Privacy policy.
CF Capital Investments Pty Ltd (‘CF Capital’, ‘we’, ‘us’, or ‘our’) recognizes the importance of safeguarding your privacy and are committed to complying with the Australian Privacy Principles which set the standard for how organizations should deal with personal information. The Australian Privacy Principles (the APPs) are found in amendments to the Privacy Act 1988 which are effective from 12 March 2014.
We trust that this Privacy Policy will help you to understand how CF Capital collects, uses, discloses and manages your personal information.
You also have the option of not identifying yourself to CF Capital or you may use a pseudonym. We can provide you with general information on CF Capital and its products in these instances. You will be required to identify yourself where required by law or it is impractical not to do so. Examples include applying for or making a change to an investment, requesting personal information or lodging a complaint.
What information do we collect?
The type of information collected by us will depend upon your relationship with CF Capital and may include:
Nname and title
Address
Contact details
Detail on entities through which you invest
Date of birth
Bank account details
Detail on your nominated beneficiaries
Security holding or plan participation details and balances
Taxation Identification Number e.g. Tax File Number
How we collect your information
In most cases, and wherever possible, CF Capital will try to collect personal information only from you. Information will be collected through various company forms and from you directly, either in writing or verbally. We may also collect information about you from third parties, including:
Financial advisers
Outsourced registry providers
Securities Exchanges
Credit reporting bodies
Public websites
Contractors
Tenants
Other third parties you have authorised
How your information is held
Your personal information is held in our registry systems for our investors and shareholders. These are either 3rd party specialist registry service providers or through an in-house registry system.
Personal information is stored in secure electronic databases and, where applicable, on paper documents. Any information on paper documents is stored in secure, offsite storage facilities for a period of time determined by law or client’s instructions. The databases and offsite storage facilities are both located within Australia. CF Capital takes reasonable steps to ensure that the personal information that we hold is secured against such risks as loss or unauthorised access, destruction, use, modification or disclosure.
Generally, we do not combine or link other personal information held about you. The exception is when you notify us in an investment application that you have previously invested with us. In these situations, we will add the new investment to the existing client profile so that all investments are linked to under one client profile.
All internal systems are subject to the security measures detailed in this policy. All external service providers are contractually required to hold personal information in accordance with the Privacy Act.
How do we use your Personal Information?
Personal information is collected and used to provide additional services related to the initial purpose for which your personal information was collected. The services for which we require personal information include the following:
To provide you with the products and services you request
To provide you with the information you request
To verify your identity before transactions are processed, your instructions are carried out, or providing you with information about your investment
To administer your financial product or loan
Maintaining security registers, which issuers of securities are obliged to maintain under the Corporations Act 2001 (Cth) (“Corporations Act”)
Providing services related to registry and employee equity plan administration, including dividend and distribution payments and corporate communications
To provide you with information about other products or services offered by CF Capital or its related entities
To respond to your enquiries or complaints
To prepare internal reporting that includes identifiable customer information (e.g. customer sales or marketing information, complaints or issues reporting, registry operations reporting) to satisfy any legal requirements.
Facilitating compliance with legal and regulatory requirements
Cookies and log files
We use cookies and log files on our web portals to enhance their functionality. A cookie is a small text file that our websites may placed on your computer to collect information such as your internet protocol address, your computer’s operating system and the browser you are using. We use this information to monitor service usage and to optimise the delivery of our services to you. You may adjust your internet browser to disable cookies or to inform you when one is being used. If you choose to disable cookies, you may be unable to access certain areas of our website.
External Websites
Sometimes our website contains links to external websites for convenience and information. These websites are not managed by CF Capital and we cannot be responsible for their privacy practices.
Anti-Money Laundering and Counter Terrorism Legislation
The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) is aimed at addressing money laundering in Australia and the threat to national security caused by terrorism. This legislation requires us to collect identification information from investors into our investment products and reverse mortgage borrowers and to verify your identify from original or certified copies of specified documents or perform electronic verification. Details of what identification information and documentation you are required to provide are set out in transactional based forms. We may also contact you to follow up and clarify certain information.
Under this legislation we are also required to monitor transactions to identify any suspicious activity within any of our investment products.
As required under the AML/ CTF Act, we may, in our absolute discretion, without notice to you, disclose or otherwise report details of any transaction or activity, or proposed transaction or activity (including any personal information) to the relevant reporting body.
