Privacy Policy

We are committed to protecting your privacy and the security of your personal information.

We are required under the Privacy Act 1988 (Cth) (Privacy Act) to have a clearly expressed and up-to-date privacy policy with information about how we collect, use and manage your personal information, including personal information collected via our website. This policy describes how we will comply with our obligations under the Privacy Act and manage the personal information we collect.

If you are a legal entity or partnership, by forming a business relationship with us, you confirm to us that you have provided your employees, directors, officers or representatives with the information set out in this policy and that they have agreed to us using, in accordance with this policy, any personal information about them that you provide to us in connection of our business. By continuing your business relationship with us, you authorise us to use and transfer the personal information about you, or if you are a legal entity or partnership, your employees, directors, officers or representatives in accordance with this policy, as amended from time to time.

You should note that:

  • our website may contain links and references to other websites (which are for convenience only and may not be current or maintained);
  • we may use social networking services (for example, Twitter, Facebook, YouTube or Linked In) to communicate with current and potential investors; and
  • we may use third party service providers to manage contact lists, manage event registrations or collect feedback about our services.


Our privacy policy does not apply to these third parties.  You should review the relevant third party’s privacy policy (which could differ substantially from our privacy policy) and assess whether it is acceptable to you before you provide them with your personal information.


1 What does “personal information” mean?


“Personal information” is any information that can identify you or that can reasonably enable your identity to be determined. This information could include your name, postal or email address, date of birth or financial details.

Personal information includes “sensitive information”. Sensitive information is any information, or an opinion concerning about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices or criminal record.  It also includes health or genetic information, biometric information and biometric templates.


2 What personal information do we collect?


We may collect personal information about you from you or a third party through a number of different methods, including through online forms, email correspondence, written correspondence and telephone conversations.

The type of personal information we collect and hold about you will depend on the dealings you have with us. When you deal with us (including for the purposes described in section 3 of this policy) the types of personal information you may be required to provide to us include:

  • your contact details (for example, name, address, telephone number and email address), date of birth, gender and occupation;
  • financial information;
  • your Tax File Number;
  • your Australian Business Number (if applicable);
  • your bank account or other financial institution details; and
  • identification documents (for example, drivers licence).


In certain situations, the personal information we collect may (where appropriate and where it is permitted by law) include sensitive information (for example, to comply with anti-money laundering laws we may collect information about an individual’s political connections and/or whether they have a criminal record).

From time to time we may obtain personal information about you from third parties (for example, identity verification service providers, publicly or commercially available sources or third parties you have authorised us to contact) for the purpose of complying with legislative obligations, such as anti-money laundering laws.

When you use our website, we may also indirectly collect your internet protocol (IP) address, device identifiers, browser type, operating system, internet service provider, location, mobile network information, pages accessed, time stamps and your online transaction history.


3 For what purposes will we use your personal information?


We collect, use and disclose your personal information in order to provide investment management services in respect of managed investment schemes (funds) for which we have been appointed investment manager and where we may provide financial product advice to you, including for the following purposes:

  • Your identification details are used to process your application, verify your identity and contact information, set up an account in your name, provide you with secure access to our service provider’s website portal, process transactions and send you confirmations, manage your investment, ensure that you receive your distributions, provide you with information about your investment from time to time, improve the services we provide to you and to ensure that we comply with our legal and regulatory obligations.
  • During the time you are an investor in our funds we will hold investment-related information about you including the amount you have invested.
  • Your Tax File Number and Australian Business Number (where relevant) will be collected in order for us to ensure that your investment is taxed correctly.
  • Your identification details are used to provide you with information about any important changes relating to your investment in our fund, and related services, as well as any changes to our business generally.
  • We may also use your personal information for any purpose:
    • for which your personal information was originally collected or you have consented;
    • for enforcement related activities conducted by, or on behalf of, an enforcement body; or
    • which is authorised or required by a court/tribunal order or an Australian law.


We may collect, use and disclose your personal information to provide you with information about our products and services and products offered by other parties that we believe may be of interest to you (including by way of direct mail, telephone, email, SMS and MMS, secure portals, and online advertising and marketing) or to request your feedback for research purposes. You always have the right to opt out of receiving such information. You may exercise that right by contacting us as set out below in section 13.

