Accuracy, completeness and timeliness of information
The information on our website is not comprehensive and is intended to provide a summary of the subject matter covered. While we use all reasonable attempts to ensure the accuracy and completeness of the information on our website, to the extent permitted by law, we make no warranty regarding the information on this website. You should monitor any changes to the information contained on this website.
We are not liable to you or anyone else if interference with or damage to your computer systems occurs in connection with the use of this website or a linked website. You must take your own precautions to ensure that whatever you select for your use from our website is free of viruses or anything else (such as worms or Trojan horses) that may interfere with or damage the operations of your computer systems.
We may, from time to time and without notice, change or add to the website or the information or services described in it. However, we do not undertake to keep the website updated. We are not liable to you or anyone else if errors occur in the information on the website or if that information is not up-to-date.
Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we do not endorse and are not responsible for the content on those linked websites and have no control over or rights in those linked websites.
Any information provided by us on our website is provided for informational purposes only, and is not a recommendation or endorsement by us to acquire any interest in a scheme or other financial product we issue or make available on our website or otherwise.
Intellectual property rights
Unless otherwise indicated, we own or license from third parties all rights, title and interest (including copyright, designs, patents, trademarks and other intellectual property rights) in this website and in all of the material (including all text, graphics, logos, audio and software) made available on this website (Content).
Your use of this website and use of and access to any Content does not grant or transfer any rights, title or interest to you in relation to this website or the Content.
Any reproduction or redistribution of this website or the Content is prohibited, except to the extent permitted by law and may result in civil and criminal penalties. In addition, you must not copy the Content to any other server, location or support for publication, reproduction or distribution is expressly prohibited.
You may download a single copy of material on this website, keep a temporary copy in your computer's cache and where necessary for reference, make a single hard copy.
Warranties and disclaimers
To the maximum extent permitted by law, we make no warranties or representations about this website or the Content, including but not limited to warranties or representations that they will be complete, accurate or up-to-date, that access will be uninterrupted or error-free or free from viruses, or that this website will be secure.
We reserve the right to restrict, suspend or terminate without notice your access to this website, any Content, or any feature of this website at any time without notice and we will not be responsible for any loss, cost, damage or liability that may arise as a result.
To the maximum extent permitted by law, in no event shall we be liable for any direct and indirect loss, damage or expense – irrespective of the manner in which it occurs – which may be suffered due to your use of our website and/or the information or materials contained on it (including without limitation, the Content), or as a result of the inaccessibility of this website and/or the fact that certain information or materials contained on it (including without limitation, the Content) are incorrect, incomplete or not up-to-date.
Jurisdiction and governing law
Your use of the website and these Terms are governed by the law of South Australia and you submit to the non-exclusive jurisdiction of the courts exercising jurisdiction in South Australia.
We can unilaterally vary these terms at any time. By accessing or continuing to access the Website after we have varied the terms, you will be deemed to have accepted the varied terms. It is therefore important that you review these terms regularly.
If any term is declared unlawful, void or unenforceable, that term will be deemed severable and will not affect the validity and enforceability of the remaining provisions of these terms.
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:
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;
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 [email protected].
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
A: Level 1, 86 Pirie Street, Adelaide SA 5000
Effective: March 2019