Constantia Investment Partners Pty Limited, as well as other members of the Constantia Investment Partners group (together “we,” “us”, “our” or “Constantia”) are committed to safeguarding any personal information that we receive. Constantia will hold personal information in confidence in accordance with the Australian Privacy Principles (“APPs”) and the Privacy Act 1988 (Cth), as amended (“Privacy Act”).
Constantia (through the registrar of its investment products) may collect personal information about investors in Constantia investment products from the investor (including their staff and representatives), individuals we do business with and individuals who send us correspondence. This information includes, but is not limited to:
• date of birth or age;
• mailing or street address;
• email address;
• telephone number;
• Tax File Number;
• country of residence;
• profession, occupation or job title;
• investment information;
• bank account information;
• details about the products that an investor has invested in or enquired about, together with any additional information necessary to deliver those products and respond to those enquiries; and
• any additional information relating to an investor that an investor provides to us directly or indirectly through our representatives and advisors.
We will not generally collect sensitive information (for example information on race or religion, or health information).
We generally collect the above information directly from investors and business contacts (or their staff and representatives) and from investors and business contacts through third party administrators, representatives and advisors. We may collect personal information in multiple manners, including during conversations between an individual and our administrators, representatives and advisors, when an individual completes an application or when a business partner agrees to do business with us.
We may also collect personal information from individuals who send us correspondence by taking the personal information from the correspondence. We collect this information directly from the relevant individuals and not from third parties.
We collect, hold, use and disclose this personal information so that we can perform our business activities and functions and we can provide the best possible quality of customer service and deal with any correspondence. We also collect, hold, use and disclose this personal information to facilitate an investment in the relevant product and to comply with relevant laws, for example Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
The purposes for which we collect, hold, use and disclose personal information include:
• to provide products and services to you and to send communications requested by you;
• to answer your enquiries and provide information or advice about existing and new products or services
• to provide you with access to protected areas of our website;
• to assess the performance of the website and to improve the operation of the website;
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of Constantia, its related bodies corporate, contractors or service providers;
• to provide your updated personal information to our related bodies corporate, contractors or service providers;
• to update our records and keep your contact details up to date;
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.
Constantia may not be able to provide you with the products you are seeking, either to the same standard or at all. We also may not be able to provide you with information about products that you may want or tailor the content of our website to your preferences.
Constantia may disclose personal information to its employees, affiliates, contractors and service providers, suppliers and other third parties with whom we have commercial relationships for the purposes of operation of our business, marketing purposes, fulfilling requests from investors, providing products and services to investors and other related purposes. We may also disclose your personal information to any organisation for any authorised purpose with your express consent. Where we disclose information to a third party, confidentiality arrangements will be in place.We may disclose personal information to our third-party representatives and advisors located overseas, including disclosures to our administrator located in Canada, for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
Constantia may be required by relevant laws to disclose personal information to a regulator (such as the Australian Taxation Office) or to a court or tribunal.
We will take reasonable steps to ensure that any personal information that we have collected is stored securely and protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your personal information in either electronic or hard copy form. The measures utilised to secure personal information include password protection to our systems, restricting access to our systems and education of staff. As our website is linked to the internet, and the internet is inherently unsecure, we cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
You have a right to request access to the personal information we hold about you by contacting Constantia at the address below (although there are some exceptions to this where we cannot grant you access). When we grant your request, we will try to provide you with suitable means of accessing the personal information (for example, by mailing or emailing it to you).
You also have the right to request we correct any of your personal information that you believe is incorrect (although there are some exceptions where we can refuse to correct the personal information). If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting Constantia at the address below. We will consider and respond to requests for access or correction within a reasonable time. If we deny a request, we will provide you with a written explanation within a reasonable period. If you are dissatisfied with the outcome of your request, please refer to our “Complaints” section below for further information. We will not charge you a fee to make a request, to update or correct your personal information or to provide your personal information to you.
If you believe that your privacy has been breached, you may also make a complaint to Constantia by writing to our Privacy Officer at the address below. We will ask you to provide details of the incident so that we can investigate it. We may request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. We will attempt to confirm the details of the complaint with you and what you expect as an outcome. We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
After we have completed our enquiries, we will contact you to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view. If you are dissatisfied with the outcome of our investigation, you may take your complaint to the Privacy Commissioner at the Office of the Australian Information Commissioner (OAIC). The contact details for the OAIC are available from the OAIC’s website at www.oaic.gov.au.
We may send investors marketing communications and information about our products and services that we consider may be of interest to an investor. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). An investor’s consent to us sending those marketing communications by any of those methods may be implied by virtue of our existing business relationship. If an investor indicates a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time an individual may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that the individual’s name is removed from our marketing lists. We do not provide your personal information to other organisations for the purposes of direct marketing.
If you have a privacy concern, complaint or query or believe your privacy has been breached, please contact our Privacy Officer at +61 2 8379 3700 or by email at email@example.com.
Constantia Investment Partners Pty Limited
Suite 1, Level 9
17 Castlereagh Street
Sydney NSW 2000
Constantia Investment Partners Pty Limited