Privacy

This is the Privacy Policy of all subsidiary companies of Altair Assets Ltd as well as all related bodies corporate, collectively known as ‘Altair’. In this Privacy Policy, ‘Altair’, ‘we’, ‘our’ and ‘us’ mean any or all members of the Altair group of companies as the context requires.

If you want more information about this Privacy Policy, or if you want to inquire about any of your personal information, or if you believe your personal information is inaccurate, incomplete or out-of-date, contact us.

If you give us personal information about another person, you represent that you are authorised to do so and agree to inform that person who we are, that we will use and disclose that information for the relevant purposes set out below, and that they can access the information we hold about them.

We understand that privacy is important to you. Your personal information will be treated strictly in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) as amended from time to time.

We reserve the right to update this policy from time to time without notice.

Should you wish to obtain further information about privacy you can do so by visiting the Office of the Australian Information Commissioner at www.oaic.gov.au

Altair Privacy Policy

This Privacy Statement sets out the policy of Altair for management of personal information. We are committed to ensuring the privacy of your information and recognise that you, as a customer, are concerned about your privacy and about the confidentiality and security of information that Altair may hold about you.

This Policy is designed to inform customers of –

The Altair Privacy Policy;
What information we collect and the purposes for which we collect it;
Use and disclosure of information collected;
Security of your personal information;
Gaining access to information we hold about you;
What to do if you believe the information we hold about you is inaccurate;
Complaints in relation to privacy; and
How to contact us.

Personal Information

Personal information is information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. We must obtain personal information about you so we can provide the most appropriate products and services to you, provide information and marketing material to you and satisfy certain legislative and regulatory requirements.

Altair will also collect any personal information necessary for the purposes of complying with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

The information we collect from you will depend on what services we provide to you and may include the following:

your name, address and contact details;
your e-mail address;
your tax file number;
Bank account details;
Identification and verification information; and
details of specific transactions.

If you do not give us your personal information, we may not be able to provide products and services as requested by you.

Open and transparent management of personal information

Altair seeks to ensure that personal information we hold about an individual is managed in an open and transparent manner. We have implemented procedures to ensure compliance with the Australian Privacy Principles and any applicable codes, and to deal with any complaints relating to our compliance therewith.

Altair has a clear and up-to-date privacy policy outlining our management of personal information, including details regarding the kind of personal information we collect and hold; how and why we collect and hold this information, and how an individual may access and seek correction of the information we hold about them. We further provide details regarding our complaints handling process, our policy on disclosure of information to overseas recipients (and if so, which countries).

Collection of personal information

This policy details how Altair adheres to the Australian Privacy Principles regarding the collection of solicited personal information.

Altair only collects personal information directly from individuals, which is reasonably necessary for the provision of our services, and only by lawful and fair means. Information is generally sought through our application forms, in which the purpose is articulated. Accordingly, we will always ensure you are apprised of our purpose in collecting information, and your right to gain access to such information. If you do not provide the information requested, we may be unable to provide you with our services.

Please note that generally we will only use the personal information (e.g. postal address, e-mail address, telephone numbers, facsimile number, date of birth, bank account details, TFN, details related to the provision of verification and identification documentation) we collect for the main purposes disclosed at the time of collection such as to provide financial services.

The main ways we may collect personal information about you are:

(a) if you subscribe to any of our information or other services;

(b) if you open any form of an account with us;

(d) if you give information or other material to any member of the Altair; or

(e) if the information is provided to us by a third party.

Altair maintains records of transactions and activities on accounts you may have with various entities within Altair. During the course of your relationship with Altair, we will also gather information about products and services provided to you.

Where possible we will collect the information directly from you via our application form. We may also collect information about you from our web site but this information will only identify who you are if you provide us with your details (eg. if you e-mail your contact details to us). When you visit our web site our web server collects the following types of information for statistical purposes:

your Internet service provider's address;
the number of users who visit the web site;
the date and time of each visit;
the pages accessed and the documents downloaded;
the type of browser used.

No attempt is made to identify individual users from this information.

The Altair web site contains links to the web sites of third parties. If you access those third party web sites they may collect information about you. Altair does not collect information about you from the third parties. You will need to contact them to ascertain their privacy standards.

