Privacy
Policy
Fortune Prime Limited
Trading as Fortune Prime Global (FPG)
Company Number 700507
Issued 13
th
November 2021
Privacy
Policy
Authorised
Dealer in Securities
Table of Contents
1. PRIVACY POLICY
2. PERSONAL INFORMATION
3. OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION
4. COLLECTION OF PERSONAL INFORMATION
5. COOKIES
6. EMAIL ADDRESS
7. UNSOLICITED PERSONAL INFORMATION
8. NOTIFICATION OF THE COLLECTION OF PERSONAL INFORMATION
9. USE AND DISCLOSURE OF PERSONAL INFORMATION
10. DIRECT MARKETING
11. CROSS BORDER DISCLOSURE/SENSITIVE INFORMATION/USE OF GOVERNMENT
IDENTIFIERS/ANONYMITY & PSEUDONYMITY
12. QUALITY OF PERSONAL INFORMATION
13. ACCESS TO PERSONAL INFORMATION
14. CORRECTION OF PERSONAL INFORMATION
15. SECURITY OF PERSONAL INFORMATION
16. NOTIFIABLE DATA BREACHES SCHEME
17. PRIVACY COMPLAINTS
18. YOUR CONSENT AND CHANGES TO THE PRIVACY POLICY
19.EU GENERAL DATA PROTECTION REGULATION
20.CONTACT
1. Privacy Policy
This privacy statement is made on behalf of Fortune Prime Limited (VFSC 700507). All
references to “Fortune Prime Global”, “FPG”. “we”, “us” or “our” in this policy are references
to Fortune Prime Limited. FPG is committed to protecting your privacy and to compliance with
the Vanuatu Privacy Principles contained in the Privacy Act 1988 (Cth). If you have any
questions relating to this privacy statement or your privacy rights, please contact us. This
Privacy Statement sets out the policy of FPG for handling and protecting your personal
information. We are committed to ensuring the privacy of your information and recognize that
you, as a customer, are concerned about your privacy and about the confidentiality and security
of information that FPG may hold about you. This Policy is designed to inform customers of –
The FPG Privacy Policy.
• What information we collect and the purposes for which we collect it;
• Use and disclosure of information collected;
• Security of your personal information;
• Gaining access to information we hold about you;
• What to do if you believe the information, we hold about you is inaccurate;
• Complaints in relation to privacy; and
• How to contact us.
The Client acknowledges that FPG reserves the right to amend or update this Privacy Policy
any time without prior notice to the Client. The amendments to the Privacy Policy shall become
effective immediately and shall be legally binding on the Client upon publishing of the Privacy
Policy on FPG’s website. The Client undertakes to regularly review this Private Policy on FPG’s
website.
2. Personal Information
Personal information is information or an opinion about an individual whose identity is
apparent, or can reasonably be ascertained, from the information or opinion. FPG will also
collect any personal information necessary for the purposes of complying with the Anti-Money
Laundering and Counter- Terrorism Financing Act 2006.
3. Open and Transparent Management of
Personal Information
FPG seeks to ensure that personal information we hold about an individual is managed in an
open and transparent manner. We have implemented procedures to ensure compliance with the
Vanuatu Privacy Principles and any applicable codes, and to deal with any complaints relating
to our compliance therewith. FPG has a clear and up-to-date privacy policy outlining our
management of personal information, including details regarding the kind of personal
information we collect and hold; how and why we collect and hold this information, and how
an individual may access and seek correction of the information we hold about them. We further
provide details regarding our complaints handling process, our policy on disclosure of
information to overseas recipients (and if so, which countries).
4. Collection of Personal Information
This policy details how FPG adheres to the Vanuatu Privacy Principles regarding the collection
of solicited personal information. FPG predominantly collects personal information directly
from individuals, although information may sometimes be provided by a client’s professional
adviser on their behalf and with their consent. FPG only collects personal information which is
reasonably necessary for the provision of our services, and only by lawful and fair means.
