Australia’s National Privacy Policy contained in the Privacy Act 1988 (the Privacy Act) defines Personal Information as information or opinion that allows others to identify you. It includes your name, age, gender, contact details as well as your financial information.

At Third Link Investment Managers Pty Limited (Third Link) the privacy of your personal information is important to us. We collect personal information to provide you with the products and services you request. In some circumstances the law may also require us to collect personal information.

What personal information does Third Link collect?

Third Link may obtain personal information in order to provide you with our services or manage our relationship with you.

If you acquire services from Third Link, we may ask you to provide certain details including, for example, your name and contact information, your birth date, your tax file number and your financial details. We may collect personal information about you from an application form or a registration form or verbally if you speak directly with our staff.

Sometimes, we may need to collect personal information about individuals who are not customers of Third Link (for example, business contact details of a company representative with whom we deal).

See also “Internet privacy” below.

How is your personal information dealt with?

In the course of doing business we outsource certain tasks to third party suppliers. In these circumstances we may disclose your personal information to third parties including administration and unit registry services, mailing houses, information technology support, email suppliers, the responsible entity of the fund we manage. From time to time we also seek expert help to improve our systems, products and services. These third parties are bound by confidentiality agreements when handling your personal information. Your personal information will not be shared with third parties other than of this kind without your consent.

Your personal information may also be used by us to administer products and services, gather, aggregate and report statistical information, assist you with any queries and take measures to detect and prevent fraud and other illegal activity. We may also be allowed or obliged to disclose information by law and to report on prudential or risk management matters to regulators and our related bodies.

If you used a financial adviser who recommended your investment in the fund (as indicated on your application form), then details of your investments may be provided to your current financial adviser.

Third Link’s policy is to use personal information only for the main business purposes for which it was collected.

The personal information collected from you by Third Link may be used to provide you with our services or with other information you have requested or manage our relationship with you.

Personal information collected from you will only be used to send commercial electronic messages if express or inferred consent has been obtained.

Security

All our data is stored in written and/or electronic form and we maintain physical, electronic and procedural safeguards to protect your personal information. We restrict access to information about our clients to those employees, corporate partners and third party providers who need to know that information to deliver services efficiently and effectively. We are committed to ensuring that any personal information you provide to us remains confidential and secure.

Internet Privacy

We receive information from browsers when you visit our website such as your server address, domain name, date and time of your visit, pages visited and selected information for statistical purposes only. No personal information is available on the Third Link website.

The only personal information which we collect about you when you use the website is what you tell us about yourself if you send us an email. We will record your email address if you send us an email.

Our website contains links to other websites, for your convenience and information. When you access a website other than our website, please understand that Third Link is not responsible for the privacy practices of that site. We suggest that you review the privacy policies of each site you visit.

Accuracy of your personal information

We aim to ensure that the personal information we retain about you is accurate, complete and up to date. You will be asked to agree to the use, collection and disclosure of your personal information when you make an investment in the fund. If you provide us with incomplete or inaccurate information, we may not be able to provide you with the products or services you are seeking.

Your right of access and correction

Under the Privacy Act, you have the right to seek access to information which Third Link holds about you (although there are some exceptions to this). You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date.

If you wish to exercise your right under the Privacy Act to seek access to the personal information that Third Link holds about you, or if you believe that personal information about you is not accurate, complete or up to date, you should contact Third Link, including the details of your request for correction. The contact details can be found at the end of this Privacy Policy.

Third Link’s policy is to consider any requests for access or correction in a timely way.

Please note that the personal information we hold about you will be information that you have provided.

Contacting Third Link

If you have any questions, complaints or would like further information on our privacy and information handling practices, you can:

Contact us by calling 1300 793 855 or emailing us at enquiries@thirdlink.com.au

This privacy policy may change from time to time.

Fundhost Limited Privacy Policy

As Fundhost LImited ABN 69 092 517 087, AFSL 233045 (Fundhost) is the Responsible Entity for the Fund, personal information obtained in relation to an application into the Fund will also be handled in accordance with Fundhost’s Privacy Policy.

Fundhost’s Privacy Policy is available here.

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