PRIVACY POLICY

Privacy Policy Background
We respect your rights to privacy of the personal details supplied to us through application forms associated with our issued Product Disclosure Statements or such other disclosure document or via this Website.

The Privacy Act 1988, the Privacy Amendment (Private Sector) Act 2000, the National Privacy Principles and other laws include provisions that regulate the way private sector organizations, collect, use, disclose, keep secure and provide access to personal information. We are bound to protect your personal information in accordance with the law and the National Privacy Principles.

Why we collect personal information
We collect personal information:

to make and maintain your investments in our funds,
to contact investors with regards to reporting of fund information such as distribution statements and performance, and
to fulfil requirements of the law such as Tax File Numbers.

We may also use personal information for other reasons such as:

monitoring and evaluating products and services,
gathering, aggregating and analysing for statistical, actuarial, prudential or research purposes,
helping to improve internal policies and procedures, and
provide you information about other services and products we offer.

What personal information we collect:

We collect information about you from our Product Disclosure Document application forms or other forms, phone, fax, email and from this web site.

Personal information collected includes the following:

name, gender and date of birth to verify your identification,
contact details such as phone number and address to mail advices,
bank account details for direct crediting of distributions and redemptions,
investment information about your holding in our products,
tax file numbers to ensure that tax is levied by us as required by the law,
employment information in relation to investments made via a superannuation fund,
login details for this website,
information with regards to responding to technical difficulties with accessing this web site, and
responses to our surveys.

Consent to give us information
We will not collect any other information about you, unless you are aware that the information is being collected by us, or unless you have authorised a third party to provide it to us on your behalf.

Disclosure of personal information
We will not disclose personal information collected by us for any purpose other than where you have:

consented to the disclosure, or
where the National Privacy Principles authorise use or disclosure where required or authorised by law, in circumstances relating to public health and safety, social security and taxation in connection with certain operations by or on behalf of an enforcement body.

In relation to our role as a financial service provider we are required pursuant to the Corporations Act to maintain certain transaction records with regards to your investment in our products and make those records available for inspection to the Australian Securities and Investments Commission.

If you use a financial adviser who recommended your investment in our products (as indicated on an application form or letter authorised by you) then personal details held by us may be made available to the adviser.

We may disclose personal information to companies with the Headland group, superannuation fund trustees, insurance brokers, insurance companies, fund managers, custodians, fund administrators, mailing houses and auditors for the purpose of giving effect to the service provided by us.

Personal information security
We are committed to ensuring that personal information collected and held by us is kept secure and protected from misuse, loss, unauthorised access, modification or disclosure.

We have a number of physical access and technology policies and procedures in place to provide a robust security environment. We ensure the ongoing adequacy of these policies by regularly reviewing them. All information stored on electronic medium is protected from use by access passwords.

Online services
Collection of information via the HEADLAND Web site
The internet is not a secure environment and although all reasonable steps are taken to protect your security, we cannot guarantee the security of information you provide to us via our web site.

We may use “cookies” to obtained information with regards to web site activity such as the type of browser used, the number of pages viewed and navigation patterns. This information on its own does not identify an individual but it does provide us with statistics that can help us with design of the web site. You can configure your browser to accept or reject cookies. If you reject all cookies you may not be able to use our web site.

While we may collect personal information from our web site no personal data is stored on our web site.

Links to other web sites
This web site may contain links to other web sites for your convenience. We are not responsible for the information handling and privacy policies and practices of other linked web sites.

Telephone services
We may monitor or record telephone calls for training and security purposes. If we do so, we will tell you at the time.

Jointly held information
Where we hold your personal information in conjunction with another individual(s) in the case of joint accounts we will allow each individual access to account balances and transaction details, but not to the personal details of the other individual

Changes to handling and privacy practices
We may make changes to information handling and privacy policies and practices and this Privacy Policy Statement. We will publish important changes on our web site and if necessary update this Privacy Policy Statement.

Access to personal information
In most circumstances, you have the right to access any personal information we collect and hold about you and to have it corrected if it is wrong.

Please contact our Privacy Officer at the address below if you wish to access or update your personal information, or if you have a complaint about how we have handled your details. If your investment into our products is through an IDPS, wrap, master trust or such other portfolio administration system, please contact the provider directly with your query.

Privacy Officer
Headland Global Investment Management Pty Limited
Level 4
99 Queen Street
Melbourne VIC 3000

Tel: 03 8616 8209
Email: privacyofficer@headlandglobal.com.au