In accordance with the Privacy Act 1988 (Cth) (“Privacy Act”), this policy (“Policy”) details how Salter Brothers Emerging Companies Limited collects personal information and how we maintain, store, use and disclose the information.
It will also provide details about your privacy rights with Salter Brothers Emerging Companies Limited’s general rights and obligations and the steps we take to protect the information in accordance with the Privacy Act and the Australian Privacy Principles (“APPs”).
Salter Brothers Funds Management Pty Ltd and other entities of Salter Brothers (collectively, “Salter Brothers”, “we”, “our” or “us”).
The information we collect
Salter Brothers collects information that is necessary for the management of your account(s) and/or investments held with us (or managed by us) and for administrative processes in relation to us delivering financial services (or funds management services) to you.
Such information includes:
- Full name, date of birth, gender, and contact details, including residential and mailing addresses, email address;
- Information about identity, place of birth, residency, citizenship, and identification documentation for the purpose of verifying identity and to comply with regulatory requirements regarding identification verification, tax status, tax reporting, and withholding;
- Tax file or identification number and bank account and payment method details, if such information is needed for the purpose of administering your accounts;
- Employment details, which may include annual salary;
- Business details, which may include business’ contact and financial information.
- Contribution amounts and investment choices;
- Photographs we take of you with your permission and physical or digital signatures.
- Details about authorised signatories, agents, or representatives (including deceased estates);
- Copies of any relevant trust deeds, partnership agreements, constitutions, or articles of association;
- Details of services you are interested in and your investment needs;
- Information about employees, agents, or other representatives of a client or prospective client, if such information is needed to open or maintain an account;
- Detailed contact information about your financial, legal and taxation adviser(s); and
- Other information that you provide to us in connection with your account.
We may also collect information:
- regarding other individuals related to your account. By disclosing information about authorised signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as outlined above, you warrant that you have the consent of those parties to such collection, use, and disclosure of their information as described in this Policy.
- about you from public websites or social media where you have communicated in relation to Salter Brothers or our products or services.
Salter Brothers collects and holds this personal information for the purpose of delivering our products and services to you, managing and administering the products and services and keeping you updated on product and service developments, including associated and newly introduced products and services.
How information is collected
The information we collect is primarily derived from account application forms, product application forms, supplementary forms, letters of engagement and via our website and other marketing related activities in which you engage through our ongoing communications, and through which you voluntarily provide information.
Salter Brothers may also collect information about you that is not voluntarily provided by you in order for us to comply with relevant laws and regulations surrounding your investments and or services provided to you by us.
How we use and disclose the information we collect
Salter Brothers’ sole purpose for holding and using information provided by you or sought externally is for the delivery of financial services and Fund investments provided to you by us.
In fulfilling these services, we work with some external organisations to which we disclose your personal information. These include:
- Any organisations involved in providing or administering our products such as referral agents, financial institutions who hold accounts for you, professional advisers appointed by us, software providers involved in the management and administration of our Funds.
As we are a financial service company, there are situations where we might be required by law to provide your information to Government bodies such as Australian Securities and Investments Commission (“ASIC”), Australian Transaction Reports and Analysis Centre (“AUSTRAC”) and the Australian Taxation Office (“ATO”) or other foreign Government agencies for the purposes of Foreign taxation.
How we protect personal information
Salter Brothers is committed to ensuring the necessary controls are in place to protect personal information held physically and electronically from misuse, interference, loss and unauthorised access, modification or disclosure. Access to information is restricted to only Salter Brothers’ personnel who need to know the information for the purpose of providing services to you.
Your access to and correction of personal information held
Personal information held by Salter Brothers is accessible by you, unless under exceptional circumstances it contravenes the Privacy Act to provide this information to you.
We will take all reasonable measures to ensure that the personal information we collect, hold, use or disclose is accurate, complete, up to date, relevant and not misleading. Please contact us if any of the details you have provided to us change. It is also your responsibility to notify us promptly upon becoming aware of any incorrect personal information we may hold that has either been provided by you or by a third party.
Your information is also collected by our share registry (Computershare Investor Services Pty Limited). Please refer to their privacy details on how they manage the privacy of this information: https://www.computershare.com/au/privacy-policies.
Contact and Complaints handling
- Phone: +61 3 9258 2100 (9am to 5pm on business days in Victoria)
- Email: firstname.lastname@example.org
Salter Brothers will acknowledge receipt of your request or complaint and attend to it as soon as practicable. We will endeavour to investigate and resolve your complaint and will respond to it within 30 days from receipt.
If your complaint is not resolved to your satisfactory, you can lodge a complaint to the Office of the Australian Information Commissioner by:
- Phone: 1300 363 992; or
- Submitting an online complaint form at www.oaic.gov.au