Privacy Policy

Privacy relates to the protection of personal information- information that identifies you or could identify you. This differs from confidentiality, secrecy or freedom of information.

We work consistently with the APPs as to how we collect, use, disclose and protect personal information, and your rights to access and correct it.

The law allows you to:

• know why your information is collected and how it’s used,
• access your records,
• stop unwanted marketing,
• correct inaccurate details, and
• ensure your information is only used as our policy states.

See https://www.oaic.gov.au/ for information about Australia’s privacy laws.

We collect, hold, use and disclose personal information so that we can provide financial services, promote and operate the Funds, and run our business. This includes assessing and processing applications, establishing and administering investments, maintaining registers, responding to enquiries and complaints, and managing our relationships with investors and other stakeholders.

We also use personal information to comply with our legal and regulatory obligations (for example under corporations, financial services, anti-money laundering, tax and sanctions laws), to cooperate with regulators and external auditors, and for operational, risk management, training and quality-assurance purposes.

We may use personal information for analytics, research and statistical activities, where practicable using de-identified information. We may also use your personal information to provide you with information about products and services offered by us or our related entities that we believe may be of interest to you. You can opt out of receiving direct marketing from us at any time.

If you don’t provide required information, we or others may not be able to provide products or services to you or otherwise deal with you.

We do not make decisions about you that have legal or similarly significant effects based solely on automated processing of your personal information.

We usually collect personal information directly from you – for example when you complete application or other forms, contact us by phone, email or post, use our website or digital services, or participate in events or other activities we organise.

We also collect personal information from third parties where this is reasonable and lawful. These can include the trustee of a Fund and its registry or administration service providers, your financial adviser or broker, distributors and platform operators, identification-verification service providers, your employer or other organisations you deal with, and public sources such as company or government registers.

Where someone else gives us personal information about you, we rely on them to have your authority or another lawful basis to do so. If we collect personal information about you from someone else, we take reasonable steps to ensure you are aware of the collection and how it will be handled.

We may automatically collect certain technical information when you visit our website (for example log information, device identifiers and cookie data) to help us operate and improve our online services and tailor content.

We only collect personal information we consider reasonably necessary for one or more of our functions or activities. This can include:

• your name, contact details and date of birth,
• information about your investments and interactions with us,records of communications with you, and
• information we are required or authorised to collect under laws or regulatory policies
  for example relating to financial services, tax or anti-money laundering.

In operating the Fund, the trustee and its registry and administration service providers may also collect and hold additional personal information, such as banking details, TFNs/ABNs, information about the source and use of money invested and tax status. Their privacy policies are available on their websites.

We disclose personal information only:

• for the purpose for which it was collected, or a related purpose you would reasonably expect
  with your consent, or
• where we are required or authorised to do so by law.

Recipients may include:

• the trustee of a Fund and its registry and administration service providers,
• our and their related entities and service providers (such as custodians, IT providers, cloud and data-hosting providers, insurers, lawyers, auditors and consultants),
• regulators and government agencies,
• your financial adviser or other authorised representatives, and
• other third parties you ask us to share your information with,

or as permitted by the Privacy Act.

Some recipients may be located outside Australia. Where we disclose personal information overseas, we take reasonable steps to ensure that it is handled in accordance with the Australian Privacy Principles. In most cases we remain accountable in Australia for that handling.

We are committed to ensuring that your personal information is kept secure. We take reasonable steps to protect information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. Measures may include access controls, user authentication, physical security, system security, staff training and incident-response processes.

We use the internet in our business, and records may be stored on secure servers (including in the cloud) in Australia or overseas by us and by our service providers. We take reasonable steps (including contractual protections and security measures) to ensure that those providers protect personal information and only use it for authorised purposes.

The internet is not always a secure environment, and although we take steps we consider reasonable to protect your information, we cannot absolutely guarantee its security.

We have processes for identifying, assessing and responding to actual or suspected data breaches involving personal information. If we determine that a data breach is likely to result in serious harm to affected individuals, we will notify those individuals and the Office of the Australian Information Commissioner in line with the Notifiable Data Breaches scheme.

We may use cookies and similar technologies to collect information about how our website is used (for example the type of browser, pages viewed, time on site and navigation patterns) and to help the site function and remember you when you return.

We generally use this information in aggregate form to help improve the design and performance of our website. In some cases cookie data may be linked with other information we hold and therefore be treated as personal information – in that case it will be handled in accordance with our Privacy Policy.

You can configure your browser to accept or reject cookies. If you choose to reject cookies, some features of our website may not work properly.

You generally have the right to access and correct your personal information, subject to legal exceptions. If we refuse, we will explain why

We may update our policy and will publish a fresh summary as needed on our website.

For further information or to raise concerns about our privacy practices, please contact us by email at enquiries@thirdlink.com.au.