Privacy policy
Spencer Bullion Exchange (“SBE”, “we”, “us” or “our”) is committed to protecting the privacy and personal information of our customers.
Privacy is important to our business, particularly given the nature of the transactions we conduct and our legal and regulatory obligations.
This Privacy Policy explains how Spencer Bullion Exchange collects, holds, uses, discloses and protects personal information relating to customers, prospective customers, website visitors, people selling goods to us, recipients of our electronic communications and other members of the public.
By using our website, visiting our premises, providing personal information to us or using our products or services, you acknowledge that your personal information may be handled in accordance with this Privacy Policy.
1. Personal Information We Collect
We may collect personal information that you provide to us directly or through an authorised representative.
Depending upon your dealings with Spencer Bullion Exchange, this information may include:
- Your full name;
- Date of birth;
- Residential or postal address;
- Email address;
- Telephone number;
- Customer account details;
- Transaction and purchase history;
- Payment and banking information;
- Details of products purchased from or sold to us;
- Government-issued identification;
- Copies or details of driver's licences, passports or other identification documents;
- Information concerning companies, trusts, SMSFs or other entities;
- Information concerning directors, trustees, beneficial owners and authorised representatives;
- Correspondence between you and Spencer Bullion Exchange;
- Information required to investigate suspected fraud or unlawful activity; and
- Other information reasonably required to provide our products and services or comply with applicable laws.
We may collect this information through our website, by telephone, email, online forms, electronic communications or when you visit or transact with us in person.
Where you provide personal information concerning another person, you must be authorised to provide that information to us.
2. Information Collected Through Our Website
When you access our website, certain technical information may be collected automatically.
This may include:
- IP address;
- Browser type;
- Device type;
- Operating system;
- Pages visited;
- Access times;
- Referring websites;
- Website activity;
- Approximate geographic information derived from your internet connection; and
- Other technical information relating to the use of our website.
We may use this information for purposes including website operation, analytics, security, fraud prevention, troubleshooting and improving our products, services and online experience.
3. Why We Collect Personal Information
Spencer Bullion Exchange may collect, hold, use and disclose personal information for purposes including:
- Processing purchases;
- Processing items sold to us;
- Providing bullion, coins, banknotes, jewellery, collectables, accessories and other products;
- Processing bullion and precious-metal buybacks;
- Creating and administering customer accounts;
- Responding to enquiries;
- Providing customer service;
- Processing payments and refunds;
- Issuing invoices, receipts and transaction records;
- Arranging shipping and delivery;
- Managing order collection;
- Communicating with customers about orders or transactions;
- Verifying customer identities;
- Preventing and detecting fraud;
- Maintaining the security of our premises, customers and staff;
- Complying with applicable laws and regulatory requirements;
- Maintaining records required by law;
- Managing disputes or legal proceedings;
- Improving our website, products and services; and
- Conducting legitimate business administration.
4. Identification and Regulatory Compliance
Due to the nature of our business, Spencer Bullion Exchange may be required or consider it reasonably necessary to identify and verify customers and other persons conducting transactions with us.
We may collect information for purposes associated with applicable:
- Anti-money laundering and counter-terrorism financing requirements;
- AUSTRAC requirements;
- Second-hand dealer requirements;
- Taxation requirements;
- Fraud-prevention measures;
- Law-enforcement requirements; and
- Other Australian legal or regulatory obligations.
Identification information may include your:
- Full legal name;
- Date of birth;
- Residential address;
- Driver licence;
- Passport;
- Proof-of-age card;
- Other government-issued identification; or
- Information concerning companies, trusts, SMSFs, beneficial owners or authorised representatives.
We may use reputable third-party identity-verification providers to assist us in verifying this information.
Where permitted by law, information provided by you may be checked against information held by document issuers, government records, credit reporting bodies or other approved data sources for identity-verification purposes.
We may refuse, delay or restrict a transaction where we cannot satisfactorily complete required identification or compliance procedures.
5. AUSTRAC and Government Reporting
Spencer Bullion Exchange may be required to collect, retain and disclose information to AUSTRAC or other Australian government or law-enforcement authorities.
