1. Personal Information

1.1 Personal Information means all information of whatever kind relating to the Client personal assets (including any profit projections, research, diagrams, plans or other documents whatsoever belonging to the Client), which has an effect of making someone identifiable as an individual and is disclosed by the Client to SCS prior to, at or after the execution of this Deed by SCS and includes:

1. Your name, address, telephone number, date of birth and other information required for security purposes;
2. We may also collect information about your use of our products and services, and any preferences you tell us about.

1.2 However, the personal information we collect, does not include sensitive information such as your political or religious beliefs, ethnic backgrounds or sexual preference.

2. Purpose for Collection

2.1 Our purpose for the collection of personal information includes, but is not limited to:

1. establishing you as a client and serve your needs under this agreement;
2. meeting legal and regulatory requirements;
3. achieving any other purpose to which you have given consent;
4. assisting our internal administration and operations including, accounting, risk management, record keeping, archiving, systems development and testing;

3. How we Obtain the Information

3.1 Personal information is generally collected directly from you, when you sign up to become a SCS client.
3.2 We may collect this information over the phone, in person, over the internet, or through emails from you directly or emails through associates.

4. Confidentiality

In consideration of the Client providing SCS with access to certain Personal Information, SCS covenants to the Client that, subject to Clause 5:

1. SCS will treat the Personal Information as subject to a duty of confidence and will only use the Personal Information for the purpose of the acting in the clients best interests in relation to their portfolio and personal administration;
2. except as is permitted specifically under this Clause, they will not in any other way use the Personal Information without SCS prior written consent (which shall not be unreasonably withheld);
3. SCS will only disclose the Personal Information on a need to know basis to the officers, employees and professional advisers;
4. SCS will not disclose the Personal Information to any person not considered an approved third party, without the prior written consent of the Client;
5. SCS will keep a list of all persons to whom any Personal Information is disclosed and will provide a copy of the list to the Client, if requested to do so by the Client.

5. Oblications Not to Apply

The obligations of SCS under this policy shall not apply to any of the Personal Information which:

1. SCS (or any of its employees or professional advisers) is (or are) required by statute or law (including the Listing Rules of the Australian Stock Exchange Limited) to disclose, reproduce, use or disseminate, subject to reasonable written prior notice being given to the Company/ Client;
2. is in or enters the public domain, otherwise than as a result of a breach by SCS of its duty hereunder or disclosure by any person receiving the Personal Information from SCS.

6. Indemnification

Your Order hereby indemnifies and shall keep indemnified the Client against any loss, damage, cost (including legal costs on a solicitor, client or full indemnity basis whichever is the higher) or expense suffered or incurred by the Client directly or SCS or their directors, officers, agents, employees of the Recipient or professional advisers of any of the terms of this Deed.

7. Failure to Enforce Not to Affect Validity

The failure of the Client at any time to enforce any of the provisions of this Deed or any rights in respect hereto or to exercise any election herein provided shall not be a waiver of those provisions, rights or elections or affect the validity of this Deed.