Officium Capital - Disclaimer

Privacy Policy Statement

Officium Capital Limited (Officium) abide by the National Privacy Principles established under the Privacy Amendment (Private Sector) Act, 2000.

1. INFORMATION WE COLLECT

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,
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 this web site, and
responses to our surveys.

2. CONSEQUENCES OF NOT PROVIDING INFORMATION

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.

3. INFORMATION COLLECTION POLICY

We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.

Generally, collection of your personal information will be effected from our Product Disclosure Statement 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.

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 contact you with regards to reporting of funds information such as distribution statement and performance; and
to fulfil requirements of the law such as Tax File Number collection.

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; and
Providing you with information about other services and products we offer (unless you tell us you don’t want this information).

4. INFORMATION DISCLOSURE

We will not use or disclose personal information collected by us for any purpose other than:

the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure;
where you have consented to such disclosure;
where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

We are also 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 Officium, superannuation fund trustees, insurance brokers, insurance companies, fund managers, custodians, fund administrators, mailing houses and auditors for the purpose of giving effect to the service provided by us.

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.

In order to ensure that you receive a personal and tailored service, your personal information will be made available to other employees of Officium. It is a condition of our agreement with each of our employees that they adopt and adhere to this privacy policy. You can be assured that your information will be maintained by any employee of Officium in accordance with this policy. If you have any concerns in this regard, you should contact us by any of the methods detailed overleaf.

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

It is a condition of our agreement with each of our external contractors that they adopt and adhere to this privacy policy. We will confirm with external contractors that they have systems and procedures for handling personal information in accordance with this policy.

If you have any concerns in this regard, you should contact us by any of the methods detailed below.

We will advise you of any change in business circumstances that may affect the handling of your personal information.

5. STORAGE 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. Data is backed up each evening and stored securely off site.

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).

6. 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.

7. CORRECTION 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 outdated, you may contact us by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness or of any outdated information and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.

8. COMPLAINTS

If you wish to complain about any breach or potential breach of this privacy policy or the National Privacy Principles, you should contact us by any of the methods detailed below and request that your complaint be directed to the Privacy Officer. Your complaint will be considered within seven days and responded to. It is our intention to use our best endeavours to resolve any complaint to your satisfaction, however, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.

9. INTERNET SITE

Officium’s website may at times contain links to other Websites whose operator may or may not adhere to a privacy policy or be governed by the National 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 e-mail 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 e-mail to the e-mail 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 e-mail to the e-mail address noted below providing your amended details. Please allow two weeks for your request to be actioned.

Our website may use cookies, which would allow us to identify your browser while you are using our site. Cookies do not identify you; they simply allow us to track usage patterns so that we can measure the level of interest in various areas of our site. All browsers allow you to be notified when you receive a cookie and elect to either accept it or not. Your Internet service provider should be able to assist you to set your preferences.

10. ADDITIONAL PRIVACY INFORMATION

Further information on privacy in Australia may be obtained by visiting the website of the Office of the Federal Privacy Commissioner at www.privacy.gov.au .

11. CONTACT DETAILS

Privacy Officer: Privacy Officer
Terrace House 3, 249 Coronation Drive,
Milton QLD 4064
Telephone: (07) 3876 4333
Facsimile: (07) 3876 4377
Email: admin@officiumcapital.com.au
Web: www.officiumcapital.com.au
Australian Financial Services Licence No: 275101
ACN 108 747 637

Dated: 24 February 2010