Information is generally sought through our account application forms, in which the purpose is
articulated. Accordingly, we will always ensure you are apprised of our purpose in collecting
information, and your right to gain access to such information. If you do not provide the
information requested, we may be unable to provide you with our services. Please note that
generally we will only use the personal information (e.g. national ID number. residential
address, e-mail address, telephone numbers, date of birth, bank account details, details related
to the provision of verification and identification documentation) we collect for the main
purposes disclosed at the time of collection such as to provide financial services. Where
possible we will collect the information directly from you via our application form. We may
also collect information about you from our web site, but this information will only identify
who you are if you provide us with your details (e.g. if you e-mail your contact details to us).
When you visit our web site our web server collects the following types of information for
statistical purposes:
• your internet service provider’s address;
• the number of users who visit the web site;
• the date and time of each visit;
• the pages accessed and the documents downloaded;
• the type of browser used.
No attempt is made to identify individual users from this information.
5. Cookies
A cookie is a small text file placed on your computer hard drive by a web page server. Cookies
may be accessed later by our web server. Cookies store information about your use of our web
site. Cookies also allow us to provide you with more personalised service when using our web
site. FPG may use cookies to:
• determine whether you have previously used the FPG web site;
• identify the pages you have accessed; and
• facilitate administration of the site and for security purposes.
Most web browsers are set to accept cookies, but you may configure your browser not to accept
cookies. If you set your browser to reject cookies you may not be able to make full use of the
FPG web site.
6. Email Address
If you provide us with your e-mail address during a visit to our web site, it will only be used
for the purpose for which you provided it to us. It will not be added to a mailing list without
your consent unless the mailing list is related to the purpose for which you provided your e-
mail address to us. We may use your e-mail address, for example, to provide you with
information about a particular service or respond to a message you have sent to us. If you
subscribe to one of our services and provide your e-mail address to us so that we may
communicate with you through e-mail, we may also use your e-mail address to advise you of
upgrades and changes to those services.
7. Unsolicited personal information
Where we receive personal information about an individual which is unsolicited by us and not
required for the provision of our services, we will destroy the information (provided it is lawful
and reasonable for us to do so).
8. Notification of the collection of personal
information
When we obtain personal information about you, we ensure that you have our contact details
and that you are aware of the collection of information and our purposes for doing so. As per
above, we are unable to provide certain services if the requested information is not provided.
We do not disclose your information to third parties, unless they are related entities or services
providers, in which case they are required to conform to our procedures.
9. Use and disclosure of personal information
FPG collects and holds personal information about an individual for the purpose of providing
financial services. We collect this information with your consent as per our application form or
other documentation, for the primary purpose disclosed to you at the time of collection.
However, in some cases FPG will use or disclose personal information for secondary purposes
(any purpose other than a primary purpose). Personal information obtained to provide financial
services may be applied to secondary purposes if the secondary purpose is related to the primary
purpose of collection and the person concerned would reasonably expect the personal
information to be used or disclosed for such secondary purpose. In some cases, we may ask you
to expressly and additionally consent to any collection, use or disclosure of your personal
information. Your consent will usually be required in writing, but we may accept verbal consent
in certain circumstances. We may also disclose your personal information where it is required
or authorised by law.
We may use your personal information to:
• process your application;
• respond to any specific requests you may make of us;
• notify you of any products that may be of interest to you;
• audit and monitor the services we provide to you;
• update your personal files; and
• enable us to meet our obligations under law, for example, the Anti-Money Laundering and
Counter Terrorism Financing Act 2006 (Cth) and Vanuatu taxation laws.
We may disclose your personal information to:
• third-party service providers to enable them to provide administrative and other support
services to us; and
• where the disclosure is required by law, for example to government agencies and regulatory
bodies as part of our statutory obligations, or for law enforcement purposes. FPG may use third
party service providers to maintain some of our data systems and provide auxiliary services.
