Privacy Policy

    This Policy applies to Hantec Markets (Australia) Pty Ltd (ACN 129 943 086) and any related entities, all of which are referred to as “HMA”, “we”, “our”, “us”. The Policy extends to and covers all operations and functions of HMA. At HMA, we are committed to ensuring the confidentiality and security of the personal information supplied by individuals. We are bound by the Privacy Act 1988 (“Privacy Act”), including the Australian Privacy Principles (“APPs”). All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by HMA must abide by this Privacy Policy. HMA makes this Policy available free of charge and can be downloaded from its website In this Policy:
    • ‘Disclosing’ information means providing information to persons outside HMA;
    • ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
    • ‘Privacy Officer’ means the contact person within HMA for questions or complaints regarding HMA’s handling of personal information;
    • ‘Sensitive information’ is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
    • ‘Use’ of information means use of information within HMA.
    We may collect and hold a range of information about you to provide you with our services, including:
    • your full name;
    • contact details;
    • date of birth;
    • employment details;
    • bank account details;
    • financial circumstances;
    • appetite for risk;
    • country of residency;
    • identification details such as passport or driver’s licence details required to be collected and verified in accordance with the Anti-Money Laundering and Counter Terrorist Act 2006;
    • proof of address such as utility bills and banks statements;
    • trading preferences;
    • trading history;
    • banking details;
    • credit information (if expressly authorised by the individual); and
    • other personal information we require to provide our derivative and foreign exchange trading services to you.
    We generally collect personal information directly from you. For example, personal information will be collected through our application processes, questionnaires, forms and other interactions with you in the course of providing you with our derivative and foreign exchange trading services, including when you visit our website, online trading platform, call us or send us correspondence.

    We may also collect personal information about you from a third party, such as identity verification services, your introducing broker or marketing agencies. If so, we will take reasonable steps to ensure that you are made aware of this Policy. We may also use third parties to analyse traffic at our website, which may involve the use of cookies. Information collected through such analysis is anonymous.

    HMA will not collect sensitive information about you without your consent unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

    If you do not provide us with the personal information we request, we may not be able to provide you with our products or services, or meet your needs appropriately.

    HMA does not give you the option of dealing with us anonymously, or using a pseudonym. This is because it is illegal or impractical for HMA to deal with individuals who are not identified.

    HMA may receive unsolicited personal information about you.  We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to HMA’s purposes for collecting personal information. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.
    The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:
    • clients;
    • potential clients;
    • prospective employees;
    • visitors to our website;
    • introducing brokers; and
    • service providers or suppliers.
    We collect and hold personal information about you so that we may:
    • provide you with our derivative and trading services;
    • review and meet your ongoing derivative and trading needs;
    • provide you with information relating to derivative trading that we believe may be relevant or of interest to you;
    • enter into agreements with third parties to conduct our business;
    • let you know about other products or services we offer, send you information about our special offers or invite you to events;
    • consider any concerns or complaints you may have;
    • comply with relevant laws, regulations and other legal obligations, such as the Anti-Money Laundering and Counter-Terrorism Act 2006 and the Corporations Act 2001; and
    • help us improve the products and services offered to our clients and enhance our overall business.

    We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act. 

    Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.

    We may disclose personal information to:
    • a related entity of HMA;
    • an agent, professional advisor or service provider we engage to carry out our functions and activities such as our counterparty banks, your introducing broker, lawyers, accountants, marketing agencies, compliance consultants and cloud computing storage providers;
    • organisations involved in a transfer or sale of all or part of our assets or business;
    • organisations involved in managing our corporate risk and funding functions such as securitisation;
    • financial institutions involved in managing our payments, such as banks;
    • regulatory bodies, government agencies, law enforcement bodies and courts; and
    • anyone whom you authorise us to disclose it.

    If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy.

    We are likely to disclose your personal information to our affiliates located in New Zealand. We also use cloud data storage providers, which means your personal information will be stored on servers that may be located overseas. Our servers are located in Hong Kong, Japan, New Zealand, UK and Australia.

    We will not disclose your personal information to overseas recipients without your consent unless:

    • we have taken reasonable steps to ensure that the recipient does not breach the Privacy Act, or the APPs; or
    • the recipient is subject to a similar information privacy regime.
    HMA recognises the importance of securing the personal information of our clients. We will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.

    Your personal information is generally stored in our computer database. Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:

    • passwords are required to access the system and passwords are routinely checked;
    • data ownership is clearly defined;
    • we change employees’ access capabilities when they are assigned to a new position;
    • employees have restricted access to certain sections of the system;
    • the system automatically logs and reviews all unauthorised access attempts;
    • unauthorised employees are barred from updating and editing personal information;
    • all computers which contain personal information are secured both physically and electronically;
    • data is encrypted during transmission over the network;
    • print reporting of data containing personal information is limited; and
    • reasonable steps are taken to destroy personal information when it is no longer required to be retained by law or for a permitted purpose under the APPs.
    HMA may only use personal information we collect from you for the purposes of direct marketing without your consent if:
    • the personal information does not include sensitive information; and
    • you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
    • we provide a simple way of opting out of direct marketing; and
    • you have not requested to opt out of receiving direct marketing from us.

    If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.

    You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.

    We do not adopt identifiers assigned by the Government (such as driver’s licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies. 
    We are committed to ensuring that the personal information we collect, hold, use and disclose is relevant, accurate, complete and up-to-date.

    We encourage you to contact us if any personal information we hold about you needs to be updated.  If we correct information that has previously been disclosed to another entity, we will notify the other entity of the correction within a reasonable period. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We will not charge you for correcting your personal information.

    Subject to exceptions in the Privacy Act, you can access the personal information that we hold about you by contacting the Privacy Officer. We will generally provide access within 14 to 30 days of your request.   If we refuse to provide you with access to the information, we will provide reasons for the refusal.

    We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged. We will advise the likely cost in advance.

    This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.
    It is the responsibility of management to inform employees and other relevant third parties about this Policy.  Management must ensure that employees and other relevant third parties are advised of any changes to this Policy. All new employees are to be provided with timely and appropriate access to this Policy, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Policy may be subject to disciplinary action.
    HMA must ensure that all contractual arrangements with third parties adequately address privacy issues.

    Each third party is aware of and understands this Policy, and has implemented policies in relation to the management of personal information in accordance with the Privacy Act, including:

    • regulating the collection, use and disclosure of personal information;
    • de-identifying personal information wherever possible;
    • ensuring that personal information is kept securely, protected from loss or misuse, with access to it only by authorised employees or agents of the related organisations; and
    • ensuring that personal information is only disclosed to organisations which are approved by HMA.

    Third parties specifically agree only to use personal information for the purposes authorised by HMA or by the individual concerned.

    HMA conducts periodic privacy audits in order to ascertain:
    • what sort of personal and/or sensitive information is collected and held;
    • how that information is collected;
    • what the reasons are for collection of that information;
    • where and how that information is stored;
    • how that information is secured;
    • who has access to that information;
    • whether that information is shared with anyone;
    • whether the intended use of collection is communicated; and
    • whether that information is current and necessary.
    If you have any questions about this Policy, or wish to make a complaint about how we have handled your personal information, you can lodge a complaint with us by contacting the Privacy Officer by:
    • telephoning – (02) 8017 8099
    • writing – HMA Privacy Officer, Level 25, Citigroup Centre, 2 Park St, Sydney, NSW 2000
    • emailing – This email address is being protected from spambots. You need JavaScript enabled to view it.

    If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:

    • telephoning - 1300 363 992
    • writing - Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
    • emailing - This email address is being protected from spambots. You need JavaScript enabled to view it.



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