Disclosure of Personal Information
Personal information held by CF Capital may be disclosed to third parties such as:
Outsourced service providers, including administration, custodial and registry service providers; printers and mailing houses, information technology systems
Software providers, actuaries, professional advisers and research organisations
Business partners, including insurance underwriters
Government agencies including APRA, ASIC, AUSTRAC, Centrelink, Office of the Australian Information Commissioner (OAIC) or the ATO
Related companies
Credit reporting bodies, where a person is in default in relation to loan or other credit arrangements;
Financial intermediaries such as financial planners and taxation or accounting advisers
The issuer of the securities you hold
Other third parties you have authorised to receive your personal information.
Where CF Capital contracts with an outsourced service provider or business partner we take reasonable steps to protect the privacy of any information disclosed to them. This includes inserting confidentiality provisions and a requirement to comply with the Privacy Act in our contractual arrangements.
We may be required or authorised by law to disclose information to law enforcement agencies, government agencies, and courts. This may happen for a number of reasons, including to prevent or investigate an actual or suspected crime or fraud.
Disclosure to entities in other countries
CF Capital’s registry and administration service provider for its friendly society business may perform or engage parties who are located overseas to perform certain services overseas including back-office and anti-money laundering counter-terrorism financing screening services. As a result, personal information collected by CF Capital may be disclosed to a recipient in a foreign country. The countries in which such overseas recipients are likely to be located are the United Kingdom, New Zealand, the United States of America, Canada, Singapore, The Netherlands and India.
CF Capital’s registry and administrative service provider is contractually required to takes reasonable steps to ensure the overseas recipients comply with the APPs. This is achieved by implementing contractual arrangements with overseas service providers to ensure the personal information is appropriately safeguarded and to ensure that these overseas service providers comply with the APPs.
Declining Product or Service Offers (Opting-out)
From time to time CF Capital may wish to use your information to tell you about other products, services or special offers that we think may be of interest to you. Please let us know if you do not want to receive these offers by contacting us using the contact details noted below or selecting the unsubscribe option in an email.
Quality of Information
CF Capital aims to ensure that the personal information we retain about you is accurate, complete and up to date. Please provide us with complete and accurate information and keep us informed of any changes in your details such as a change of address.
If you do not provide all or part of the personal information that we request, we may not be able to contact you or to administer your investment properly.
If you believe that the information we hold about you is inaccurate please contact us directly using the contact details provide below, so that we can update our records.
Security of Information
CF Capital will at all times take steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. Your personal information is treated as confidential.
Employees and contractors of CF Capital are bound by confidentiality obligations. Passwords, firewalls and virus protection are used by CF Capital with a view to ensure the security and integrity of the information technology systems that hold your information.
All premises housing our systems and other copies of your information are monitored and protected by security alarms and access card or key lock entry. Service providers who hold personal information are contractually required to hold information in accordance with the Privacy Act and CF Capital obtains periodic confirmation of adequate information security management.
DATA Breaches Notification
We will promptly notify you if we are aware of or have reasonable grounds to believe that your Personal Information held by us is involved in an eligible notifiable data breach and involves Personal Information being lost or subjected to unauthorised access or unauthorised disclosure which is likely to result in serious harm. Our notification to you will include recommendations about the steps you should take in response to the breach and will not be anytime longer than 30 days from when the determination has been made by our management that the breach may cause serious harm. We will also notify the OAIC of the data breach.
Our assessment and escalation of such breaches will be in done in accordance with our Incident & Breach Reporting policy and procedures.
Your Rights of Access and Correction
You are entitled to obtain access to your personal information subject to some exceptions allowed by law. You may also request that CF Capital correct or update information that we hold on you. We encourage our customers to ensure that their personal information is accurate and up to date, particularly mailing address and contact details. We include regular reminders in correspondence with our customers.
If you wish to make a request for access to your personal information, please contact our Responsible Entity using the contact details below.
Contact Details
Phone 1800-343-896
Email privacy@kam.limited
Website www.kam.limited
Mail Level 3, 424 St Kilda Rd, Melbourne, VIC 3004
Complaints
If you wish to make a complaint about a possible breach of privacy or how we have handled your personal information, please contact our Responsible entity on 1800 343 896 during business hours or address your complaint to the Complaints Manager, Keystone Asset Management Limited, Level 3, 424 St Kilda Road, Melbourne VIC 3004, or email complaints@kam.limited.
We will acknowledge your complaint within one (1) business day of being received. If we can promptly address your complaint within thirty (30) days we will provide details of the methodology used to investigate and resolve your complaint, along with our decision regarding your complaint. If we are not able to resolve your complaint within thirty (30) days of receiving it we will, before the expiry of thirty (30) days, provide you with written confirmation of the investigation(s) we have undertaken as well as details of when we anticipate to be in a position to arrive at a decision regarding the circumstances associated with your complaint.
If you are not satisfied with our response, you may also be able to lodge a complaint with the OAIC.