About this Privacy Policy
In this Privacy Policy ‘us’, ‘we’ and ‘our’ means Ashe Morgan Investments Pty Limited (ACN 111 854 132) and our subsidiaries. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store, protect and disclose your personal information. We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).
This Privacy Policy does not constitute a contractual representation, promise, guarantee or warranty by us to you as to the manner in which we will or may collect, use, store, protect, disclose or otherwise handle your personal information.
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details.
What personal information do we collect?
We may collect the following types of personal information:
- name;
- mailing or street address;
- email address;
- telephone number and other contact details;
- age or date of birth;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or through other websites or accounts from which you permit us to collect information;
- information you provide to us through customer surveys; or
- any other personal information that may be required in order to facilitate your dealings with us.
How do we collect personal information?
We will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. When you provide us with personal information you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy and any subsequent amendments.
If it is reasonably practical to do so, we will collect personal information directly from you. We may collect this information when you:
- communicate with us through correspondence, chats, email, or when you share information with us from other social media applications, services or websites;
- interact with our sites, services, content and advertising; or
- invest in our business or enquire as to a potential investment in our business.
We may also collect information about you from other people (e.g. a third party administrator) or independent sources. However, we will only do so where it is not reasonable and practicable to collect the information from you directly. Where we have collected your information from a third party, such personal information will be held, used and disclosed by us in accordance with this Privacy Policy.
In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.
If we receive personal information that we have not requested and determine that the personal information received is not reasonably necessary to provide our services, we will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.
Where practicable, you may be able to interact with us anonymously or by using a pseudonym. Circumstances where it is not practicable, however, include where personal information is required to contact you about our services.
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information in connection with providing, administering our products and services, including:
- to enable you to access and use our website and services;
- to operate, protect, improve and optimise our website, services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
- to service your request in relation to a fund we operate, including checking your eligibility for a fund, providing you with an interest in a fund and helping you to manage your interest in a fund;
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
- to consider your employment application.
If we do not collect your personal information, we may not be able to provide you with these products and services.
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may send you direct marketing communications and information about our products and services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving direct marketing materials from us by contacting us using the details set out below or by using the opt-out instructions that appear at the bottom of all emails we send. Unless and until you opt out, your consent to receive direct marketing communications from us and to the handling of your personal information for this purpose will continue.
To whom do we disclose your personal information?
We do not sell, rent or trade personal information to, or with third parties.
We may disclose personal information for the purposes described in this Privacy Policy to:
- our employees and related bodies corporate;
- third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
- professional advisers, dealers and agents;
- payment systems operators (e.g. merchants receiving card payments);
- our existing or potential agents, business partners or partners;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Disclosure of personal information outside Australia
We do not generally disclose personal information outside Australia. However, if we are required for any reason to disclose your personal information to third parties outside Australia, we will take steps to ensure that your privacy rights continue to be protected by ensuring that the relevant third party is either covered by data privacy laws substantially similar to those in Australia or adheres to the APPs.
Using our website and cookies
To improve your experience on our website, we may use ‘cookies’: small data files that are served by our platform and stored on your device. These are used by us or third parties for a variety of purposes including to operate and personalise the website. Cookies may be used for recording preferences, conducting internal analytics, conducting research to improve our offering, assisting with marketing and delivering certain website functionality (Cookie Information).
We make no attempt to use the Cookie Information to personally identify you. However, if Cookie Information is linked with personal information, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.
You may remove or refuse to accept cookies by selecting the appropriate setting on your internet browser. However, please note that if you do this, you may not be able to use the full functionality of our website.
Third party links
For your convenience and to improve the usage of the website and the services we provide, we may insert links to third-party websites, applications or resources, for which this Privacy Policy does not apply.
We are not responsible for those third party websites, applications or resources. If you access such websites, applications or resources, you do so at your own risk and we make no representations or warranties regarding third parties’ privacy practices. We encourage you to read the privacy statements/policies of every website, application or resource you use. When we do link to a third party website, application or resource, this does not imply that we endorses that website, application, resource and their contents. Our Privacy Policy does not cover the use of cookies by any third parties.
Security
We take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. We store information in access-controlled premises and electronic information on secure servers. Notwithstanding this, you should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, we cannot guarantee any transmission will be completely secure.
In addition, we have procedures that prevent our employees and contractors from unnecessarily accessing your personal information. Only those employees and contractors with a business reason to know have access to such information. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and internal policies on data privacy and corporate integrity. We take appropriate disciplinary measures to enforce employee privacy responsibilities.
Your information is kept for so long as we need it to provide our products and services to you and where applicable, for as long as we are required to keep it to comply with relevant statutory requirements. Where we determine that it is no longer necessary to hold your personal information for the purpose for which the information was used or disclosed, we will securely destroy, delete or permanently de-identify that information to the extent it is possible to do so.
If we become aware of unauthorised access to or disclosure of your personal information, we will take appropriate steps to rectify the data breach and notify you as soon as practicable and provide you with a description of the breach, the type of information involved and any recommended actions you can take to protect yourself.
Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the contact details set out below. We may also need to verify your identity when you request your personal information. We will respond to the request within a reasonable period after the request is made. There is no charge to make a request, however we may charge a reasonable fee to cover the administrative costs of retrieving your personal information. Sometimes, we may refuse or may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why.
If you think that any personal information we hold about you is inaccurate, incomplete or out of date, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the contact details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. In any event, we will endeavour to respond to your complaint within 30 days. If you think that we have failed to resolve the complaint satisfactorily, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined
Contact Us
For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
Investor Relations
Level 13, 131 Macquarie Street
Sydney NSW 2000, Australia
+61 2 9240 1000
Changes to our Privacy Policy and information handling practices
We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy. If we change this Privacy Policy an updated version will be posted on our website to notify you of this change. By continuing to use our services after that time you will be deemed to have accepted any changes to our Privacy Policy.
Effective: 1 January 2023