A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes. We may use cookies and other technologies to grant you access to certain parts of the website and to monitor traffic patterns, manage advertising and other activities.

Cookies may also be used for other purposes on the Altair website but in each case none of the information collected can be used to identify you personally but rather identifies your computer. You can configure your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it each time.

If you disable the use of cookies on your web browser or remove or reject specific cookies from the website or linked sites then you may not be able to gain access to all of the content and facilities in this website.

Altair’s website may contain references or links to other external websites. Those references or links may in turn refer or link to other references or links. Altair, its directors, officers, employees or agents are not responsible for any privacy policies or practices or content of websites to which we provide external links.

E-mail address

If you provide us with your e-mail address during a visit to our web site it will only be used for the purpose for which you provided it to us. It will not be added to a mailing list without your consent unless the mailing list is related to the purpose for which you provided your e-mail address to us. We may use your e-mail address, for example, to provide you with information about a particular service or respond to a message you have sent to us.

If you subscribe to one of our services and provide your e-mail address to us so that we may communicate with you through e-mail, we may also use your e-mail address to advise you of upgrades and changes to those services.

Unsolicited personal information

Where we receive personal information about an individual which is unsolicited by us and not required for the provision of our services, we will destroy the information (provided it is lawful and reasonable for us to do so).

Notification of the collection of personal information

When we obtain personal information about you, we ensure that you have our contact details and that you are aware of the collection of information and our purposes for doing so. As per above, we are unable to provide certain services if the requested information is not provided. We do not disclose your information to third parties, unless they are related entities or services providers, in which case they are required to conform to our procedures.

Use and disclosure of personal information

Altair collects and holds personal information about an individual for the purpose of providing financial services. We collect this information with your consent as per our application form or other documentation, for the primary purpose disclosed to you at the time of collection.

However, in some cases Altair will use or disclose personal information for secondary purposes (any purpose other than a primary purpose). Personal information obtained to provide financial services may be applied to secondary purposes if the secondary purpose is related to the primary purpose of collection and the person concerned would reasonably expect the personal information to be used or disclosed for such secondary purpose.

In some cases we may ask you to consent to any collection, use or disclosure of your personal information. Your consent will usually be required in writing but we may accept verbal consent in certain circumstances. We may also disclose your personal information where it is required or authorised by law.

We may use your personal information to:

process your investment application;
respond to any specific requests you may make of us;
notify you of any products that may be of interest to you;
audit and monitor the services we provide to you;
update your personal files; and
enable us to meet our obligations under law, for example, the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth.), Financial Transaction Reports Act 1988 (Cth.) and Australian taxation laws.

We may disclose your personal information to:

agents, contractors, or external service providers appointed by Altair (such as Custodian, Auditors or other professional advisers)
a client's nominated financial adviser
a client's personal representative, attorney or agent (only with a client’s written consent)
a government or regulatory body (such as ATO, AUSTRAC, ASIC or a law enforcement agency)
financial institutions and other similar organisations that it deals with in the course of its corporate activities, or those that are nominated by you
external service providers and professional advisers (which may be located overseas) that provide services to us
credit reporting agency, any credit provider named in the report and any credit provider whose details have been provided to us by you
in order to comply with a Court order
where the disclosure is required by law, for example to government agencies and regulatory bodies as part of our statutory obligations, or for law enforcement purposes.

Depending on how your information came to us; we may disclose personal information to service providers who provide services in connection with our products and services or we may provide information about you to your nominated financial advisor with your permission.

We will use our best endeavours to ensure that each of our authorised representatives and the businesses that we deal with adhere to the Privacy Legislation. Contact us, if you have any concerns about this. We do not sell personal information to other organisations.

Direct Marketing

Altair will only use personal information obtained for the provision of financial services, or for the secondary purpose of direct marketing where:

Altair collected the personal information from the individual; and
The individual would reasonably expect Altair to use or disclose the information for the purpose of direct marketing; and
Altair provides a simple means through which an individual can request to not receive marketing communications; and
The individual has NOT requested such communications cease.