We require any party that has access to personal information to conform to our privacy
standards and be subject to comparable privacy regulation in their jurisdiction.
10. Direct Marketing
FPG will only use personal information obtained for the provision of financial services, for the
secondary purpose of direct marketing where:
• FPG collected the personal information from the individual; and
• The individual would reasonably expect FPG to use or disclose the information for the
purpose of direct marketing; and
• FPG provides a simple means through which an individual can request to not receive
marketing communications; and
• The individual has NOT requested such communications cease.
Often the law requires us to advise you of certain changes to products/ services or regulations.
You will continue to receive this information from us even if you choose not to receive direct
marketing information from us. We will not disclose your information to any outside parties for
the purpose of allowing them to directly market to you.
11. Cross border disclosure/Sensitive
information/Use of government
identifiers/Anonymity & Pseudonymity
FPG does not, for the purposes of the Privacy Act, transfer personal information overseas nor
does it collect sensitive information. Wherever lawful and practicable, individuals may deal
anonymously with FPG but given the nature of our services, it is unlikely that this will be a
viable option. FPG does not use official identifiers (e.g. tax file numbers) to identify individuals.
An individual’s name is not an identifier for the purposes of the Privacy Act and hence may be
used to identify individuals.
12. Quality of personal information
FPG takes all reasonable steps to ensure the personal information held about individuals is
accurate, up-to-date and complete. We verify personal information at the point of collection.
FPG encourage you to help us by telling us immediately if you change your contact details
(such as your phone number, street address or email address) or if any of your details need to
be corrected or updated. A person wishing to update their personal information may contact our
team on the contact details shown within this document.
13. Access to personal information
Where a person requests access to their personal information, our policy is, subject to certain
conditions (as outlined below) to permit access. FPG will correct personal information where
that information is found to be inaccurate, incomplete or out of date. We will not charge you a
fee for your access request but may charge you the reasonable cost of processing your request.
If a person wishes to access their personal information or correct it, they should contact our
team, and we will seek to provide such information within a reasonable period, and in the
manner so requested (where reasonable to do so). FPG may not always be able to give you
access to all the personal information we hold about you. If this is the case, we will provide a
written explanation of the reasons for our refusal, together with details of our complaints
process for if you wish to challenge the decision. We may not be able to give you access to
information in the following circumstances:
• Where we reasonably believe this may pose a serious threat to the life, health of safety
of any individual or to public health/safety;
• Which would unreasonably impact the privacy of another individual;
• Where such request is reasonably considered to be frivolous or vexatious;
• Which relates to existing or anticipated legal proceedings which would otherwise not
be accessible in the discovery process relating to such proceedings;
• Which would reveal our intentions and thereby prejudice our negotiations with you;
• Which would be unlawful;
• Which is prohibited by law or a court/tribunal order;
• Which relates to suspected unlawful activity or serious misconduct, where access
would likely prejudice the taking of appropriate action in relation thereto;
• Where enforcement activities conducted by or on behalf of an enforcement body may
be prejudiced; or
• Where access would reveal details regarding a commercially sensitive decision-making
process.
14. Correction of personal information
Where FPG believes information, we hold about an individual is inaccurate, out of-date,
incomplete, irrelevant or misleading, OR an individual requests us to correct information held
about them, FPG will take all reasonable steps to correct such information in a reasonable time
frame. No fees are payable for such requests. If you request us to similarly advise a relevant
third party of such correction, we will facilitate that notification unless impracticable or
unlawful for us to do so. If FPG intends to refuse to comply with your correction request, we
will notify you in writing of our reasons for such refusal, and the complaints process you may
avail if you wish to challenge that decision. You may also request that we associate the personal
information we hold with a statement regarding your view of its inaccuracy.
