Privacy Policy

1. Introduction

Brenton Financial Pty Ltd (ABN 21 696 298 227), trading as "Brenton," and its affiliates are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us.

By accessing our website or using our services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy.

2. Information We Collect

2.1 Personal Information

We may collect personal information that you voluntarily provide to us, including:

• Name, contact details (email address, phone number, mailing address)
• Professional information (company name, job title, industry)
• Financial information (investment history, financial objectives, assets under management)
• Identity verification documents (passport, national ID, proof of address)
• Bank account and payment information
• Communications with us (emails, meeting notes, correspondence)

2.2 Automatically Collected Information

When you visit our website, we automatically collect:

• Device information (IP address, browser type, operating system)
• Usage data (pages visited, time spent, click patterns)
• Location data (based on IP address)
• Cookies and similar tracking technologies

2.3 Information from Third Parties

We may receive information about you from third parties, including business partners, service providers, publicly available sources, credit reference agencies, and regulatory bodies.

3. How We Use Your Information

We use your information for the following purposes:

• Service Delivery: To provide advisory services, execute transactions, and manage client relationships
• Client Onboarding: To verify your identity, conduct due diligence, and comply with regulatory requirements
• Communication: To respond to inquiries, send updates, and provide relevant market insights
• Risk Management: To assess and manage financial, operational, and regulatory risks
• Legal Compliance: To comply with anti-money laundering (AML), know-your-customer (KYC), and other regulatory obligations
• Analytics: To improve our website, services, and user experience
• Marketing: To send you information about our services (with your consent where required)
• Security: To detect, prevent, and address fraud, security breaches, and technical issues

4. Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contractual Necessity: Processing necessary to perform our advisory services and contractual obligations
• Legal Obligation: Processing required to comply with regulatory, tax, and legal requirements, including those under the Australian Privacy Act 1988 (Cth)
• Legitimate Interests: Processing necessary for our legitimate business interests, including risk management and service improvement
• Consent: Where you have provided explicit consent for specific processing activities

5. Information Sharing and Disclosure

We may share your information with:

• Affiliated Companies: Brenton entities in Australia
• Service Providers: Third-party vendors providing IT, legal, accounting, and administrative services
• Transaction Partners: Counterparties, lenders, investors, and other parties involved in transactions
• Regulators and Authorities: Financial regulators (including ASIC), tax authorities, law enforcement, and courts
• Professional Advisors: Lawyers, auditors, and consultants bound by confidentiality obligations
• Business Transfers: In connection with mergers, acquisitions, or sale of assets

We do not sell your personal information to third parties for marketing purposes.

6. International Data Transfers

Your personal information is primarily stored and processed in Australia. Where we transfer your information outside Australia, we implement appropriate safeguards to protect your information in accordance with the Australian Privacy Principles (APPs).

7. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security audits and vulnerability assessments
• Employee training on data protection and confidentiality
• Secure data centres with physical and logical access controls

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

8. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary based on:

• The nature of our relationship and services provided
• Regulatory requirements (typically 7-10 years for financial records)
• Legal obligations and potential disputes
• Legitimate business purposes

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights under applicable law, including the Australian Privacy Act 1988:

• Access: Request access to your personal information
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your information (subject to legal obligations)
• Restriction: Request restriction of processing in certain circumstances
• Portability: Request transfer of your information to another service provider
• Objection: Object to processing based on legitimate interests or for marketing purposes
• Withdraw Consent: Withdraw consent at any time (without affecting prior processing)
• Complain: Lodge a complaint with a data protection authority, including the Office of the Australian Information Commissioner (OAIC)

To exercise your rights, please contact us using the details in Section 13.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience, analyse website traffic, and provide personalised content.

Types of cookies we use:

• Essential Cookies: Required for website functionality
• Analytics Cookies: Help us understand how visitors use our website
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Deliver relevant advertisements (with your consent)

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. We will post the updated policy on this page with a revised "Last Updated" date.

Material changes will be communicated via email or prominent notice on our website. Your continued use of our services after changes constitutes acceptance of the updated policy.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact: