Privacy Policy

PROTECTING CAPITAL, GENERATING INCOME, ENHANCING GROWTH

Privacy Policy

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Skybound Fidelis Investment Limited is committed to the protection of the privacy of the people we deal with and we seek to uphold high standards of privacy practice and security. This policy explains how we handle personal information.

Whenever we handle personal information, we seek to ensure that appropriate standards of privacy practice and security are applied.

This policy sets out the kinds of personal information that we collect and hold, why we need to collect personal information, how we collect it, what we do with it, how it is stored and who we might share it with. The policy also describes how you can access or correct information we hold about you, how you can ask further questions or make a complaint. We will update this privacy policy when our information handling practices change. Updates will be published on our website and through our email lists.

For most products and services it is necessary for us to collect ‘personal information’ such as your name, identity details, contact details, transaction information and other personal details where needed (such as your tax file number and financial information).

Sensitive Information

Generally, we do not collect sensitive information about you unless required by law or where you consent for us to do so (only where it is relevant to your product). Sensitive information includes information relating to race, political or religious beliefs, sexual orientation, criminal history and association memberships. We may collect information about your affiliation with certain organisations, such as professional associations.

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

  • provide you with our products or services;

  • consider applications and approaches you make to us;

  • conduct marketing;

  • maintain your contact details; and

  • fulfil our legal obligations, such as those relating to taxation and anti- money laundering and counter-terrorism financing or as otherwise authorised by you.

Without such information, we may not be able to process your application or provide you with an appropriate level of service.

We collect personal information about you directly from you – this can be in person, in documents you give us, from telephone calls, emails or from transactions you undertake with us.

We may also collect your personal information from third parties including public sources, your adviser(s), agents, referrers, brokers, our related companies and service providers (including credit reporting bodies and information service providers).

We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include storage on the cloud. Where this occurs, we take steps to protect personal information against misuse or loss.

We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints.

We use personal information about you for the purpose for which it was provided to us, including to:

  • process applications for investments in our managed funds;

  • administer and manage our products and services (including monitoring, auditing, and evaluating those products and services); and

  • communicate with you and deal with or investigate any complaints or enquiries.

    We may also use your personal information for related purposes which would reasonably be expected without your permission. For example, we may from time to time use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, if you do not want to receive such communications, you can tell us by using any of the methods listed below.

    While we may sometimes share personal information with companies we do business with (e.g. in product development, joint venture arrangements or distribution arrangements), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.

We may disclose personal information outside Skybound Fidelis Investment Limited:

  • as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator;

  • to our service providers, who provide services in connection with our products and services (including auditing, accounting, legal, mailing, marketing, insurance, identity verification, trustee, website and technology services);

  • to your nominated financial adviser with your permission; and

  • as contained in the terms and conditions of our product or service.

    It is unlikely that any of the parties to whom we disclose personal information operate outside of Australia. However, where this occurs, we will take steps to protect personal information against misuse or loss.

We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

We use security procedures and technology to protect the information we hold. Access to and use of personal information within Skybound Fidelis Investment Limited seeks to prevent misuse or unlawful disclosure of the information – this includes internal policies, training and monitoring of staff.

If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.

Where the personal information we collect is no longer required, we delete the information or permanently de-identify it in accordance with relevant laws.

You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

If you have any questions or complaints regarding a breach of this Privacy Policy including the way in which we have collected, held, used, disclosed, kept or given access to your personal information, you can make a complaint to us using the contact details set out below. ,

Please write to GPO Box 2085, Brisbane QLD 4001
or info@fidelisgroup.com.au or contact us by phone on 0410 657 780.

Please mark communications to the attention of the Chief Executive Officer. We will respond, generally within 30 days, to let you know who will be handling your matter and when you can expect a further response.

If your concerns are not resolved to your satisfaction, or if you don’t hear from us within 30 days, you may contact us to discuss your concerns or you can refer your complaint to the Office of the Australian Information Commissioner (OAIC).

A copy of our Privacy Policy (this document) is available from us free of charge as follows:

  • you can download it from our website

  • you can request a copy be emailed to you by emailing your request to

    info@fidelisgroup.com.au

  • you can phone us on 0410 657 780 and request a copy be emailed or mailed to

    you

  • you can write to us and request a copy by mailed or emailed to you.

    Policy updated: March 2019

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