Our commitment to your privacy
Phajong Holdings and Investments Pty Ltd respects the privacy of every person we deal with. We are bound by the Privacy Act 1988 (Cth) and the thirteen Australian Privacy Principles (APPs), and we take a deliberate, disciplined approach to how personal information is gathered, stored, used and disclosed.
This policy explains, in practical terms, how those obligations apply across our investment holdings and wealth management activities, and how you can exercise your rights.
Who we are, and who this policy applies to
Phajong Holdings and Investments Pty Ltd (ABN 50 704 008 239) is an investment holdings and wealth management firm based in Melbourne VIC. In this policy, “we”, “us” and “our” refer to Phajong Holdings and Investments Pty Ltd as the APP entity responsible for your personal information.
This policy applies to our clients and prospective clients, website visitors, service providers, referrers and job applicants. It should be read alongside our Terms of Use.
The information we collect
We only collect personal information that is reasonably necessary for our functions and activities. Depending on your relationship with us, this may include:
- Identity and contact details — your name, date of birth, residential or postal address, email address and preferred contact method.
- Verification information — identification documents and particulars (for example, passport or driver licence details) used to verify your identity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
- Financial information — investment objectives, risk profile, source of funds, banking details and tax residency. Where you choose to provide a tax file number, we handle it in accordance with the Tax File Number Guidelines issued by the Office of the Australian Information Commissioner.
- Portfolio and transaction information — holdings, instructions, statements and correspondence relating to your investments.
- Corporate information — director, shareholder and beneficial-ownership details drawn from public registers where we hold or manage entity structures.
- Website and technical information — IP address, device and browser type, referring pages and activity on phajongholdings.site, collected through cookies and similar technologies.
Sensitive information is only collected where it is reasonably necessary for one of our functions, with your consent, or where the law otherwise permits.
How we collect information
- Directly from you — when you complete a form on this website (including our quote and contact pages), email us, or meet with us.
- From your advisers and referrers — such as your accountant, solicitor or broker, where you have authorised them to share information with us.
- From public and commercial sources — including ASIC registers and identity-verification services.
- Automatically — through cookies, analytics tools and server logs when you use our website.
Wherever practicable, we collect information directly from you and tell you the purposes for which it is being collected at or before the time of collection.
Why we collect it
We collect, hold, use and disclose personal information to:
- provide investment holdings, portfolio and wealth management services, and administer your accounts;
- verify your identity and comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Corporations Act 2001 (Cth) and taxation laws;
- process transactions, distributions and investor reporting;
- manage risk, prevent fraud and protect the security of our systems and client assets;
- respond to enquiries and provide ongoing client care;
- improve the performance, content and usability of our website; and
- send you market insights or service updates, where you have opted in or where the law permits.
We do not use or disclose personal information for a purpose other than the primary purpose of collection unless you would reasonably expect it, you have consented, or an exception under the APPs applies.
Who we disclose information to
Depending on the services we provide, we may disclose personal information to:
- custodians, brokers, platform providers and share registries engaged to hold assets or execute transactions;
- professional advisers, including auditors, lawyers and accountants, engaged in connection with our services;
- technology providers, including cloud hosting, email, document management and analytics suppliers;
- identity-verification and fraud-prevention providers; and
- government agencies and regulators — such as ASIC, AUSTRAC and the ATO — where required or authorised by law.
We do not sell, rent or trade personal information, and we require third parties we engage to handle it only on our instructions.
Overseas disclosure
Some of the technology providers we use host data or provide support services outside Australia, which may include Singapore, the United States or the European Union. Where personal information is likely to be disclosed to an overseas recipient, we take reasonable steps under APP 8 to ensure it is handled consistently with this policy, typically through contractual safeguards and supplier due diligence.
Security and retention
We apply technical and organisational measures appropriate to the sensitivity of the information we hold, including encryption of data in transit, multi-factor authentication, role-based access controls, least-privilege permissions and ongoing staff awareness training. Physical records are stored securely and destroyed by secure means.
We retain personal information for as long as it is required for the purposes set out in this policy and to meet our legal record-keeping obligations — generally at least seven years after the end of a client relationship — after which it is securely destroyed or de-identified.
Access to, and correction of, your information
You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Requests can be made at any time by emailing ceo@phajongholdings.site. We will verify your identity, respond within a reasonable period (usually within 30 days) and generally do not charge for access requests. If we decline a request, we will explain our reasons and how you can complain.
Cookies and analytics
Our website uses cookies and similar technologies to operate the site, remember preferences and understand how pages are used. You can configure your browser to refuse cookies or to delete them; some features of the site may not function as intended if you do. We do not use cookies to identify you personally across unrelated third-party websites.
Our website may also contain links to third-party sites. We are not responsible for the privacy practices of those sites, and we encourage you to review their policies before providing any personal information.
Direct marketing
We may use the contact details you have provided to share insights, market updates or information about our services, in accordance with APP 7. Every marketing communication includes a simple way to opt out, or you can ask us to stop at any time by emailing ceo@phajongholdings.site. We will action your request promptly and record your preference so it is honoured in future.
Data breaches
Under the Notifiable Data Breaches scheme in the Privacy Act 1988 (Cth), we assess suspected data breaches and, where an eligible data breach is likely to result in serious harm to individuals, we will notify the affected individuals and the Office of the Australian Information Commissioner as soon as practicable, including a description of the breach and the steps we recommend you take.
Complaints, enquiries and contact
If you have a question, concern or complaint about how we handle personal information, please contact our privacy officer:
- Email: ceo@phajongholdings.site
- Post: Privacy Officer, Phajong Holdings and Investments Pty Ltd, Melbourne VIC, Australia
We will acknowledge your complaint promptly and aim to resolve it within 30 days.
If you are not satisfied with our response, you may raise the matter with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
Changes to this policy
We may update this policy from time to time to reflect changes in our practices, technology or legal obligations. The current version is always published on this page, together with the date of the latest revision. Material changes will be highlighted for a reasonable period after they take effect.