Privacy Policy

1. About this Policy
Warakirri Asset Management Ltd (Warakirri) recognise that privacy is important to you.

This Privacy Policy has been developed by Warakirri as it values and respects its relationships with investors, shareholders and other individuals with whom it deals (collectively ‘Stakeholders’). Warakirri respects its Stakeholders’ desire for privacy and therefore, the aim of this Policy is to provide you with information on the collection, use, disclosure and storage of your personal information by Warakirri.

Warakirri abides by the Privacy Act 1988 (Cth)  (Privacy Act) in the manner required by the Australian Privacy Principles (APPs). All officers and employees of Warakirri are bound to perform their duties in accordance with this Privacy Policy which conforms to the Privacy Act.

2. Types of personal information collected
Warakirri may collect and retain information that identifies an individual, or from which an individual’s identity can be identified, from its Stakeholders (each ‘Personal Information’) including

  • Your name, date of birth, residential or business addresses, telephone number, email address, financial product holdings and dealings, bank accounts, tax and other identifiers required for investment in financial products issued by Warakirri; and
  • Other information required under the Australian Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AMLCTF), Foreign Accounts Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) regime; and
  • General information about the different types of investment products and services as collected through the ordinary course of business development and maintenance of relationships.

Warakirri will use best endeavours to collect the required Personal Information directly from its Stakeholders unless it is unreasonable and impracticable to do so. Warakirri will take reasonable steps to ensure that the Personal Information it uses or discloses is accurate, up to date and relevant. Where Warakirri has reason to believe that the Personal Information held is inaccurate, out of date or incomplete, it will take reasonable steps to correct that information having regard to the purpose for which the information is held.

3. How we may collect personal information
Warakirri may collect Personal Information in the ordinary course of its business activities, when:

  • you submit and applications, including information required by the Corporations Act 2001 (Cth) and other legislative or regulatory requirements, held on unit registers maintained by external registry provider;
  • responding to your enquiries either through direct email, letters or telephone conversations; and
  • dealing or communicating with your authorised financial adviser.

Warakirri may also collect information about you through publicly maintained records or from an information service provider where it is not reasonable or practical to collect the information directly from you.

4. Use and disclosure of personal information
Warakirri does not sell any personal information to any person or entity.

Warakirri only uses Personal Information for its internal business needs which may include:

  • facilitating Warakirri’s business operations;
  • administering and processing requests or applications that you submit, to communicate with you regarding your request;
  • marketing and promotional activities including providing you with information about your investment and other Warakirri products that may be of interest to you but will cease to provide you with marketing material where a request to do so has been made;
  • to make payments of your distribution to your nominated bank account and other administrative purposes;
  • to comply with legal and regulatory obligations including tax reporting and AMLCTF requirements and advising the Australian Taxation Office, Australian Transaction Reports and Analysis Centre (AUSTRAC) or other authorities of information which may be required by law.

Warakirri generally only discloses Personal Information as required by law and, it may disclose Personal Information to non-affiliated parties such as its custodian, fund administrator and or unit registry provider that may directly communicate with you regarding your investment and provide you with investment reports as part of the agreed services with Warakirri. Warakirri has entered into agreements with each external service provider and under the terms of appointment strict compliance with the Privacy Act is required.

Your Personal Information may also be disclosed to:

  • Persons acting as your authorised agent or representative (i.e. authorised professional or financial advisor);
  • Warakirri’s professional advisers including legal, auditors and consultants
  • Any person with a valid and legal reason to inspect or obtain a copy of a register of unitholders of a fund registered by ASIC
  • Regulators in order to satisfy Warakirri’s legal regulatory obligations;
  • As otherwise required or permitted by law.

Warakirri does not disclose Personal Information to other persons offshore unless appropriate privacy protection is in place (e.g. its portfolio management bureau system) or with the concurrence of the individual concerned (e.g. names, roles and contact details of Warakirri representatives).

5. Security of Personal Information
Warakirri will ensure that Personal Information is kept in a secure manner free from unauthorised access, modification or disclosure. Personal Information retained in electronic format is subject to system security measures (i.e. complex password protection and authorised access levels) in accordance with the internal Information Technology Policy. Any hard copy of Personal Information is retained in secure filing cabinets.

Where Warakirri no longer requires, or is no longer required to hold Personal Information, it will take reasonable steps to securely destroy the information or ensure that the information is de-identified.

6. Accessing or correcting your personal information
You may request to access your personal information. There are certain restrictions to accessing your information as outlined in the APPs and Warakirri will inform you whether it agrees to provide you with access within 20 business days of the receipt of your request.

Before access is granted, you will be required to provide evidence of your identity.

Warakirri seeks to ensure that the personal information held is accurate, complete and up to date. You can update your personal information at any time by using the various forms provided on the website.

7. Complaints Handling
Any complaint in relation to privacy or in relation to the Personal Information held, should be directed to Warakirri’s Privacy Officer.

Complaints may be in either written or verbal form and will be dealt with consistent with its Complaints Handling Policy. Warakirri will endeavour to acknowledge your complaint immediately and respond within a reasonable time but not later 20 business days.

Where an actual or suspected loss, unauthorised access or modification of personal information occurs, Warakirri will promptly take action and assess the matter in accordance with the requirements of the Privacy Act.

For further information please contact Warakirri’s Privacy Officer:

Privacy Officer
C/- Compliance & Risk Manager

Level 17, 140 William St
Melbourne 3000

Telephone 03 8613 1111
Email: compliance@warakirri.com.au

Additional information about privacy in Australian is available by visiting the Office of the Australian Information Commissioner at www.oaic.gov.au.