If you cease your relationship with us, we will only retain your personal information on file to the extent necessary to meet our regulatory obligations and we will only contact you with your consent.


4 Do you have to provide your personal information to us?


If lawful and practicable, we offer you the opportunity to deal with us anonymously or by using a pseudonym. For example, we can provide general information to you about our products or services, or general guidance on how to fill out our forms without collecting any personal information.

However, if we are unable to collect and/or verify some or all of your personal information, we may not be able to enter into a business relationship with you or provide certain services to you.  In order for us to provide our services to you it is normally impracticable for us to deal with you anonymously or by using a pseudonym. For example if you do not provide your personal information to us, we will be unable to properly administer your investment, notify you about distributions or the performance of your investment, or adequately provide our services.


5 How do we collect personal information?


We will generally collect your personal information as much as possible directly from you. For example, we collect information about you through online forms, via discussions and meetings and other forms that you may complete after becoming an investor in our funds.

We may on occasion collect your personal information from publicly available sources of information and from third parties, including for example, from:

  • your financial adviser or another person who acts as your agent;
  • third party administrators or Platform providers where you may invest;
  • the trustee/responsible entity of the funds;
  • Australia Post and/or the Australian Taxation Office (if we cannot contact you);
  • direct marketing organisations and data providers.


We will only collect “sensitive information” if you have consented to the collection of the information and the information is reasonably necessary for one or more of our functions or activities or if the collection of sensitive information is authorised or required by a court/tribunal order or an Australian law, including the following Australian laws:

  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
  • Corporations Act 2001 (Cth);
  • Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth);
  • Privacy Act.

 

6 Who do we disclose your personal information to?


There are a range of people and organisations we may disclose your personal information to and collect your personal information from. The particular party we may disclose your personal information to will depend on the dealings you have with us. Some examples of persons to whom we may disclose your personal information include:

  • Mail and electronic mail service providers for the communication of investor statements and other information.
  • Legal advisers and other experts.
  • Regulatory authorities and legal bodies as required by law (e.g. Australian Taxation Office, the Australian Transaction Reports and Analysis Centre, Australian Prudential Regulation Authority, the Australian Securities and Investments Commission or a Court or tribunal).
  • Auditors (in order to assist them in conducting their independent audit and review activities of our financial statements and operations).
  • Third parties (if you give us permission to do so e.g. your financial adviser).
  • Other third party service providers so that they can provide contracted services to us such as information technology support, hosting services, telephone services, mailing or sending other documentation, identity verification, fraud prevention, marketing or market research.


We may also share your personal information with a third party where we have obtained your consent.

We may require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected.

If you do not consent to us collecting, using and/or disclosing your personal information for such other purposes, this may affect our ability to deliver and improve our products and services, or to engage or do business with you.


7 Do we disclose your personal information overseas?


We may disclose personal information about an individual to overseas organisations that help us provide our services, in certain circumstances, such as when storing information with a “cloud service provider” which stores data outside of Australia. We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:

  • you have asked us to or we have your consent to do so;
  • we have outsourced a business activity or function to an overseas service provider;
  • we reasonably believe that the overseas recipient is subject to a law or binding scheme that protects the information in a way that is substantially similar to the way the information is protected under the Privacy Act and the Australian Privacy Principles, and there are mechanisms you can access to take action to enforce that protection; or
  • the disclosure is required or authorised by or under an Australian law or a court/tribunal order.


Please note that the laws on processing personal information in other countries may be less stringent than in Australia. When we disclose your personal information overseas, we will take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia, including the Australian Privacy Principles.


8 How do we protect your personal information?


We have security policies and systems in place to protect your personal information, which are reviewed, monitored and updated on a regular basis.   We take reasonable steps to protect the personal information we hold from loss, interference, destruction, unauthorised access, modification or disclosure using both physical and electronic security measures.  We implement multiple layers of security controls throughout our systems so that in the event that one control fails, or a vulnerability is exploited, there are other measures still in place to protect your personal information.  Relevant measures include firewalls, data encryption, limiting physical access to data centres and controls over access to information.

The people within our organisation who handle your personal information are only those who have the need to access it and they have the training and skills to protect your personal information from unauthorised access or misuse.

If you provide us with your personal information over the internet you accept that such information will be transmitted at your own risk as the security of such information cannot be guaranteed.


