Privacy Policy

Zodia Custody has an Australian operation which is governed by the Privacy Act, including the Australian Privacy Principles (APPs). The APPs regulate Zodia Australia’s handling of ‘personal information’, which means information or an opinion that identifies an individual or allows their identity to be readily worked out from the information. It includes information such as an individual’s name, address, financial information, marital status or billing details.

You consent to our use and collection of personal information

For institutional clients, the types of personal information we may collect includes current and historical information about individuals names, contact details, identification, organisational affiliations, positions held, forms submitted, and enquiry details etc. This extends to the directors, key management, beneficial owners and authorised signatories of the corporate entities we deal with.

Zodia Australia collects personal information to meet legal and regulatory obligations with respect Anti-Money Laundering and Counter-Terrorism Financing (AMLCTF) and Sanctions legislation, as well as in the prevention, detection, investigation and prosecution of crime in any jurisdiction (including without limitation, money laundering, terrorism, fraud, government sanctions or embargoes, and other financial crime. As an Australian operation of a Group that is ultimately headquartered in the United Kingdom this includes, but is not limited to data collection requirements as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended.)

The collection of your personal information can occur during our customer due diligence process, in response to a request for additional information or through the completion of a client questionnaire.

In many cases, we collect the personal information from you, including through records of your interactions with us (including email, telephone and online). We may also collect it from third parties including your organisation and representatives, public sources, our related companies, information service providers and the parties with whom we exchange information as described here. Whereby personal information is being collected by Zodia, the institution must take reasonable steps to ensure the individuals whose personal information it is, has been notified of the matters documented in this privacy notice.

If you do not provide us with the requested information we may not be able to process or assess your application to provide you with Zodia products or services.

Our use of your personal information

The primary reason we collect, use and disclose your personal information is to assess your application, including the verification of your identity (anAMLCTF obligation) and then administer and maintain the Zodiaservice. For example Zodia maintains records of the product or service each customer holds to enable us to respond to any queries a customer may have in that regards. This may involve different Zodia companies within the Zodia group or broader Standard Chartered Bank Group affiliates, providing management, operational and administration services. We may also handle your personal information to improve our products and services, verify your identity and personal information, manage our relationship with you, conduct product and market research and protect our lawful interests and manage any sale or proposed sale of all or part of Zodia’s business.

A range of security measures including information access restrictions and internal Data Privacy and information sharing policies are in place and are designed to prevent the misuse, interference, loss, unauthorised access, modification or disclosure of your personal information. We hold personal information in physical and electronic forms, both at our own premises and with the assistance of service providers.

We may provide you with further information about Zodia’s products and services in Australia and through our network offices across the world with our consent or as otherwise permitted by law. You can always opt out of these sorts of communications by emailing or calling us on the number listed below.

Disclosure of your personal information

We may exchange your personal information with certain third parties, including other companies in the Zodia Custody and wider Standard Chartered Bank Group, for example to assist Zodia Australia in managing, administering and providing financial services. Some of these third parties will be based outside of Australia. The types of organisations with which we may exchange your personal information includes:
  • Organisations undertaking reviews of the accuracy and completeness of our information;
  • third party service providers, subcontractors, agents and other organisations who provide services to us in connection with the operation of our business, or to you on our behalf such as IT and cloud hosting providers, HR and administrative services, financial and accounting, recruitment agencies, onboarding/KYC /ID verification/Travel Rule providers;
  • professional advisers including lawyers, bankers, auditors, accountants and insurers;
  • in relation to job applicants, educational institutions, previous employers, credit reference agencies and recruiters;
  • anyone authorised by you, as specified by you or in any contract with you;
  • third parties where we choose to sell, transfer or merge parts of our business or our assets;
  • our customers in connection with the products and services we provide to them;
  • regulators who regulate how we operate, including the Financial Conduct Authority and the Information Commissioner’s Office.
Zodia does conduct some administrative and operational processes (including those for the purposes of compliance with AML and Sanctions requirements, such as KYC onboarding, screening, transaction monitoring etc) outside of Australia and these are in-sourced to another company in the Zodia Group. We may disclose your personal information to these organisations and other companies within Zodia and the broader Standard Chartered Group to enable them to undertake specified management, administration and operational services.

The third parties to whom we disclose personal information are generally located but not limited to Australia, Singapore, Hong Kong, and the United Kingdom.

Retaining Your Information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory and tax, accounting or other requirements.

How to access and update your personal information

You may request to access or update personal information that we hold about you by contacting Zodia Australia’s Privacy Officer.

We may seek reimbursement for providing access to this information to recover any reasonable expense incurred in retrieving and collating the requested information. We may request that you specify the information you wish to access, to help us quickly identify and retrieve the information for you.

Zodia Australia’s Privacy Officer will inform you how long it will take to provide or update the requested information. This would usually be in less than 30 days.

We may exercise our right to deny access to or correction of particular information in certain situations where permitted by law. If we deny your request we will provide in writing the reason why it was denied.

How to contact us

If you have any questions about privacy at Zodia Australia, please contact:

5th Floor, Holland House,
1-4 Bury Street, London, EC3A 5AW

Email: [email protected]

Privacy complaint

Zodia Australia is committed to resolving your privacy complaint as quickly as possible and has procedures in place to help resolve any problems or complaints efficiently. If you have a concern or complaint about privacy at Zodia Australia, please contact the Privacy Officer.

If you are not satisfied with the resolution of your complaint by Zodia Australia, you may contact the Office of the Australian Information Commissioner at:

Email: [email protected]
Tel: 1300 363 992
Post: GPO Box 5288 Sydney NSW 2001

We are entitled to charge a small administrative fee to meet our costs in providing you with your information you have requested.

We update our website privacy statement from time to time and ask that you regularly check this website to make sure you are familiar with the most recent version.

The website privacy statement was last updated on 27/10/2023