Privacy Policy

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1   About this Policy

Allier Capital Pty. Ltd. (ABN 19 135 428 616, AFSL 336276)(the “Business”) is committed to safeguarding the personal information that it receives. The Business will hold personal information in confidence in accordance with the Australian Privacy Principles (“APPs”) and the Privacy Act 1988 (Cth) as amended (“Privacy Act”).

By visiting our website or accessing any of our services, you have consented to such information being processed as set out in this policy and for receiving additional information about the full range of services offered by us and our affiliates.

1.1   WHAT IS PERSONAL INFORMATION?

Under the Privacy Act, personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

1.2   WHAT PERSONAL INFORMATION DO WE COLLECT AND WHY DO WE COLLECT IT?

We may collect personal information for the purpose of providing financial products or services from the client (including their staff and representatives). This information includes, but is not limited to:

·      name

·      date of birth

·      contact details

·      gender

·      Tax File Number

·      country of residence

·      investment information

·      credit card or bank account information

·      information about your business or personal circumstances

·      information in connection with surveys, questionnaires and promotions

·      communications between us and you

This information is collected to facilitate the provision of a service or product by the business and to comply with local and international laws, for example anti-money laundering and counter terrorism financing laws.

The Business may also collect personal information from people we do business with in order to fulfil the relevant business purpose. This will usually happen when we collect the name and business contact details of a person who is an adviser, supplier or other business contact. We collect this information to facilitate the relevant business purpose.

The Business may also collect personal information from people who send us correspondence. Information collected includes name and contact details. We collect this information to deal with correspondence.

We will not collect information of a sensitive or personal nature that is not required for us to provide a financial service or product (for example information on health, race, religion etc).

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1.3   HOW WE COLLECT PERSONAL INFORMATION?

In most instances we will collect personal information directly from the person to whom the information relates, or the organisation of which that personal is an employee, director or principal including where you:

·      contact us through our website

·      communicate with us via email, telephone, SMS, social media (such as        LinkedIn)

·      access our services, content and advertising

However, we may also collect personal information about individuals from the following third parties including:

·      government agencies

·      publicly available records

·      public registries

·      parties to whom you refer us, including previous employers and referees

·      recruitment agencies

We may also collect personal information from people we do business with in order to fulfil the relevant business purpose. This will usually happen when we collect the name and business contact details of a person who is an adviser, supplier or other business contact.

We may also collect personal information from people who send us correspondence. We collect this information to deal with correspondence.

1.4   WHAT IF THE INFORMATION IS INCOMPLETE OR INACCURATE?

We may not be able to provide you with the services you are seeking.

1.5   HOW DO WE USE AND DISCLOSE PERSONAL INFORMATION?

Your personal information will only be used for the purpose for which it was provided and for any other purposes for which we obtain your separate and additional consent. These purposes may include:

·      providing requested products orservices

·      managing and developing our relationship with clients and potential clients

·      to respond to queries, complaints or to provide general customer services

·      carrying out our functions as a professional service provider

·      to conduct service and market research

·      to train our staff

We may disclose the information to our affiliates and service providers who may be located in Australia or overseas. Where information is disclosed to a third party, we will take steps to ensure that confidentiality arrangements are in place prior to the information being disclosed, and only the information necessary for the third party to perform their service is disclosed.

We may be required by local or international laws to disclose personal information to a government body, regulator, enforcement agency, court or tribunal.

1.6   HOW DO WE PROTECT THE CONFIDENTIALITY OF PERSONAL INFORMATION?

We will take reasonable steps to ensure that any identifiable personal information that we have collected is stored securely. The measures utilised include password protection to our systems, restricting access to our systems and education of staff.

1.7   OUR WEBSITE AND COOKIES

Our website may collect non-personal information when you visit our website. Our website also uses cookies. A 'cookie' is a packet of information that allows the server (the computer that houses the web site) to identify and interact more effectively with your computer. This information does not typically identify individual users and it is unlikely to be personal information.

If you do not wish to receive any cookies, you may set your web browser to refuse cookies.

1.8   LINKS TO OTHER WEBSITES

Our website may have links to external third-party websites that may benefit the user. External websites should contain their own privacy statements and we recommend you review them when using their websites. Please note, however, that third party websites are not covered by our Privacy Policy and these websites are not subject to our privacy standards and procedures.

1.9   ACCESS TO PERSONAL INFORMATION, CORRECTIONS AND COMPLAINTS

You have a right to access any personal information we hold about you (although there are some exceptions to this) and correct any personal information that may be incorrect by contacting us at the address below. We may deny such a request in some circumstances, if we do this we will explain why. Please note that the personal information we hold about you will be information that you (or your representative) have provided.

We will respond to requests for access or correction within a reasonable time. We may ask you to pay its reasonable costs of responding to your request. You may also make a complaint concerning a breach of the Privacy Act by contacting us:

By phone:         +61 2) 80146048

By mail:            The Privacy Officer

                          Allier Capital

                          Level 2, Bligh Street, Sydney NSW 2000

By email:           ea@allier.com.au

We will acknowledge complaints and provide a final response within 45 days of receipt of the complaint.

The complaint may also be taken to the Office of the Australian Information Commissioner (OAIC). For more information on how to lodge a complaint with the OAIC, please contact OAIC on 1300 363 992 or email enquiries@oaic.gov.au.

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1.10  ADDITIONAL INFORMATION

For further information about privacy issues, see the Office of the Australian Information Commissioner's website at www.oaic.gov.au.

1.11  CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Policy at any time. We will make this Privacy Policy available to anyone who requests it, free of charge, either at our offices, through our website or by individual request.