At Ascalon Capital Managers Limited (Ascalon) your privacy is important to us.
This policy and other privacy statements
This privacy policy explains how we collect personal information and how we maintain, use and disclose that information. It also provides some detail about your privacy rights along with our general rights and obligations and our policy in relation to the personal information we keep on record.
When you apply for a new product or service, the application includes notices about privacy and requests for consent. Those privacy notices (called privacy statements) specify in more detail how any information about you may be used and disclosed in relation to the particular product or service.
If you are an investor, when you apply for or use one of our products or services, you consent to us collecting, maintaining, using and disclosing personal information about you and provided by you or by another person in accordance with the privacy statement in the application and this policy.
If you are an adviser, by recommending our products or services, you consent to us collecting, maintaining, using and disclosing personal information about you and provided by you or by another person in accordance with the privacy statement included with the application and this policy.
This privacy policy does not apply to parties that may be linked or associated with our website. Those website owners are responsible for the privacy of the information they collect and should be contacted directly for details of their privacy policies.
What information does Ascalon hold?
The types of information we keep on record will depend on the type of product or service requested by an investor or recommended by an adviser.
Generally, we keep a record of one or more of the following types of information about you:
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- if you apply for an investment product or service, information about your employment, beneficiaries, bank accounts for funds to be transferred to or from;
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- transaction information relating to the product or service acquired by you, such as details of payments of contributions, units on issue and capital and income distributions for investment products; and
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- if you have a financial adviser, information in connection with your relationship with your adviser.
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for advisers: |
- information about products or services provided by us or our preferred providers acquired by your clients through you or about which we have sent you information in your business capacity;
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- information in connection with your relationship with your clients; and
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for investors and advisers: |
- information that identifies you, such as your name and address and other information provided by you and people nominated by you.
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All information sought is required for our business purposes, which are detailed generally in this privacy policy and more specifically in our application forms or on the web pages which allow you to contact us.
We do not actively seek to collect sensitive information (for example health information or information about your racial or ethnic origin or any criminal record), unless it is necessary for our business purposes. If we do have to collect sensitive information, we will only collect, use and disclose it in accordance with privacy laws.
Sometimes we act as an agent for others when collecting information about you, such as for our preferred insurance companies. We will tell you when we do this.
How Ascalon collects information from its website
We collect and hold information about you when you:
- complete an online application or other type of form;
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- provide us with your email address; or
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- access and use our services through our website.
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We also collect some statistical information about visitors, from our website (for example, the number of visitors, pages viewed, types of transactions conducted, time online and documents downloaded). Some of this statistical information is collected by using cookies, but none of the statistical information we collect allows us to identify a visitor. We use this information to evaluate our website performance and continually improve our services.
Other than statistical information, we do not collect any information about you through our website unless you provide the information to us.
How Ascalon generally collects your information
Generally, we only collect personal information about you from you, unless it is not reasonable or practical for us to do so or you consent. For example, you may authorise us to collect information from a third party, like your accountant, adviser or client or you may be named as a beneficiary in another application for one of our products or services. We may also collect information about you from publicly available sources such as company registers or land title registries.
How may Ascalon use your personal information?
We use personal information about investors and advisers to:
- help us process investors’ applications for products or services and subsequent investment directions (including processing any commissions payable to the adviser);
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- assist with investors’ financial planning needs;
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- effectively manage and administer all products and services we provide to investors (including keeping records required under the Corporations Act);
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- help us form views about how we can improve our relationship with you; and
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- ensure our internal business operations are running smoothly which may include fulfilling legal requirements and conducting confidential systems maintenance and testing.
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When we request your information, we may give more specific details about the way we use your information.
What rights does Ascalon have to disclose personal information?
We may disclose your information if you consent to us doing so. You can give us your consent expressly or it may be implied by your conduct.
Sometimes the law requires or allows us to give out information about you. For example, we must tell the Australian Tax Office how much interest we pay you. Another example is giving your account details to a court if we are ordered to do so under a subpoena.
Depending on our relationship with you, if it is necessary we may also disclose your personal information:
- if you are an investor, to anyone who holds amounts on your behalf which will be transferred to or from us;
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- if you are an adviser, to your dealer group;
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- to our external service providers (which may be located overseas) that provide services to us. This is on a confidential basis and includes organisations which provide us with advisory and administration services, such as fund managers and mailing houses and back office services;
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- to anyone acting on your behalf, for example solicitors, accountants, and for investors, your financial advisers (including their dealer group) and any information service accessed by the financial adviser;
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- to any party acquiring an interest in any business; and
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- to any complaints body to whom a complaint relating to a product or service is referred.
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We may at other times give you more details about our disclosure practices in relation to specific products or services - for example on the forms we use to collect personal information about you.
How Ascalon protects the security of your information
We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure.
We provide the maximum level of security when you use our online products and services.
We have physical, electronic and procedural safeguards to protect your information which is held by us. For example, your personal information is stored in secured office premises, in electronic databases requiring logins and passwords for access. Access to information stored electronically is restricted to staff whose job purpose requires access. We require all staff to maintain the confidentiality of customer information.
Any visitor, for any purpose, to any part of our premises in which customer personal information is kept is required to register with a security desk or be accompanied by a member of staff while in the premises.
We use secure methods to destroy or de-identify any personal information as soon as the law permits, provided the information is no longer needed by us for any purpose. Ordinarily, for information about a particular account, we destroy the information seven years from the date you close the account.
Changes to our Privacy Policy
We may amend this policy from time to time. Not all changes to our privacy policy will require your consent, for example where office security procedures are changed. We will notify you of any change to our information handling policy that requires your consent before being implemented.
What are your rights?
You need not give us any of the personal information about you or any other person which may be requested in our communications with you. However, without that information, we may not be able to process an application, fulfil your request or provide you with an appropriate level of service.
Marketing Opt-out
If you do not want the benefit of receiving information, special offers or exclusive opportunities about products and services (which may be supplied by us or our preferred suppliers) which we think may be of interest or value to you, then please tell us. You can do this at any time by writing to us or telephoning us at the contact details listed on our contact us page.
Access to your information
You can request access at any time to personal information we hold about you. We will process your request within a reasonable time, usually 14 days. More time may be needed, depending on the nature of the request.
There is no fee for requesting access to your information, however we may charge you the reasonable cost of processing your request.
Sometimes we are not required to provide you with access. If we refuse you access to your personal information, we will tell you the reason why. If we are not required to provide you with access to the information requested, we will consider, if reasonable, whether the use of a mutually agreed intermediary would allow sufficient access to meet your needs and ours.
Correction of information
We try to ensure that all information we hold about you which we collect, use or disclose is accurate, complete and up to date. You must promptly notify us if there are any changes to your personal information.
You may ask us at any time to correct personal information held by us about you, which you believe is incorrect or out of date. We will deal with your request within a reasonable time.
If we disagree as to the accuracy of the information, you may request we make an appropriate notation in relation to that information noting that you consider it is not accurate, complete or up to date.
If there is anything you would like to discuss, please contact us
If you have any questions, concerns or complaints about our privacy policy or practices, please contact us in writing, by telephone or by email.
We will try to answer any questions you may have, correct any error on our part or resolve any complaint that you may have about our information handling practices. If we do not resolve a complaint to your satisfaction, you also have the right to complain to the Privacy Commissioner. We will provide you with the Privacy Commissioner’s contact details if required.
Administration and Investor Services
| Phone: 1300 303 933 |
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Address: Level 18, 15 Castlereagh Street, Sydney NSW 2000 |
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Email: ascalon@ascalon.com.au |
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