- What personal information we collect
- How we collect and store personal information
- How we use personal information
- How personal information can be disclosed to others
- How you may access or correct your personal information
- How you can complain if you have concerns about how we have managed your personal information.
The Company has practices in place to comply with the 13 Australian Privacy Principles set out in the Privacy Act 1988. These principles govern how organisations handle personal information.
1. WHAT PERSONAL INFORMATION DOES THE COMPANY COLLECT?
Personal information is information or an opinion about you from which you can be reasonably identified. The Company collects personal information so that we can administer your investment in the Company, provide facilities and services that you request and comply with our legal obligations. If the Company does not collect your personal information, we may not be able to provide you with these services.
The kinds of personal information that we may collect and hold about you include: your name, contact details, date of birth, citizenship, tax file number (TFN) and banking details.
In addition, we may collect personal information about other individuals (e.g. business contact details of a company representative with whom we deal).
Generally, we will not collect sensitive information about you (such as your race, political beliefs or religion). If we need sensitive information, we will ask for your consent when we collect this information (unless an exemption applies).
2. HOW DO WE COLLECT AND STORE PERSONAL INFORMATION?
Depending on how you choose to interact with us, we may collect your personal information when you contact us or our service providers by telephone, by email, through our web site or when you complete a form or document and provide it to us. The Company may also collect information about you from third parties. For example, the Company may collect personal information from our service providers, including Link Market Services Limited.
Collecting information from visits to the Company’s website
We may collect information based on how you use our website. We use “cookies” and other data collection methods such as pixel tags to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our site. This information is collected to analyse and improve our website, our marketing campaigns and to record statistics on web traffic. No attempt is made by the Company to use this information to personally identify you.
Securing your personal information
We hold personal information in secure computer storage facilities (both in-house and at our service providers); on paper-based files; as well as in other formats. The Company takes reasonable steps to protect your information from loss and unauthorised access, destruction, use, modification or disclosure. Access to personal information held by the Company is controlled to prevent misuse or unauthorised disclosure of the information. We utilise a range of technical security measures such as secure authentication, password controls, encryption, firewalls and anti-virus technology to prevent unauthorised access to your information.
3. HOW DO WE USE YOUR PERSONAL INFORMATION?
The Company may collect, hold, use or disclose your personal information so that we can administer your investment in the Company and provide facilities and services that you request.
We may also collect, hold, use or disclose your personal information to:
- Consider any concern or complaint that you raise against the Company or to manage any legal action between you and the Company;
- Prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
- Identify you or establish your tax status under any Australian or foreign legislation; or
- Comply with any relevant laws, regulations, codes of practice and court orders.
The Company may use your personal information that we have collected about you to identify a product or service that may be of interest to you. If at any time you no longer wish to be notified about other services or promotions please contact us. Privacy specific contact details are included at the end of this policy.
4. HOW IS PERSONAL INFORMATION DISCLOSED TO OTHERS?
The Company does not sell, rent or trade personal information to, or with, third parties.
In some circumstances your information may be disclosed to service providers that perform a range of services on our behalf. Examples include:
- Mailing houses and printing companies;
- Auditors and solicitors;
- Registry providers (including Link Market Services Limited);
- Information Technology vendors; or
- Other consultants.
In some circumstances, personal information may be disclosed to third parties in jurisdictions including Australia, New Zealand, Singapore, United Kingdom and India.
Where we disclose your information to our service providers, we will take steps to ensure that they are authorised to only use personal information in order to perform the functions required by the Company.
We may also disclose your personal information to law enforcement agencies, courts or government agencies where required to comply with specific legal requirements. In particular, the Corporations Act 2001 (Cth) requires certain information about you to be included in the Company’s registers which is able to be accessed by the public.
5. HOW YOU MAY ACCESS OR CORRECT YOUR PERSONAL INFORMATION
You may contact us to request access to the personal information we hold about you at any time. You may also ask us to correct information about you that you may believe is inaccurate, incomplete or out of date.
We will need to verify your identity before giving you access, or correcting your information.
In certain circumstances, the Company may not be able to correct or provide you with access to your information. In these circumstances, we will write to you to explain and provide the reasons why.
6. HOW YOU MAY COMPLAIN IF YOU HAVE CONCERNS ABOUT HOW WE HAVE MANAGED YOUR PERSONAL INFORMATION
If you have a complaint related to how the Company has managed your personal information, please contact us using the contact information below. We may ask you to place your concerns in writing in order for us to fully understand and investigate the issues you have raised. We will acknowledge any complaint in writing within five business days and make every effort to resolve your issue within a reasonable time of us being notified.
If a complaint remains unresolved, you may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. The Commissioner may be contacted on the privacy hotline: 1300 363 992.
When we write to you about our decision, we will explain how you may access an external dispute resolution scheme or make a complaint to the OAIC.
NEED MORE INFORMATION?
by telephone: 02 9229 9000; or
by email: firstname.lastname@example.org; or
by letter: The Company Privacy Officer, GPO Box 4172, Sydney, NSW 2001