Often the law requires us to advise you of certain changes to products/ services or regulations. You will continue to receive this information from us even if you choose not to receive direct marketing information from us. We will not disclose your information to any outside parties for the purpose of allowing them to directly market to you.

Cross border disclosure/Sensitive information/Use of government identifiers/Anonymity & Psuedonymity

Altair may provide your information to third party service providers in Canada and the United States of America. Altair does not, for the purposes of the Privacy Act, collect sensitive information. Wherever lawful and practicable, individuals may deal anonymously with Altair but given the nature of our services, it is unlikely that this will be a viable option. Altair does not use official identifiers (e.g. tax file numbers) to identify individuals. An individual’s name or Australian Business Number is not an identifier for the purposes of the Privacy Act and hence may be used to identify individuals.

Quality of personal information

Altair takes all reasonable steps to ensure the personal information held about individuals is accurate, up-to-date and complete. We verify personal information at the point of collection. The accuracy of records is also maintained by regular mail-out of statements.

Altair encourage you to help us by telling us immediately if you change your contact details (such as your phone number, street address or email address) or if any of your details need to be corrected or updated. A person wishing to update their personal information may contact our staff or the Privacy Officer on the contact details shown within this document.

Access to personal information

Where a person requests access to their personal information, our policy is, subject to certain conditions (as outlined below) to permit access. Altair will correct personal information where that information is found to be inaccurate, incomplete or out of date. We will not charge you a fee for your access request but may charge you the reasonable cost of processing your request.

If a person wishes to access their personal information or correct it, they should contact the Altair Privacy Officer and provide identifying information, and we will seek to provide such information within a reasonable period of time, and in the manner so requested (where reasonable to do so).

Altair may not always be able to give you access to all the personal information we hold about you. If this is the case, we will provide a written explanation of the reasons for our refusal, together with details of our complaints process for if you wish to challenge the decision.

We may not be able to give you access to information in the following circumstances:

Where we reasonably believe this may pose a serious threat to the life, health of safety of any individual or to public health/safety;
Which would unreasonably impact the privacy of another individual;
Where such request is reasonably considered to be frivolous or vexatious;
Which relates to existing or anticipated legal proceedings which would otherwise not be accessible in the discovery process relating to such proceedings;
Which would reveal our intentions and thereby prejudice our negotiations with you;
Which would be unlawful;
Which is prohibited by law or a court/tribunal order;
Which relates to suspected unlawful activity or serious misconduct, where access would likely prejudice the taking of appropriate action in relation thereto;
Where enforcement activities conducted by or on behalf of an enforcement body may be prejudiced; or
Where access would reveal details regarding a commercially sensitive decision-making process.

Correction of personal information

Where Altair believes information we hold about an individual is inaccurate, out-of-date, incomplete, irrelevant or misleading, OR an individual requests us to correct information held about them, Altair will take all reasonable steps to correct such information in a reasonable time frame. No fees are payable for such requests. If you request us to similarly advise a relevant third party of such correction, we will facilitate that notification unless impracticable or unlawful for us to do so.

If Altair intends to refuse to comply with your correction request, we will notify you in writing of our reasons for such refusal, and the complaints process you may avail if you wish to challenge that decision. You may also request that we associate the personal information we hold with a statement regarding your view of its inaccuracy.

Security of personal information

We take reasonable steps and precautions to keep personal information secure from loss, misuse, and interference, and from unauthorised access, modification or disclosure. However, Altair, its directors, officers, employees or agents do not guarantee the security of your personal information.

If you use the Internet to communicate with us, you should be aware that there are inherent risks in transmitting information over the Internet. Altair does not have control over information while in transit over the Internet and we cannot guarantee its security.

Where information is no longer required to be held or retained by Altair for any purpose or legal obligation, we will take all reasonable steps to destroy or de-identify the information accordingly.

Privacy Complaints

If you have a complaint relating to our compliance with privacy laws or our treatment of your personal information, please contact our Privacy Officer on 1300 438 318 or by mail to Altair Assets Ltd, GPO Box 135 Sydney NSW 2001. We will investigate your complaint and endeavour to resolve the issue to your satisfaction. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with the Office of the Australian Information Commissioner by telephoning 1300 363 992 or visiting their website at www.oaic.gov.au