Invest Unlisted Pty Ltd (ACN 166 819 898, CAR 454 235) is committed to protecting your privacy and the security of your personal information and acting in accordance with your rights under data protection law.
"Personal information" is any information that can identify you or that can reasonably enable your identity to be determined. This information could include your name, postal or email address, date of birth, or financial details. Personal information includes "sensitive information." Sensitive information is any personal information about your racial or ethnic origin, political opinions, membership in a political association, religious beliefs or affiliations, philosophical beliefs, membership in a professional or trade association, membership in a trade union, sexual preferences or practices, criminal record, health or genetic information.
The type of personal information we collect and hold about you will depend on the dealings you have with us. When you deal with us the types of personal information you may be required to provide include: • Your contact details (name, address, telephone number, email address), date of birth, gender, and/or occupation • Financial information • Your Tax File Number • Your Australian Business Number (if applicable) • Your bank account or other financial institution details • Identification documents (for example, drivers licence) When you use our website, we may also indirectly collect your internet protocol (IP) address, device identifiers, browser type, operating system, internet service provider, location, mobile network information, pages accessed, time stamps and your online transaction history.
If you choose to become an investor in a fund that we manage, we may collect, use, and disclose your personal information, including for the following purposes: • Your identification details are used to process your application, verify your identity and contact information, set up an account in your name, provide you with secure access to our website, process transactions and send you confirmations, manage your investment, ensure that you receive your distributions. • During the time you are an investor in our fund we will hold investment-related information about you including the amount you have invested. • Your Tax File Number and Australian Business Number (where relevant) will be collected in order for us to ensure that your investment is taxed correctly.
If lawful and practicable, we offer you the opportunity to deal with us anonymously or by using a pseudonym. For example, we can provide general information to you about our products or services without collecting any personal information. However, if we are unable to collect and/or verify some or all of your personal information, we may not be able to enter into a business relationship with you or provide certain services to you.
Invest Unlisted, and Evolution Trustees Limited (ACN 611 839 519, AFSL 486217) as trustee for the Fund, will generally collect your personal information as much as possible directly from you. For example, we collect information about you through your application form and other forms that you may complete after becoming an investor in our fund.
Some examples of persons to whom we may disclose your personal information are: • Mail and electronic mail service providers for the communication of investor statements and other information • Custodians and fund administrators • Legal advisers and other experts • Regulatory authorities and legal bodies as required by law (e.g. Australian Taxation Office, ASIC or a Court or tribunal) • Auditors • Third parties (if you give us permission to do so e.g. your financial adviser) • Other third-party service providers
We will only disclose your personal information to a recipient overseas in accordance with the Privacy Act. Circumstances in which we will do this include instances where you have asked us to or we have your consent to do so, we have outsourced a business activity or function to an overseas provider, or the disclosure is required or authorised by or under an Australian law or a court/tribunal order.
We have security policies and systems in place to protect your personal information. We take reasonable steps to protect the personal information we hold from loss, interference, destruction, unauthorised access, modification, or disclosure using both physical and electronic security measures. We implement multiple layers of security controls throughout our systems.
You may request access to any of the personal information we hold about you by contacting us. We will provide you with access to your personal information in accordance with the Privacy Act. Under the Privacy Act, we can deny access to some or all of your personal information in specified circumstances and will provide reasons for any refusal in writing.
We endeavour to ensure that the personal information we hold about you is accurate, up to date, complete, relevant, and not misleading. Please let us know if you believe any of your personal information that we hold is incorrect by contacting us.
Some of the pages on our website use "cookies," which are small files that may be placed on your hard disk for record-keeping purposes. Cookies help us remember who you are and may collect and store your server address, top level domain name, the date and time of your visit, the type of browser you used, the pages viewed and any downloads made. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.
We have appointed a Privacy Officer. If you have any queries you can contact us by the following means: Call: +61 (3) 9225 5216 Mail: Attn: Privacy Officer, Invest Unlisted, Level 31, 120 Collins St Melbourne VIC 3000 Australia
If you believe that we have not protected your personal information as set out in this privacy policy you may lodge a complaint with us: Call: +61 (3) 9225 5216 Email: privacyofficer@investunlisted.com.au Mail: Attn: Privacy Officer, Invest Unlisted, Level 31, 120 Collins St Melbourne VIC 3000 Australia If you are not satisfied with how we deal with your complaint you may refer it to the Office of the Australian Information Commissioner (OAIC). Online: www.oaic.gov.au Email: enquiries@oaic.gov.au Phone: 1300 363 992
This privacy policy may change from time to time. We will display our current privacy policy on our website and we may notify you when significant changes are made. This privacy policy was last updated on 1 November 2019.