Privacy Policy
What is privacy?
The word ‘privacy’ means different things to different people. The type of privacy covered by Australia’s Privacy Act and its privacy regulator, the Office of the Australian Information Commissioner (OAIC), is the protection of people’s personal information.
Our policy is directed towards the protection of people’s personal information. Personal information is information that identifies you or could identify a person. The protection of your personal information privacy is different to other related concepts such as confidentiality, secrecy or freedom of information. If you are in doubt, contact us or the OAIC.
Generally
The Australian Privacy Principles (APPs) are the baseline privacy standards which many private sector organisations need to comply with in relation to personal information they hold. There are 13 APP that regulate how private sector organisations manage personal information. They cover the collection, use and disclosure, and secure management of personal information. They also allow individuals to access that information and have it corrected if it is wrong. A copy of the Australian Privacy Principles is available at https://www.oaic.gov.au/privacy-law/privacy-act/australian-privacy-principles.
There is also a summary of the APPs below.
Why we collect
Broadly, the primary purpose we collect, hold, use and disclose personal information for purposes related to the direct and indirect promotion of the Fund and assisting in its operation, but also for related and/or secondary purposes, for example to:
- make the use of our web site easier
- contact investors regarding services from us or our affiliates – investors can opt out of these communications
- comply with legal obligations and
- conduct research.
We also use personal information for other reasons such as:
- monitoring, evaluating and improving products and services
- statistical, actuarial, prudential or research and
- to provide you information about other services and products.
If you do not provide us with contact details and other information we ask for, we (or others) may not be able to provide services to you.
How we collect
There are several ways we collect or obtain personal and other information, but we aim to ensure they are lawful and fair:
- when you become a client or shareholder,
- when you otherwise tell us, for example, when you contact us to update or change your details or volunteer your details
- through our website – like many websites, ours collects some limited information from users.
People who assist you such as your financial adviser or the trustee of a fund or custodian of a platform you use to invest may pass it onto us.
What we collect
Personal information collected can include the following:
- name, gender and date of birth
- contact details
- bank account details
- TFNs and ABNs
- employment information, in relation to investments made via a superannuation fund,
- details of your investors and beneficiaries
- details of the source and use of money you invest
- use details for our website
- information contemplated by laws and regulator, settlement system or exchange policies and requests and
- any other information that we consider necessary or desirable
Disclosure of personal information
We will seek to ensure that your personal information is not used or disclosed for any purpose other than:
- the primary purpose for which it was collected (or a purpose that is related to the primary purpose for which it was collected or a related secondary purpose),
- where you have consented to the use or disclosure, and
- in other circumstances where the Australian Privacy Principles authorise the use or disclosure such as when it is required by or authorised under law.
We will not disclose personal information we hold about you unless:
- this policy allows,
- you otherwise agree,
- we consider someone needs the information, typically because they are a regulator, settlement system or exchange or your adviser or to assist us – for example the administrator of one of our investment products you have invested in, or
- laws or regulator, settlement system or exchange policy requires, or a regulator, settlement system or exchange requests and
- to administer your investment.
Those we disclose personal information to include:
- our clients and shareholders and those that assist them (for example the Fund administrator)
- our affiliates and those that assist them,
- regulators, settlement system or exchanges (such as the ATO, AUSTRAC, the ASIC, the OAIC, APRA and ASX),
- your financial or other adviser,
- those we have no reason to doubt are acting on your behalf,
- companies with our group and associated with us, and
- those who help us provide products and services to you (for example, distributors, promotions companies, insurance brokers, insurance companies, custodians, fund administrators, mailing houses, lawyers and auditors)
In agreeing for us to provide services to you, you consent to the collection by us of information from someone other than you whom we have no reason to doubt properly represents you, for example, someone investing jointly with you, your relative, your trustee or administrator, your financial, legal or other adviser, if a trustee, your beneficiary, your partners, your investors, someone authorised to operate your account or your broker.
What about security?
We are committed to ensuring that personal information is kept secure. We take reasonable steps to ensure that the personal information that we hold is protected from misuse and loss and from unauthorised access, modification and disclosure. We have a number of physical access and technology policies and procedures in place designed to provide a robust security environment. No personal data is stored on our website.
The internet is not a secure environment and we cannot guarantee the security of information we store or exchange electronically. This is the nature of the Internet.
Although we take steps we consider reasonable to protect your information, we cannot guarantee its security nor that anything we send to you is virus free.
It is possible however that your personal information will be moved by those who help us provide products and services to you to a place where Australian laws do not apply, and different standards may apply there.
Records may be stored in the cloud, in Australia or overseas (as is the nature of storage such as this), by us as well as those who help us provide products and services to you. We will tell you what cloud providers are used if you ask, and direct you to their information policies on personal information.
It is not practicable to tell you the countries where that information is likely to be located.
We may use “cookies” to obtain information with regards to web site activity (such as the type of browser used, the number of pages viewed, time of the site and navigation patterns), and to help you use this site when you visit again. This information on its own does not identify an individual but it does provide us with statistics that can help us with design of the web site. You can configure your browser to accept or reject cookies. If you reject cookies you may not be able to use some or all of our website.
We may also arrange for advertising through our site. If you use an ad blocker, we may restrict your use of the site.
Access to personal information
In most circumstances, you have the right to access any personal information we collect and hold about you, and to have it corrected if it is wrong.
This is subject to exceptions allowed by law such as where giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety or where providing you with access would have an unreasonable impact upon the privacy of others.
If we deny your request or access we will provide you with the reasons for this decision.
To request access please contact us and we will respond within a reasonable period after the request is made.
Correcting personal information
We endeavour to take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, up to date, complete, relevant and not misleading.
If you believe that any of the personal information that we hold about you is not accurate, complete, up-to-date or is misleading please contact us.
If we agree that the personal information requires correcting we will take reasonable steps to do so.
If we do not correct your personal information we will provide you with the reasons for not doing so. If you request that we associate with the information a statement claiming that the information is not accurate, complete
and up-to-date we will take reasonable steps to comply with this request.
What else?
We may take and may act (or not act as relevant) on any advice, information and documents which we have no reason to doubt as to authenticity, accuracy or genuineness.
We may make changes to information handling and privacy policies and practices and this Privacy Policy Statement. We will publish important changes on our web site and if necessary update this Privacy Policy.
Questions and complaints
You can obtain further information about the way in which we manage personal information that we hold, or you can raise any privacy issues with us (including any concerns you may have about breaches of the Australian Privacy Principles), by emailing us.