15. Security of personal information
We take reasonable steps and precautions to keep personal information secure from loss, misuse,
and interference, and from unauthorized access, modification or disclosure. If you use the
Internet to communicate with us, you should be aware that there are inherent risks in
transmitting information over the Internet. FPG does not have control over information while
in transit over the Internet and we cannot guarantee its security. Where information is no longer
required to be held or retained by FPG for any purpose or legal obligation, we will take all
reasonable steps to destroy or de-identify the information accordingly.
16. Notifiable Data Breaches Scheme
We will report ‘eligible data breaches’ to the affected individual(s) and the Vanuatu Information
Commissioner in relation to the (including suspected) unauthorized access or disclosure of
personal information held, which is likely to result in serious harm to the relevant individual(s),
and where we have been unable to prevent the likely risk of serious harm with remedial action.
We will formulate a data breach response plan, to limit any negative consequences of such a
breach. An effective response involves a process to contain, assess, notify and review.
17. Privacy Complaints
If you have a complaint relating to our compliance with privacy laws or our treatment of your
personal information, please contact our Compliance team by email to
compliance@fortuneprime.com. We will investigate your complaint and endeavor to resolve
the issue to your satisfaction. If you are not satisfied with the outcome of your complaint, you
have the right to lodge a complaint with the Office of the Vanuatu Financial Services
Commission by telephoning +678 22247 or visiting their website at www.vfsc.vu. Any personal
information that we no longer require is destroyed. An exception to this may be where records
are retained to comply with legal requirements.
18. Your Consent and Changes to the Privacy
Policy
Upon using this web site and our services, you consent to our use and collating of your
information as it appears within this policy. Although this is not our immediate intention,
periodically, we may utilize this customer information for any unforeseen uses that have not
been disclosed within this current privacy notice. If at any time our information practices
change in the future, we will amend our policy on this Web site. Should you have any immediate
concerns about how your information is used, you should check our Web site sporadically to
ensure you are up to date with our current policy.
19. EU General Data Protection Regulation
In accordance with the new data protection requirements in the European Union General Data
Protection Regulation (EU GDPR) which apply from 25 May 2018, we provide the following
additional measures which we have adopted in relation to all EU clients and third parties:
1. We will limit the processing, collection and retention of data to the extent legally
possible and practically viable.
2. We will not request or collect data that is not required for the purpose of providing our
services or meeting our legal obligations.
3. We will delete your information and acknowledge your right of erasure or to be
forgotten, as soon as we are legally able and subject to our other legal and regulatory
obligations regarding record - keeping.
4. You may advise us at any time that you withdraw any consent previously given to us
and require us to stop processing your data.
5. You may object to any decision based on automated processing, and you may request
a manual review.
6. You have the right to request a transfer of your personal information, which will be
provided in a machine-readable electronic format.
7. Where we intend to process/utilise your personal data beyond the disclosed legitimate
purpose for which it was collected, we will obtain a clear and explicit consent from you
(which can be withdrawn at any time).
8. We will maintain a Personal Data Breach Register and notify the relevant regulator in
a timely manner as required.
9. We ensure that organisational and technical mechanisms are utilised to protect personal
data when we are designing new systems and processes.
10. We will conduct Data Protection Impact Assessments when initiating a new
project/change/product which involves significant changes to the processing of
personal information.
11. We ensure our representatives are regularly trained regarding our obligations and their
responsibilities under applicable privacy/data protection regulations.
20. Account Deletion
If you would like to delete your account, you may send an email request to
support@fortuneprime.com with the subject line “Account Deletion Request.” Our support
team will contact you to verify your request and complete the process. Once confirmed, your
account will be permanently closed, and any personal information associated with your
account will either be deleted or anonymized in accordance with our data retention policies.
Please note that once your account is deleted, this action cannot be reversed.
2
1. Contact
If clients have any complaints or concern in relation to our privacy practice, please reach us via
the following channels:
Email: compliance@fortuneprime.com
