We are committed to protecting your privacy

1. ​This document outlines the policy on handling the personal information that Sitali Pty Ltd (hereafter “Sitali” or “we”) and its related companies collect about individuals including customers and potential customers. 

2. Sitali recognises the importance of privacy and we are committed to protecting your personal information. We arerequired to comply with the Privacy Act 1988 (Cth) which provides for the fair handling of personal information, andsets standards for the collection, access, storage and use of personal information. Our policy for dealing with anypersonal information that you disclose to us is explained below. 

About this Privacy Policy

1. This Privacy Policy outlines how we manage your personal information. It also describes generally the types of personal information held, for what purposes, and how that information is collected, held, used and disclosed. 

2. This Privacy Policy applies to all your dealings with us whether using the Sitali website (www.Sitali.com), inwriting or in person. By dealing with Sitali, you consent to our use and disclosure of your personal information in themanner described in this Privacy Policy. We encourage you to check our website regularly for any updates to our Privacy Policy.

​​​What personal information does Sitali collect and why?

1. Sitali collects information in a number of different ways including directly, indirectly and through third parties. These include (but are not limited to) the following:

   1.  ​its website;

   2. email;

   3. social media;

   4. over the phone; and

   5. in person

2. Depending on your purpose for contact, the information we collect for you may vary. The information may include (but is not limited to) the following:

   1. ​Your name, address, telephone number and email address;

   2. Key contract data (contractual/legal relationships, contractual or product interest);

   3. Details of interaction between you and Sitali’s staff;

   4. Feedback in relation to your experience with Sitali;

   5. Your geographic location;

   6. Web browser type and version; and

   7. Network and device identification (including IP address). 

3. Generally, the purpose for which Sitali collects personal information will be apparent from the way in which it collects it or will be disclosed at the time of collection. If at any time the purpose for which Sitali is collecting your personal information is unclear, please raise your concerns initially with the person you are dealing with or by contacting hello@sitali.com .

4. If you, or a company you work for, supplies goods or services to Sitali, Sitali may collect personal information about you in connection with the provision of those goods or services, either directly from you or from that company. This information may include your name, date of birth, contact information, and any other information you provide. This information will be used for the purposes of managing the provision of those good or services.

5. Although Sitali may use your personal information as stated above, Sitali may also use your personal information for secondary purposes. Sitali may communicate news, promotional offers or special events to you or Sitali may use personal information for marketing, research, planning and product development purposes. Sitali uses this information to conduct its business, to communicate with you to provide or promote Sitali’s business and to help Sitali manage and enhance its business. Where you have consented to receiving these communications from Sitali, that consent will remain current until you advise Sitali otherwise. However, you can opt out at any time by contacting hello@sitali.com or by unsubscribing to Sitali’s commercial electronic messages as set out below.

6. In addition, Sitali is required by law to collect some personal information. Such laws include (but are not limited to) the Anti- Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Corporations Act 2001 (Cth), the National Consumer Credit Protection Act 2009 (Cth) and the U.S Foreign Account Tax Compliance Act.

7. By continuing to engage Sitali, you provide your consent to Sitali collecting and handling your Personal Information inaccordance with this policy. Such consent may be withdrawn at any time upon written notice.

Will my personal information be used for direct marketing?

1. Sitali may also use and disclose your personal information to keep you informed about the Sitali business. Personal information of individuals is only used to market relevant products and services specific to that individual. 

2. You can opt out of receiving direct marketing from Sitali at any time (see the ‘How can you contact Sitali about privacy’ section below).

3. Sitali will not disclose your personal information to a third party for the purposes of direct marketing unless you have given your express consent for such disclosure and use.

 ​What happens if I do not provide information that has been requested?

1. It is your choice whether to provide your personal information. However, if you don’t, Sitali may be unable to fulfil your request for a specific service or request or may affect Sitali’s ability to properly analyse your personal circumstances to effectively perform the services offered by Sitali. 

