What is personal information?
Personal information is information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, email address and contact details.
What personal information do we collect?
The information we may collect from you and hold includes:
- name, address and date of birth;
- contact information, including telephone numbers, mailing addresses and/or email addresses;
- bank account details;
- ID information including your drivers’ licence or passport details;
- details of your current financial circumstances (personal and/or business), including your assets and liabilities (both actual and potential), income and expenditure; and
- any other relevant information that you give to us for the purpose of providing you with our products or services.
We may collect these types of information either directly from you or from third parties. We may collect information when you complete an application form, enquire about investing with us or otherwise engage with us.
We may collect information about you from others such as:
- financial institutions;
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
- assessing applications for our products and services;
- administering our products and services, including maintaining any managed investment scheme of which we are the trustee for and facilitating the issue of units in those managed investment schemes;
- sending you information that you request, or other information that we consider is important to tell you;
- to correspond with you and send/receive information from you;
- dealing with complaints;
- answering queries;
- to enable you to access and use our website and services;
- to send you marketing and promotional messages and other information that may be of interest to you;
- complying with our legal obligations, including for example, to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006; and
- for any purpose related to the above.
If you do not provide us with the personal information we request, we may not be able to provide you with the services or products you have requested.
Do we use your personal information for direct marketing?
We may send you direct marketing communications and information about our services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or email.
To whom do we disclose your personal information?
- our service providers that provide administrative or promotional services to us (for example, mail processing businesses, printers, data storage, sharing and collaboration service providers);
- legal and accounting firms, auditors, consultants, financial institutions and other advisers for the purpose of administering our managed investment schemes;
- government authorities when required by law; and
Do we disclose personal information outside Australia?
Due to some of the software we use to provide our products and services, data maintained by us may be disclosed and stored outside Australia, including in Hong Kong.
We will take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
Using our website and cookies
We may collect personal information about you when you use and access our website.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
How do we keep your information safe?
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example we:
- train our staff about how to keep your information safe and secure;
- have firewalls, intrusion detection and virus scanning tools to stop viruses and unauthorised access to our systems;
- have building security measures in place;
- destroy and de-identify data when it is no longer required.
However, we cannot guarantee the security of your information.
Accessing or correcting your information
You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your information.
If you think that any information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
If you are not satisfied with how we have dealt with your complaint you can contact the Office of the Australian Information Commissioner using any of the following details:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
T: 08 7099 3983
E: [email protected]
A: Level 1, 86 Pirie Street, Adelaide SA 5000
Effective: March 2019