Purpose of policy
- In this policy we explain how and why we collect your personal information, how we use it, and what controls you have over our use of it. We are committed to complying with our obligations under the Privacy Act 1988 (Cth) (Act).
Collection of information
- We will not collect sensitive information about you, unless it is required by law and you have consented to the collection of this information.
- We will collect personal information from you when you apply to our funds or managed investment schemes. This may include: your name, contact details, date of birth, citizenship, tax file number (TFN), country of residence, employment details, financial information and banking details.
- We will ensure that in relation to any personal information we hold that we take such steps as are reasonable in the circumstances to protect the information from misuse, interference, loss unauthorised access, modification or disclosure.
- Given the nature of our funds and managed investment schemes, other than providing general publicly available information (such as via our website), it is not practical for us to deal with individuals who wish to remain anonymous or would prefer to identify themselves only by way of pseudonym.
Use of information
- We retain the right to use or disclose personal information about you that is required for the purposes it was disclosed to us. This includes administering our funds and managed investment schemes and communicating with investors and clients.
- You consent to us collecting, holding, using and disclosing your personal information for the primary purpose it was provided, a related purpose or as required or permitted by law. This includes:
- establishing, maintaining and administering your investment in our funds or managed investment schemes;
- verifying, monitoring and reporting as required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
- collecting taxation information such as your tax file number, Australian business number and country of residence as required for:
- reporting to the Australian Taxation Office and other relevant regulatory bodies; and
- withholding tax correctly from payments;
- communicating with investors regarding the status of their investments in our funds and management investments schemes;
- responding to your enquiries and information requests;
- processing authorised payments; and
- any other uses identified at the time of collecting your personal information.
- We may disclose your personal information to:
- our associated entities, including commercial and joint venture partners;
- professional advisors and contracted service providers engaged by us to assist in providing our services (e.g. lawyers, accountants, consultants, investment providers and insurers);
- your financial advisor or any other person that you have consented to for the purpose of managing your investment;
- your financial advisor or any other person that you have consented to for the purpose of managing your investment in our funds or managed investment schemes; and
- persons to which we are obliged by law to disclose personal information to (e.g. the Australian Taxation Office, the Australian Securities and Investment Commission, the Australian Securities Exchange or other government entities).
- It is unlikely that we will need to disclose your information to an overseas recipient.
- If we are ever required to do so, we will either obtain your informed consent or ensure that the overseas recipients complies with the Australian Privacy Principles (contained in the Act).
Security and storage
- We place great importance on maintaining the security of your personal information. We have security measures in place to protect against the loss, misuse and alteration of personal information under our control.
- If we hold information which we no longer need (for any purpose for which the information may be used or disclosed) or are no longer required to keep, it will take such steps as are reasonable in the circumstance to destroy the information or to ensure that the information is de-identified.
- Information stored within our computer systems can only be accessed by those entrusted with authority and computer network password sanctions.
Access to and correction of personal information
- We are committed to maintaining accurate, timely, relevant and appropriate information about our clients.
- We will provide access to your personal information where a request is made in accordance with the Australian Privacy Principles (contained in the Act). There are no charges for requesting access to your personal information.
- To maintain the confidentiality of all customers, details of your personal information will only be passed on to you if we are satisfied that the information relates to you. If we refuse to provide access or correct personal information relating to you, we will provide reasons for this refusal.
- Inaccurate information will be corrected if you inform us that the information is inaccurate, out of date, incomplete, irrelevant or misleading. This will be done free of charge within a reasonable period after the request has been made
- You can contact our privacy officer regarding access to or correction of your information by any of the following methods.
Phone: (07) 3036 1420
- We will investigate your complaint and attempt to resolve any breach that might have occurred in relation to the collection, use or destruction of personal information held by us about you in accordance with the Act. If you are not satisfied with the outcome of this procedure then you may contact the Office of the Australian Information Commissioner.
- Should you wish to read more information on the Act we recommend that you visit the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.