1. Personal Information and Our Privacy Commitment
Personal Information includes any information relating to, describing, reasonably capable of being associated with, or capable of reasonably being linked, directly or indirectly, to an identified or identifiable natural person.
2. How do we collect personal information?
Where possible, we collect your Personal Information directly from you, in accordance with applicable law. This collection may include when:
(a) you interact with us on our websites or the investor portal; and
(b) you communicate with us via email, phone or social media.
We may collect your Personal Information from third parties or public agencies to verify any information you provide or in instances where it would be impracticable or unreasonable for us to collect the Personal Information directly from you. Any information we collect from third parties will be done in a fair and lawful manner and is considered reasonably necessary for our functions or activities.
3. What personal information do we collect?
The Personal Information we collect differs dependent upon the purpose of collection and the services we are providing to you. We will retain the information provided, unless we explicitly advise you otherwise. Generally, we collect the following types of personal information from you:
(a) contact information, such as your name, email address, physical address and telephone numbers;
(b) demographic information, such as your age and gender; and
(c) any other information you voluntarily provide to us.
There will be certain occasions where we will collect additional personal information. Where you apply for employment with us, we may collect additional personal information such as employment history, educational history, and employment references.
Any unsolicited personal information you provide us with, will be assessed to determine whether such information is reasonably necessary for one or more of our functions or activities. The unsolicited personal information you disclose to us may be used and disclosed for the purpose for which you supplied such information or where you would reasonable expect us to. We may also disclose or use the information for alternate purposes with your consent or as may be required by law.
4. Why do we collect and use your personal information?
The Personal Information we collect depends on the nature of the relationship we have with you. Generally, we will collect your Personal Information to provide you with the services you have requested, including without limitation, for the following purposes:
(a) information services such as industry information and quarterly updates on fund performance; and
(b) customer care such as processing payment for services provided, dealing with enquiries, requests and assessing and handling complaints.
5. Who do we disclose your personal information to?
In the conduct of business, we may disclose your information to third parties. This may include without limitation, disclosure:
(a) to employees, related bodies corporate, agents, contractors or service providers for the purposes of operating our business, fulfilling your requests and providing you with services;
(b) to suppliers and other third parties where we have established commercial relationships (including outsourced and cloud service providers) for business, marketing, maintenance, distribution of services and related purposes;
(c) with your specific and prior consent, to other companies or individuals for the purposes you have consented to; and
(d) where we consider in our absolute discretion, we are required to disclose the information in order to satisfy any applicable law, regulation, legal process or government request.
Some of our related bodies corporate, contractors and/or services providers may be located overseas. By disclosing your personal information to these parties, your personal information may be transferred overseas. Any organisations which we disclose your personal information to locally or overseas, are subject to reasonable contractual obligations to safeguard and protect your personal information and comply with all privacy laws.
6. How is your personal information secured?
Reasonable steps will be taken to protect your Personal Information from any misuse, interference, loss, unauthorised access, modification or disclosure. We maintain physical and electronic security over our paper and electronic data storage as well as computer and network security.
Subject to applicable privacy laws, we will either destroy or permanently anonymise your personal information when it is no longer needed for its purpose and it is not required to be retained by law.
7. Access To And Correction Of Personal Information
It is your responsibility to ensure the information we hold about you is accurate, current, complete, relevant and not misleading.
Where you have direct access to your Personal Information, you will be required to adhere to prompts to access, correct or update your Personal Information.
Alternatively, you can access or correct your Personal Information or Personal Information we hold about a minor or child you have legal authority to represent, by contacting us through the ‘Contact Details’ disclosed below.
There may be circumstances where we may refuse your request to access, or correct, your Personal Information. If that is the case, we will provide you with reasons for that decision unless it is unreasonable for us to do so. We take reasonable steps to ensure Personal Information we use is accurate, complete and current including updating Personal Information when we are advised by you that your Personal Information has changed. We are determined to respond to all requests for access and/or correction within a reasonable time.
8. Direct Marketing
We may rely on your Personal Information to send you direct marketing communications and information about our services that we may consider to be of interest to you. These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing laws. You consent to us sending you direct marketing communications through any of those methods.
If a preferred method of communication is indicated, we will endeavour to use that method when practical. In addition, you may opt out of marketing communications at any time by contacting us (through the ‘Contact Details’ disclosed below) or by using opt-out facilities provided in marketing communications.
When you use our website, we may use analytic tracking via a third party to gather information about how the website is used. A “cookie” is a small piece of information, or file that a website sends to your computer’s hard drive while you are viewing that website for record keeping purposes. If you do not wish to receive any cookies you may change your browser settings to block them. This may mean you might not be able to take full advantage of the website.
The information collected from cookies is used for numerous reasons, including without limitation:
(a) To measure traffic patterns and determine which parts of our website have been visited;
(b) To recognise your computer and avoid requesting you to register or log-in again; and
(c) To administer the website and analyse trends.
10. Anonymity and use of a pseudonym
You may request to deal with us anonymously or through a pseudonym. To the extent that it is lawful and practical for us to do so, we will grant such a request. Although, we may not be able to provide a complete range of services where you elect to do so.
Besides the use of a pseudonym, all other information shared must be true and correct.
11. How to make a complaint
Any complaints about the way in which we handle your personal information should be directed to our Privacy Officer using the ‘Contact Details’ disclosed below. We will investigate any complaint promptly and will respond to written complaints within a reasonable time from the date of receipt. If you are dissatisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner for guidance on alternative courses of action that may be available (refer to https://www.oaic.gov.au).
12. Your lawful rights
Each jurisdiction grants certain lawful rights in respect of your Personal Information. In some jurisdictions, additional rights may be available to you – these are outlined in Schedule A.
13. Changes to the policy
14. Contact details
Schedule A: Additional Privacy Requirements
For European Union (EU) residents, the following additional rights apply globally:
Right to erasure – you have the right to require us to delete your information if our continued use is not justified. However, this will need to be balanced with other factors. Depending on the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations restricting us from complying with your request.
Right to restrict processing – in some circumstances, you may be entitled to limit the purposes for which we can use your information.
Right of data portability – you have the right to require us to provide you with a copy of the personal information that you have supplied to us in a commonly used machine-readable format or to transfer your information directly to another controller (e.g. a third party offering services competing with ours). Once transferred, the other party will be responsible for looking after your personal information.
Right to withdraw consent – for certain limited uses of your personal information, we may ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. If you withdraw your consent, we may not be able to provide certain services to you.
In some circumstances exercising some of these rights will mean we are unable to continue providing services to you.