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Armada Funds Management Pty Limited and other companies within the Armada Group (together referred to as "Armada" in this policy) are committed to protecting your privacy and any personal information we collect. This policy applies to all services provided and funds operated under the AFSL for Mendoza Limited (AFSL 33 57 83). Armada complies with the Australian Privacy Principles contained in the
Privacy Act 1988
Privacy Amendment (Enhancing Privacy Protection) Act 2012
. This policy explains how we may collect, use and otherwise handle personal and sensitive information.
The kinds of information we collect about you
As a funds management organisation we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information about you ("personal information").
Personal information collected includes the following:
- name, gender and date of birth to verify your identification;
- information we require to verify the identity of investment entities that you operate or control;
- 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 collected by us as required by the law;
- employment information in relation to investments made via a superannuation fund;
- information with regards to responding to technical difficulties with accessing our web site, and responses to our surveys.
We will not collect personal information unless the information is reasonably necessary for, or directly related to, Armada’s activities.
Sensitive information (including racial or ethnic origin, political opinion, religious or philosophical belief, professional or trade union membership, sexual preference or criminal record) will not be collected without your consent, and only where required by law. Sensitive information, if collected, will not be used or disclosed for a secondary purpose, including direct marketing.
You have the right not to provide personal information, including identification, however failure to provide the personal information referred to above may mean that we cannot provide the services that you have requested.
If you elect not to provide us with the personal information referred to above, we may elect to withdraw our services if we believe we are unable to provide you with a complete service, including compliance with legislative and regulatory requirements.
How we collect information about you
Generally, collection of your personal information will be from our Product Disclosure Statement or Information Memorandum application forms or other forms, by telephone, facsimile, email and from this website. From time to time additional and / or updated personal information may be collected through one or more of these methods.
If we obtain personal information about you from sources other than yourself without your consent, then within a reasonable time before or after the information is obtained, we will take reasonable steps to notify you of that fact.
The purposes for which we collect information
We will only collect, maintain and use personal information about you if it is necessary for us to adequately provide to you the services you have requested including:
- to make and maintain your investment in our funds;
- to make payments to you;
- to contact you with regards to reporting of funds information such as distribution statements and performance;
- to comply with certain legislative and regulatory requirements including provision of tax file numbers to facilitate the effective administration of taxation law and to ensure compliance with the
Anti-Money Laundering and Counter-Terrorism Financing Act 2006
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;
- providing you with information about other services and products we offer (unless you tell us you don't want this information).
Use and disclosure of personal information
Personal information will only be used for the primary purpose for which it was collected (as described above under the heading “The purposes for which we collect information”) or for the purpose of direct marketing of Armada’s products and services (unless you tell us you don’t want this information).
We will not use or disclose that information for any other purpose (including provision to any marketing companies or information brokers) without your consent unless we are required to do so by law or in circumstances where you would reasonably expect such use or disclosure.
We are obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by 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 within the Armada 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 services provided by us.
It is unlikely that your personal information will be disclosed to overseas recipients. Armada’s principal business activity is the investment of funds in wholesale and retail trusts domiciled in Australia who invest in Australian real property.
We may use the personal information collected from you for the purpose of providing you with direct marketing material, however you may, by contacting us by any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow two weeks for your request to be actioned.
We may disclose your personal information to external contractors for the following purposes:
- storing information on managed scheme registers;
- audit of scheme registers; and
- compliance plan review.
Quality of personal information
We will endeavour to ensure that, at all times, the personal information about you which we hold is up to date and accurate.
In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate, incomplete or out-dated, you may contact us by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness or of any out-dated information and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.
Access to your personal information
You may at any time, by contacting us by any of the methods detailed below, request access to your personal information and we will (subject to the following exceptions) provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.
We will not provide you access to personal information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result. We will not provide you with access to your personal information if:
- providing access would pose a serious threat to the life or health of a person;
- providing access would have an unreasonable impact on the privacy of others;
- the request for access is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings between us, and would not be discoverable in those proceedings;
- providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
- providing access would be unlawful;
- denying access is required, or authorised by or under law;
- providing access would be likely to prejudice certain operations by, or on behalf of an enforcement body, or an enforcement body requests that access not be provided on the grounds of national security.
We will endeavour to respond to any request for access within 14 to 30 days depending on the complexity of the information and/ or the request. If your request is urgent please indicate this clearly. In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal.
Storage and security of personal information
Your personal information is generally held on a computer based registry system.
We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential. All record movements off premises are recorded in a central register. After-hours access to our premises is controlled by allowing only personnel with security passes to access the premises. All computer- based information is protected through the use of access passwords on each computer and encryption of storage devices.
In the event you cease to be a client of this organisation, any personal information which we hold about you will be destroyed after an appropriate period of time that complies with legislative and professional requirements (usually 7- 10 years).
Australian Privacy Principles
While it is not necessary to register your personal details to use our website, we may in future offer a registration service, which will enable you to receive product and service updates, newsletters and other information. In the event you do register with us, we will collect personal information from you including your name and email address.
If you have registered with us and decide, at any time, that you do not wish to receive any further information from us, you can send an email to the email address noted below requesting to be removed from our online registration database. Please allow two weeks for your request to be actioned.
You may amend or update your registration details by sending an email to the email address noted below providing your amended details. Please allow two weeks for your request to be actioned.
How to lodge a complaint
Additional privacy information
Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner at
Availability of this policy
This policy is available for review on our website or by contacting us by any of the methods detailed below.
Armada Funds Management Pty Ltd (ACN 124 754 847)
Suite 6, Level 8
66 Hunter Street
Sydney NSW 2000
Telephone: (02) 8070 8300
Facsimile: (02) 8070 8370
Australian Financial Services Licence No: 33 57 83
ACN 135 855 186
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