Depending upon the circumstances and applicable legislation, this may include information relating to:
- Customer identification;
- Cash transactions;
- Transaction values;
- Payment methods;
- Suspicious transactions or behaviour;
- Source or destination of funds;
- Ownership or control of entities; and
- Other information required by law.
Where we are legally required or authorised to make a report or disclosure, we may do so without obtaining further consent from the customer.
6. Purchases From Members of the Public
When Spencer Bullion Exchange purchases bullion, precious metals, jewellery, coins, banknotes, medals, collectables or other goods from a member of the public, we may collect information concerning the seller and the transaction.
This may include:
- Identification information;
- Contact details;
- Details and photographs of the goods;
- Purchase price;
- Payment details;
- Transaction date;
- Serial numbers or identifying characteristics;
- Information concerning ownership of the goods; and
- Other information required by law or our internal compliance procedures.
This information may be retained for the periods required under applicable laws, licence conditions or regulatory requirements.
7. How We Use Your Personal Information
Personal information may be used to:
- Verify your identity;
- Complete transactions;
- Communicate with you;
- Provide products and services;
- Process payments;
- Process refunds or buyback payments;
- Deliver orders;
- Maintain transaction records;
- Respond to enquiries or complaints;
- Prevent fraud and theft;
- Investigate suspicious activity;
- Protect our customers, employees and business;
- Meet regulatory requirements;
- Comply with court orders, warrants, notices or other lawful requests; and
- Establish, exercise or defend legal rights.
We will not use personal information for unrelated purposes unless permitted or required by law or you have consented to that use.
8. Disclosure of Personal Information
Spencer Bullion Exchange may disclose personal information to third parties where reasonably necessary for our business activities or where required or authorised by law.
Recipients may include:
- AUSTRAC;
- Australian Federal Police;
- Queensland Police Service and other police services;
- Courts and tribunals;
- Government departments and regulatory authorities;
- Banks and financial institutions;
- Payment processors;
- Identity-verification providers;
- Fraud-prevention providers;
- IT and website service providers;
- Ecommerce platform providers;
- Accountants, auditors and professional advisers;
- Insurers;
- Couriers and delivery providers;
- Marketing and communications providers; and
- Other service providers reasonably necessary to operate our business.
We seek to limit disclosure to information reasonably necessary for the relevant purpose.
9. Marketing Communications
Where permitted by law, Spencer Bullion Exchange may use your contact information to send you information about:
- New products;
- Bullion availability;
- Precious-metal products;
- Coins and collectables;
- Promotions;
- Events;
- Auctions;
- Business updates; and
- Other Spencer Bullion Exchange products or services.
You may unsubscribe from electronic marketing communications at any time by using the unsubscribe facility contained in the communication or by contacting us.
Unsubscribing from marketing communications will not prevent us from sending communications that are reasonably necessary to administer an existing order, transaction or customer relationship.
10. Cookies and Similar Technologies
Our website may use cookies and similar technologies.
Cookies are small files stored on your device that can help websites recognise your browser and remember certain information.
Cookies may be used to:
- Operate our website;
- Remember customer preferences;
- Maintain shopping-cart functionality;
- Understand how visitors use our website;
- Measure website performance;
- Improve customer experience;
- Detect suspicious activity;
- Support advertising and marketing activities; and
- Maintain website security.
Most browsers allow users to control or disable cookies.
Disabling certain cookies may affect the functionality of our website.
11. Online Advertising and Analytics
Spencer Bullion Exchange may use third-party analytics and advertising services to understand website usage and measure or deliver advertising.
Depending upon the technologies used, these providers may collect information including device identifiers, IP addresses, website interactions and cookie information.
Where required, these activities will be conducted in accordance with applicable privacy and electronic communications laws.
12. Security of Personal Information
Spencer Bullion Exchange takes reasonable steps to protect personal information against:
- Loss;
- Misuse;
- Unauthorised access;
- Unauthorised disclosure;
- Interference; and
- Modification.
Security measures may include physical security, access controls, passwords, encryption, secure electronic systems, CCTV and other appropriate measures.
However, no method of electronic transmission or storage can be guaranteed to be completely secure.
Customers should protect their passwords, email accounts, devices and account credentials and should contact Spencer Bullion Exchange promptly if they believe their information or account has been compromised.
