Ombudsman Service
GPO Box 3
Melbourne VIC 3001
Tel: 1300 780 808
Fax: +61 3 9613 6399
Website: www.fos.org.au
Email: info@fos.org.au
Should your dispute with the Financial Ombudsman Service fail to reach a satisfactory outcome, you may wish to contact the Office of the Australian Information Commissioner on 1300 363 992 or by email at enquiries@oaic.gov.au.
This Privacy Policy was last updated in February 2018. The Goldman Sachs Group may, at our discretion and without any prior or subsequent notice to you, amend or remove any part of this Privacy Policy at any time.