Information collected and means of collection
The kinds of personal information we collect about you include:
We are required in most circumstances to collect this information by the Corporations Act 2001 (Cth), the Superannuation Industry (Supervision) Act 1993 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or Taxation law or the Foreign Account Tax Compliance Act (USA).
We do not collect any ‘sensitive information' (e.g. about health or ethnic origin), as defined in the Privacy Act 1988 (Cth).
We typically collect personal information at the time you establish an investment account with us, either from you or your financial adviser. The information may be collected by an agent of ours, such as a unit registry for unitholders in our feeder Funds. If you are a unitholder in one of our Funds, the information is collected in the first instance when an application form is submitted. Additional information may be collected in the course of subsequent correspondence about your investment with us, including during performance review meetings.
Purpose for collecting and holding the information and disclosure of the information
We use your personal information to enable us to accept and process your application, administer and manage your investment, communicate with you about your investment and maintain a record of investment details and investors as required by legislation. We may also use your personal information to advise you of our products and services which we believe may be of interest to you. You can request not to receive these marketing communications from us by contacting us using the contact details at the end of this Policy.
As part of the identity verification process in providing our services to you, your personal information may be matched to Government-issued identity records (eg drivers licences and passports) held by the issuer of those records or the official record holder. This may occur via a third party.
In the course of carrying on our business, we may also disclose your personal information to:
Our Funds’ custodians may share personal information with entities outside Australia for the purpose of administration associated with the management of the Funds and anti-money laundering. Our storage provider may store your personal information in Canada. We may be required to disclose personal information to the Securities and Exchange Commission in the United States of America if it conducts an audit of our activities. We may also disclose personal information to the ATO, who may disclose the information to the Internal Revenue Service in the United States in accordance with intergovernmental arrangements associated with the Foreign Account Tax Compliance Act (FATCA).
Storage of information
We hold personal information in both paper and electronic form. Personal information held in electronic form is regularly backed-up and stored in a secure off-site location. Some personal information is stored with a third-party data storage provider. We will destroy or de-identify personal information once permitted by law and if we no longer need it for any purpose.
Access to, and correction of, personal information
If you wish to seek access to, or correction of, your personal information please contact us using the contact details at the end of this Policy.
Access requests for personal information must be in writing and must satisfy our internal procedures that the individual making the request is the same person as the subject of the request. If a request for access is received and accepted, we will typically grant access by giving a copy or, if agreed by you, a summary of the personal information to you. The means of delivery can be in person at our office, verbally over the phone, by mail, by fax or by email. We may refuse access to all or part of your personal information in certain circumstances as permitted under the Privacy Act 1988 (Cth).
Our aim is to respond to access requests within ten business days, with either the information requested, or if the request is denied, the reason therefore. We will not charge a fee for the making of the access request and we do not intend at this stage to charge a fee for giving you access to your information.
If you tell us that any of the personal information we hold is not accurate, complete, up-to-date or relevant, we will usually correct the information. However, there may be occasions where we refuse to do so as permitted under the Privacy Act 1988 (Cth). In this case we will notify you of the reasons for our refusal. We will not charge you for the making of the request or correcting your personal information.
Notifiable data breaches
We will endeavor to prevent unauthorised access, disclosure and loss of personal information. In the unlikely event of a suspected data breach, we will assess the breach to determine whether it is likely to result in serious harm to any of the individuals to whom the information relates. In which case, we will notify the individual(s) at risk of serious harm and the Office of the Australian Information Commissioner as soon as practicable.
Atlas Advisors Australia is committed to providing our investors with the highest level of service. If, however you are dissatisfied with our level of service and wish to make a complaint please let us know.
If you have a complaint related to how we have managed your personal information you can contact our Client Services team as follows;
Where you have called our client services team, we may ask you to put your complaint in writing. We will acknowledge receipt of your complaint immediately and we will investigate and respond to your complaint as soon as is practicable after we receive it.
Please address all privacy enquiries (aside from privacy complaints, for which contact details are outlined in the section above) to:
Atlas Advisors Australia
Level 19, 1 Macquarie Place
Sydney NSW 2000 Australia
T +61 02 9248 0457