Constantinople Holding Company Limited ABN 71 655 000 472, its subsidiaries and affiliates in Australia (collectively referred to as Constantinople) are committed to managing personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.
This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.
In this Privacy Policy, "we" and "us" refers to Constantinople and "you" refers to any individual about whom we collect personal information.
Constantinople is a global fintech company offering wholesale banking solutions.
Please contact us for a full list of the companies which comprise Constantinople and which are subject to this Privacy Policy.
When you enquire about our services or when you become a client of Constantinople, a record is made which may include your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.
We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions which require you to hold a licence or certificate).
Constantinople may collect personal information about other individuals who are not clients of Constantinople. This includes customers and members of the public who participate in events we are involved with; individual service providers and contractors to Constantinople; and other individuals who interact with Constantinople on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Constantinople. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
In limited circumstances, Constantinople may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by Constantinople we may collect health information about you in an emergency or otherwise with your consent. You can always decline to give Constantinople any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.
The way in which we handle the personal information of visitors to our websites is discussed below.
Constantinople collects personal information reasonably necessary to carry out our business, to assess and manage our clients' needs, and provide services. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing client relationships.
The purposes for which Constantinople usually collects and uses personal information depends on the nature of your interaction with us, but may include:
Constantinople generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
You may visit our websites www.cxnpl.com without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to Constantinople will be managed in accordance with this Privacy Policy.
Constantinople's websites use cookies. A “cookie” is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.
You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website. Constantinople's websites may contain links to third-party websites. Constantinople is not responsible for the content or privacy practices of websites that are linked to our website.
Constantinople will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for Constantinople to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.
Constantinople stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. Constantinople maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.
We take steps to destroy or de-identify information that we no longer require.
Constantinople may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below. If you opt-out of receiving marketing material from us, Constantinople may still contact you in relation to its ongoing relationship with you.
The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services.
If you are a customer or participant in an event, we may disclose your personal information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.
Constantinople may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research. Personal information may also be shared between related and affiliated companies of Constantinople, located in Australia and overseas. Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
Constantinople will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
Unless we have your consent, or an exception under the APPs applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.
Entities which are related entities of Constantinople, or are otherwise affiliated with Constantinople, have operations in Singapore and India. In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which Constantinople and its related entities and affiliates operate.
You are entitled to access your personal information held by Constantinople on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.
You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
You may contact Constantinople at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
You may make a complaint about privacy to the Privacy Officer at the contact details set out below.
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week. If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved. In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know. If you are not satisfied with our response to your complaint, or you consider that Constantinople may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.
Constantinople may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.
The contact details for Constantinople are:
Constantinople Privacy Officer
Address: Level 4, 725-731 George Street, HAYMARKET NSW 2000
Email address: privacy@cxnpl.com
This Privacy Policy was last updated in 2025