FUNDHOST

TERMS OF USE

Fundhost Privacy Policy: March 2014

Fundhost understands that privacy is important to you.

Fundhost is subject to the requirements of the National Privacy Principles which are contained in the Privacy Act 1988 (the Privacy Act) and which govern how we handle personal information. This policy affirms our commitment to comply with those principles.

1. What Personal Information does Fundhost collect?

Personal information means any information that can identify you.

Fundhost may obtain personal information in order to provide you with our services or manage our relationship with you. If you acquire services from Fundhost, we may ask you to provide certain details including, for example, your name and contact information, your birth date, your tax file number.

We collect personal information about you which is reasonably necessary to:

  • provide you with products or services
  • consider applications and approaches you make to us
  • maintain your contact details
  • help us to identify you over the phone
  • fulfil our legal obligations under applicable laws and rules, such as those relating to taxation, wholesale eligibility rules, FATCA beneficial ownership, and Anti-Money Laundering and Counter-Terrorism Financing.

The information we collect may include information relating to:

  • the products and services we provide or have provided to you
  • your financial interests in products we issue or administer, if you are a customer or potential customer of ours
  • your name, contact details and date of birth
  • government identifiers including: Medicare Card number, Passport number, Tax File number and ABN (for example to verify your identity at the time of investment)
  • records of our interactions with you, including by telephone, email and online
  • your enquiries or complaints.

Investors need to be aware that if you do not provide us with certain information, in some circumstances we may be unable to provide a service.

For businesses with which we have a relationship or with which we are considering entering into a contractual relationship; we collect information on the business and their representatives. This is part of our due diligence and oversight program and includes collecting reference checks, CV’s, bankruptcy records, and police checks and information about education and membership of professional bodies.

We also may keep information on persons who submit applications or register interest for employment with us. Successful applicants will also be subject to a police check.

Generally, we will not collect sensitive information about you (such as your race, political beliefs, religion or health) unless this is required to enable us to provide you with services. If we need sensitive information, we will ask for your consent when we collect this information (unless an exemption applies).

We do not collect credit information from credit reporting bodies. The exception is to run bankruptcy checks on potential and existing business partners and staff.

2. How is Personal Information collected and held?

The nature of the personal information we collect and hold, and where it comes from will vary according to the circumstances in which we are dealing with you.

We may collect personal information about you as provided to us as part of the product application process. Other parties such as your financial advisor may provide us information about you to help us perform our role as Trustee and administrator. We may also record information provided to us verbally if you call our office and speak directly with our staff or if you contact us via email or regular mail.

We may verify your identity to meet legislative requirements by using special purpose third party service providers.

Fundhost takes reasonable steps to protect the personal information it holds from loss and unauthorised access, destruction or disclosure. Fundhost may use specialist information storage suppliers to further safeguard your information.

3. How do we use Personal Information

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

We may share your contact information and investment details with the Investment Manager of the product you invested in. They will use this information to service you, such as to send you investment reports. They may provide you with access to your information through a password protected internet information portal so you can access your information at any time or let you know about other investment opportunities.

The personal information collected from you by Fundhost may be used to:

  • provide you with our services or with other information you have requested
  • determine if we are able to supply you with services
  • notify you about other services or promotions from time to time; or
  • manage our relationship with you.

Personal information collected from you, for example your email address will only be used to send commercial electronic messages, such as promotional emails and banners, if express or inferred consent has been obtained.

If at any time you no longer wish to be notified about other services, or investment offers by Fundhost or your Investment Manager, please let us know.

4. Disclosure of Personal Information to third parties

Our policy is designed to maintain the confidentiality of all personal information held by Fundhost and prevent its misuse. Fundhost does not sell, rent or trade personal information to, or with, third parties.

In some circumstances, however, personal information may be disclosed outside Fundhost. For example:

For legal reasons, disclosures may need to be made to law enforcement agencies, government agencies, courts or external advisers.

In some circumstances, personal information is disclosed to third parties where this is related to the supply of our services. Personal information may be disclosed to third parties to whom Fundhost contracts out specialised functions, such as Investment Managers, registry service providers, mailing houses, auditors. If so, we take steps to ensure that those contractors comply with the Privacy Act, and are authorised only to use personal information in order to perform the functions required by Fundhost.

We disclose information to your nominated financial adviser with your permission.

We do not send your information overseas, unless you request this.

5. How to access and correct your Personal Information?

Under the Privacy Act, you are entitled to seek access to information which we hold 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. Fundhost’s policy is to consider any requests for access or correction in a timely way.

Once we have validated your identity, we will ordinarily provide you with a print-out of the relevant personal information from our current database, or with photocopies of records which are held only on current paper files.

If you have any questions about this privacy policy, if you have a complaint about how we have handled personal information about you, or if you wish to access or correct your personal information, please contact Fundhost’s Privacy Officer who is the Compliance Officer.

by telephone: 02 8223 5400

or by letter: The Privacy Officer, Fundhost Limited, PO Box N561 Grosvenor Place, Sydney, NSW 2001

This privacy policy is dated 5 March 2014, the policy may change from time to time.