1. About this Policy
Warakirri Asset Management Ltd (Warakirri) recognise that privacy is important to you.
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
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 Where Warakirri has reason to believe that the Personal Information held is inaccurate, out of date or incomplete, it will take reasonable steps to correct that information having regard to the purpose for which the information is held.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:
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:
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:
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:
C/- Compliance & Risk Manager
Level 17, 140 William St
Telephone 03 8613 1111
Additional information about privacy in Australian is available by visiting the Office of the Australian Information Commissioner at www.oaic.gov.au.