9 How long do we keep your personal information?


We will only retain personal information for as long as we consider, in our reasonable opinion, to be necessary to comply with applicable law or for the relevant purpose (as set out in this policy).

When we no longer need your personal information, we will seek to delete, destroy or de-identify it in accordance with our record retention policy and any applicable laws.


10 Can you access the personal information we hold about you?


You may request access to any of the personal information we hold about you by contacting us as set out below in section 12. A summary of personal information such as your name and contact details and investments you have with us is available to you upon request. We will provide you with access to your personal information in accordance with the Privacy Act. Under the Privacy Act we can deny access to some or all of your personal information in specified circumstances, and will provide reasons for any refusal in writing.  If you are not satisfied with any refusal to grant you access to your personal information, you may make a complaint (see section 13).

We may seek to verify your identity before we process any access requests to make sure that the personal information we hold about you is sufficiently protected.

We will give you access to your personal information upon request unless there is a law that allows or requires us not to.


11 Can you correct any personal information held by us that is incorrect?


We endeavour to ensure that the personal information we hold about you is accurate, up-to-date, complete, relevant and not misleading. Please let us know if you believe any of your personal information that we hold is incorrect by contacting us as set out below in section 13.

We may seek to verify your identity before we process any correction requests to make sure that the personal information we hold about you is sufficiently protected.

Upon request, we will take reasonable steps to correct your personal information if we consider it is incorrect, unless there is a law that allows or requires us not to.

To ensure that the information we hold about you remains accurate, complete and up-to-date, we may ask you to check and correct your personal details from time to time. We may do this as part of our regular communications with you, when you make a telephone enquiry, or through other means.


12 Cookies


Some of the pages on our website use “cookies”, which are small files that may be placed on your hard disk for record-keeping purposes. Cookies helps us remember who you are and may collect and store your server address, top level domain name (e.g. .com, .gov, .net etc), the date and time of your visit, country your service address is located in, the type of browser you used, the pages viewed and any downloads made, the previous site you visited and the site you visited next. Cookies can make your subsequent visits to our website simpler and more efficient (for example, your password may be saved so you do not need to re-enter it). We may also use the information to assist in improving the website, marketing and product development.

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. (However, by not accepting cookies, some pages on the website may not display properly or you may not be permitted to access certain information.) A server cannot find out a name or email address, or anything about you by using cookies.

We do not store or collect cookie information. Once we receive information from you, via email or any other means, the information is stored in a secure environment.


13 Who should you contact if you have any questions regarding our privacy policy?


We have appointed a Privacy Officer. If you have any queries you can contact us by the following means:

Call: +61 (2) 9271 0900
Email: [email protected]
Mail: The Privacy Officer
Level 24, 1 Farrer Place
Sydney NSW 2000


14 Can you complain about a breach of your privacy?


If you believe that we have not protected your personal information as set out in this privacy policy you may lodge a complaint with us by contacting us using any of the following methods:

Call: +61 (2) 9271 0900
Email[email protected]
Mail: The Privacy Officer
Level 24, 1 Farrer Place
Sydney NSW 2000

Please mark the envelope or the email message “Notice of Privacy Complaint”. We will contact you to let you know who is looking in to the matter and when you can expect a further response.  We will try to resolve your complaint quickly and fairly.

If you are not satisfied with the manner in which we deal with your complaint you may refer it to the Office of the Australian Information Commissioner (OAIC). You can contact the OAIC:

Online: by visiting www.oaic.gov.au
Email: [email protected]
Phone: 1300 363 992
Mail: GPO Box 5218
Sydney  NSW  2001

If you are not happy with our response to your complaint or we have not satisfactorily resolved your complaint within 30 days, you can also refer your complaint to the Australian Financial Complaints Authority (AFCA).  AFCA can be contacted on 1300 780 808 or you can write to them at:

The Manager
Australian Financial Complaints Authority Limited
GPO Box 3
Melbourne  VIC  3001

For more information on our Complaints Resolution Process, please Complaints


15 Changes to this privacy policy


This privacy policy may change from time to time. We will display our current privacy policy on our website and we may notify you when significant changes are made.  Before providing us with personal information, please check this policy for any changes either by accessing our website or by contacting us as set out above in section 13 to request an up to date copy. This privacy policy was last updated on 20 September 2022.

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