13. Payment Information
Online payments may be processed through third-party payment processors.
Spencer Bullion Exchange may not directly store complete payment-card information where transactions are processed through those providers.
Payment providers may collect and process information in accordance with their own privacy policies and applicable laws.
14. CCTV and Security Recording
Spencer Bullion Exchange premises may be monitored and recorded using closed-circuit television (CCTV) and other security systems.
CCTV may record customers, visitors, staff and other persons entering or around our premises.
Recordings may be used for:
- Security;
- Crime prevention;
- Theft prevention;
- Fraud investigation;
- Staff and customer safety;
- Incident investigation;
- Insurance purposes;
- Dispute resolution; and
- Assisting law-enforcement agencies.
CCTV footage may be disclosed where required or permitted by law, including in response to lawful requests from police, courts, regulators or other government authorities.
Recordings may be retained for a period reasonably necessary for security or legal purposes.
15. Storage and Retention of Personal Information
Personal information may be stored electronically or in physical form.
Electronic information may be stored through our own systems or through reputable third-party service providers.
Physical records containing personal information are stored in areas with appropriate security controls.
We retain personal information for as long as reasonably required for the purposes for which it was collected and for any additional period required by law.
Where information is no longer reasonably required and we are not legally required to retain it, we may securely destroy or de-identify it.
16. Overseas Disclosure and Cloud Services
Some technology, ecommerce, payment, communications, marketing or cloud-service providers used by Spencer Bullion Exchange may store or process information outside Australia.
As a result, personal information may in some circumstances be disclosed to or accessible from overseas locations.
Where applicable, Spencer Bullion Exchange will handle overseas disclosures in accordance with its obligations under Australian privacy law.
The countries in which information may be processed can depend upon the service providers used by Spencer Bullion Exchange from time to time.
17. Third-Party Websites
Our website may contain links to websites operated by third parties.
Spencer Bullion Exchange is not responsible for the privacy practices, security or content of websites operated by third parties.
Customers should review the privacy policies of those websites before providing personal information to them.
18. Accessing Your Personal Information
You may request access to personal information Spencer Bullion Exchange holds about you.
We may require reasonable identification before providing access to protect your information from unauthorised disclosure.
In certain circumstances permitted by law, we may refuse or limit access.
Where access is refused, we will provide an explanation where required by law.
19. Correcting Your Personal Information
We take reasonable steps to ensure personal information held by us is accurate, complete and up to date.
If you believe information we hold about you is inaccurate, incomplete or out of date, you may contact us and request that it be corrected.
We may require information or identification sufficient to verify the requested correction.
20. Data Breaches
If Spencer Bullion Exchange becomes aware of unauthorised access to, disclosure of, or loss of personal information, we will investigate the circumstances and take reasonable steps to contain and address the incident.
Where the incident constitutes an eligible data breach under applicable Australian law, Spencer Bullion Exchange will comply with applicable notification requirements, including notifications to affected individuals and the Office of the Australian Information Commissioner where required.
21. Children
Our products and services are generally intended for adults.
We do not knowingly seek to collect unnecessary personal information from children.
Where a transaction involves a person under 18 years of age, we may require the involvement or consent of a parent or legal guardian and may decline the transaction where appropriate.
22. Changes to This Privacy Policy
Spencer Bullion Exchange may update this Privacy Policy from time to time to reflect changes in:
- Our business;
- Technology;
- Service providers;
- Legal requirements;
- Regulatory requirements; or
- Our information-handling practices.
The current version of this Privacy Policy will be published on our website.
23. Privacy Questions and Complaints
If you have a question, concern or complaint regarding how Spencer Bullion Exchange has handled your personal information, please contact us.
We will endeavour to investigate and respond within a reasonable period.
If you are dissatisfied with our response, you may have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).
24. Contact Details
Privacy enquiries, requests for access or correction, and privacy complaints can be directed to:
Spencer Bullion Exchange
180 Bourbong Street
Bundaberg Central QLD 4670
Australia
25. Governing Privacy Legislation
Where applicable, Spencer Bullion Exchange handles personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable Australian laws.
Nothing in this Privacy Policy limits any rights a person may have under applicable Australian privacy legislation.