Other information Sitali collects

1. Sitali may also collect the following information from you:

   1. ​The fully qualified domain name from which you accessed our websites, or your IP address;

   2. The date and time you accessed each page on Sitali’s websites;

   3. The URL of any webpage from which you accessed Sitali’s websites (the referrer);

   4. Cookies which track your visits to Sitali’s websites; and

   5. The web browser that you are using and the pages you accessed.

2. Sitali uses this information so that it can tell which pages are the most popular and where people spend most of their time. Sitali uses this information to improve its website. In some circumstances Sitali may collect personal information about an individual from a third party, for example, to analyse traffic at its website.  If this information is linked with personal information Sitali holds about you as set out above, this information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.

3. The Sitali website and its affiliate websites use cookies, which are pieces of information that a website transfers to an individual’s computer for record-keeping purposes. The only personal information that a cookie can contain is information you personally supply. Sitali recommends you accept cookies to take full advantage of the services this website provides. They allow Sitali to customise information to improve user experience and for tracking user navigation. However, if you are concerned about the use of cookies, you can set your browser to refuse cookies, or to warn you when cookies are used.

What types of personal information does Sitali collect?

1. Sitali may ask for a range of personal information to assist it in providing you with relevant products and services. Sitali will not collect personal information unless the information is reasonably necessary for one or more of itsfunctions or activities. The information Sitali may request includes (but is not limited to) name, address, date of birth,contact details, income, credit and debit card or bank account information, assets and liabilities, tax and financial statements, health information, employment details, domicile and citizenship status.

Does Sitali collect sensitive information?

1. Sitali sometimes needs to collect and use sensitive information.

2. Sensitive information may include information or an opinion relating to a person’s racial or ethnic origin, political views or memberships, religious beliefs or affiliations, membership of a professional or trade association or trade union, sexual orientation or practices and criminal record. It also includes information about a person’s health andmedical history.

3. The Australian Privacy Principles set out circumstances in which sensitive information may be collected and used.

4. Unless you give Sitali your consent, or if Sitali is required or permitted by law, Sitali will only use or disclose sensitive information for the purposes for which it was provided.

Dealing with unsolicited personal information

1. Where it becomes apparent that a communication contains unsolicited personal information that would not otherwise be lawfully requested or used, Sitali will make reasonable efforts to delete, destroy or de-identify the record of such personal information.

2. Where it is impracticable to delete, destroy or de-identify (for example, where the unsolicited information is combined with necessary information) the record will be retained. Sitali will take all reasonable steps to protect the personal information against loss, unauthorised access, use, modification or disclosure, and against other misuse.

3. At or before the time or, if that is not practicable, as soon as practicable after, Sitali collects personal information aboutyou, Sitali will take such steps as are reasonable in the circumstances to inform you of Sitali’s identity, its contactdetails and all relevant matters referred to in Australian Privacy Principles.

4. If you apply for a job with Sitali, Sitali will hold, use and disclose that information solely for the purpose of considering your application. In particular, in considering your application, it may be necessary for Sitali to disclose some of that information to third parties to verify the accuracy of that information. In such circumstances, Sitali will disclose only such information as is necessary in the circumstances. In considering your application, Sitali may alsocollect personal information about you from any third parties that you nominate as your referees in your application.

Can you remain anonymous or use a pseudonym when dealing with Sitali?

1. Where reasonable and practicable to do so, Sitali will collect your Personal Information only from you. However, in some circumstances Sitali may be provided with information by third parties. In such a case Sitali will take reasonable steps to ensure that you are made aware of the information provided to Sitali by the third party.

2. We understand that anonymity is an important element of privacy and some members of the public may wish to beanonymous when interacting with Sitali. We also understand some members of the public may wish to use a pseudonym. If you wish to remain anonymous or to use a pseudonym when dealing with Sitali, Sitali may be able to provide you with limited information or services, such as general details about its business.

3. However, in many cases it will be impractical for Sitali to assist you if you wish to remain anonymous or use a pseudonym. Because of this, if you choose not to identify yourself or wish to use a pseudonym, Sitali may be unableto provide you with the specific service or request.

How does Sitali protect your personal information?

1. Sitali is committed to keeping your personal information secure. Whether your personal information is gathered through face to face meetings or by interacting with Sitali via telephone, mail, internet or other methods, Sitali takes reasonable steps to store your information securely. Sitali holds your personal information in a combination of secure computer storage facilities, paper-based files and other formats.

