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.
- 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/CRS, 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), copies of passports and driver’s licenses or other identification as supplied by you or your representatives to meet AML requirements. Details of your profession and the source of your investment funds tax residency information 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, insolvency records, police check 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 police and insolvency checks as well as background checks. 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. Investors may choose to undertake an identification check for AML purposes against credit agency data bases, as part of electronic verification of your identification. This is voluntary, and you will always be provided alternate options.
- 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. We may contact you to verify information we hold on file about you, or to collect further information. We may contact you for this purpose by phone, email, or post. Fundhost will always provide you with alternate means of providing us this information and if you are in doubt you should independently phone our office to verify you are dealing with a valid request from Fundhost. 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.
- 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.
- 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, and financial 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 must provide the Australian Taxation Office (ATO) with certain investor information. The ATO may provide information about suspected foreign tax residents to overseas tax authorities. We do not send your information overseas, unless you request this. However, some server data back-up warehouses may be in first world countries such as the US and UK. These are sometimes located over several countries to reduce single location risk.
- 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.
- How we will respond to a data breach
Fundhost has systems and controls in place aimed at protecting information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Fundhost falls under the regime known as the Notifiable Data Breaches (NDB) scheme. As a result of amendments to the Privacy Act 1988 (Cth) (Privacy Act) data breaches that are assessed as likely to result in personal harm are to be reported to the Office of the Australian Information Commissioner (OAIC) and affected parties. A data breach occurs when personal information held by an organisation is lost or subjected to unauthorised access or disclosure. Data breaches include: information that is lost or stolen a database containing personal information is hacked; and personal information is accidentally provided to the wrong person. Fundhost is prepared and committed to compliance with the Notifiable Data Breaches (NDB) scheme.