2. Sitali takes a number of steps to protect personal information from misuse, interference and loss, unauthorised access,modification or improper disclosure. These include instructing Sitali’s staff and professional advisers who handle personal information to respect the confidentiality of customer information and the privacy of individuals.

3. While Sitali uses all reasonable endeavours to ensure that you provide personal information in a secure environment, no data transmission over the internet can be guaranteed as totally secure. Whilst Sitali maintains regular and up to date security checks, it does not accept responsibility for the security of information transmitted to us over the internet.

4. Sitali’s website may contain links or plug-ins to other sites. Sitali is not responsible for the content of or the privacy practices or policies of those sites.

Who does Sitali share personal information with?

1. From time to time Sitali may share your personal information with other entities both within and outside of Sitali. The entities that Sitali might share your personal information with vary according to the service involved, but could include:

   1. other areas and organisations within Sitali or related entities of Sitali;

   2. professional advisers of Sitali;

   3. other parties authorised by Sitali;

   4. courts, tribunals and other dispute resolution bodies in the course of a dispute;

   5. anyone authorised by you or to whom you have provided your consent (either expressly or impliedly); and

   6. anyone to whom Sitali, or its related entities, are required or authorised by law to disclose your personal information for example, law enforcement agencies, and national and internationalgovernment and regulatory authorities including but not limited to the Australian Taxation Office, the Australian Prudential Regulation Authority, the Australian Securities and Investments Commission, and the Australian Transaction Reports and Analysis Centre.

2. ​In the event that Sitali believes that the use or disclosure of the personal information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of an enforcement body, Sitali will make a written note of such use or disclosure. ​

How does Sitali update personal information?

1. We realise that your personal information changes frequently. Sitali will take all reasonable steps to ensure that the personal information it holds is accurate, up-to-date, complete and relevant. Where Sitali holds personal information about you and it is found that, having regard to a purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading, or you request that Sitali correct the information, Sitali will take such steps as are reasonably necessary to correct that information and to ensure that it is accurate, up to date, complete, relevant and not misleading.

2. Similarly, if Sitali corrects personal information about you that was previously disclosed to a third party, Sitali will take all reasonable steps to give notification to the third party of the correction.

3. If Sitali believes the information it holds is incomplete or out of date, Sitali may also seek to correct or complete its records by gathering data from other sources such as public records and other organisations.

4. In the event that Sitali refuses to correct the personal information that you have requested, Sitali will give writtennotice as to the reasons for refusal and mechanisms available for complaint.

​How long will Sitali keep your information?

1. Sitali may be legally required to maintain some of your records for a significant period of time. However, once Sitali believes information held by it is no longer needed Sitali may remove any identifying details or destroy the records entirely.

2. Sitali will also take steps to destroy or delete personal information within a reasonable time if Sitali receives a written notification from you that you withdraw your consent to our storing and processing of your personal information and/or if you request that this information be destroyed or deleted in circumstances where Sitali are not otherwise required by law to retain that information.

​How can you contact Sitali about privacy?

1. You have the right to contact Sitali by emailing hello@sitali.com to:

   1. ​seek more information about anything contained in this policy, or to request a copy of this policy in a differentformat;

   2. update or correct your personal information;

   3. opt out of receiving direct marketing material;

   4. ask about accessing or correcting the personal information Sitali holds about you; or

   5. making a privacy related complaint​

2. Under the Privacy Act you have the right to access the personal information Sitali holds about you, with someexceptions. You can also request for Sitali to correct any inaccurate, incomplete or out-of-date personal information. For security reasons, an access form outlining what information you require must be completed. Access forms can be obtained by contacting Sitali as set out above.

3. Sitali is permitted to refuse access to personal information in certain situations. Examples include (but are not limited to) where:

   1. ​giving access would have an unreasonable impact on the privacy of other individuals;

   2. giving access would be unlawful, or where denying access is required or authorised by and Australian law or acourt order;

   3. information relates to existing or anticipated legal proceedings (and would not be accessible through process ofdiscovery);

   4. request for access is frivolous or vexatious;

   5. giving access would prejudice enforcement body related activities;

   6. giving access would reveal commercially sensitive information;

   7. both of the following apply:

      1. Sitali has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to its functions or activities has been, is being or may be engaged in; and

      2. giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or

   8. giving access is likely to interfere with law enforcement activities.

4. Sitali will respond to a request for access within a reasonable period after the request is made and will give access to the information in the manner requested by the individual if it is reasonable and practicable to do so. Before providing the requested information Sitali reserves the right to give you an estimate of any potential costs that would reasonably be incurred by Sitali in retrieving archived data.

5. Upon Sitali declining access to information because of one of the above conditions, it will take such steps as are reasonable in the circumstances to give access in a way that meets the needs of the entity and the individual. Similarly, Sitali will provide reasons for the refusal and the mechanisms available for complaint.

Does Sitali collect information about children?

1. Sitali understands the importance of protecting the privacy of children, especially in an online environment. In particular, Sitali’s website, products and services are not intentionally designed for, or directed at, children under the age of 13. It is Sitali’s policy to never knowingly collect or maintain information about any person under the age of 13.

​What should I do if I have a complaint?

1. Your privacy is important to Sitali and Sitali will make every effort to resolve your concerns.

2. To raise any concerns you might have in relation to privacy, please contact Sitali via the contact channels listed below this section.

3. Sitali takes privacy-related complaints very seriously and considers all complaints carefully as part of its commitment to being open, honest and fair in dealing with your concerns. In most cases, Sitali will contact you within five (5) working days of receiving your complaint to let you know what actions Sitali is taking regarding the matter. If you are not satisfied with Sitali’s handling of your complaint or Sitali has not replied to you within a reasonable period of time, then you may be entitled under applicable law to make a complaint to the relevant regulator.

​Contact Details

1. By email: hello@sitali.com

2. If you still have concerns, further assistance may be available from:

   1. Australian Financial Complaints Authority (AFCA)

      1. Online: www.afca.org.au 

      2. Email: info@afca.org.au

      3. Phone: 1800 931 678 (free call)

      4. Mail: Australian Financial Complaints Authority GPO Box 3, Melbourne VIC 3001, or

   2. The Office of the Australian Information Commissioner

      1. Phone: 1300 363 992

      2. Website: www.oaic.gov.au 

      3. Email: enquiries@oaic.gov.au

Interactive Tools

1. Sitali’s website provides you with many interactive tools designed to help you understand its business and its business operations. 

2. Sitali may collect personal information you enter when using the interactive tools on our website or through ourapplications.

​What is a cookie and how does Sitali use cookies?

1. Sitali uses cookies to monitor your use of its website, to observe behaviour, compile aggregate data and provide you with a more effective service. Cookies are small pieces of text stored on your computer to help Sitali determine the type of browser and settings you are using, where you have been on the website, when you return to the website,where you came from, and to ensure your information is secure. The purpose of this information is to provide you with a more relevant and effective experience on Sitali’s websites, including presenting web pages according to your needs or preferences.

2. Sitali uses cookies to give you access to certain pages of the website without having to log in each time you visit. Sitali may also use external service providers to track the traffic and usage on the website.

3. Cookies are frequently used on many websites and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. You may not be able to access some parts of Sitali’s websites if you choose to disable the cookie acceptance in your browser, particularly the secure parts of the website. Sitali therefore recommend you enable cookie acceptance to benefit from all the services on the website.

​Links to third party websites

1. Sitali’s website from time to time may have links to external third party websites that benefit the user.

2. External websites should contain their own privacy statements and we recommend you review them when using their websites. Please note, however, that third party websites are not covered by this policy, and these sites are not subject to Sitali’s privacy standards and procedures.

About this policy

1. Any information Sitali holds is governed by the most current Sitali Privacy Policy. The policy is available via our website www.Sitali.com, or you can contact us about obtaining the policy in different formats (see the ‘How can you contact Sitali about Privacy’ section).

2. This policy is reviewed from time to time to take account for new laws and technology, and changes to Sitali’s operations and practices, and to make sure it remains appropriate in the changing environment.

3. This policy applies to Sitali and all Sitali’s related entities operating globally

4. Certain Sitali related entities may adopt additional procedures relating to the collection and handling of personal information. Such documentation does not detract from the Sitali Privacy Policy and any intra-related procedures between the Sitali entities intended to be read together.