2. Personal information we collect
The types of personal information we collect include:
- names, titles, contact and address details;
- information in identification documents (for example, passport, drivers licence);
- tax file numbers and other government-issued identification numbers;
- date of birth and gender;
- bank account details and details of investments;
- details of superannuation
it may be necessary for SPF to collect sensitive information about you in order to provide specific investments, services or for recruiting purposes (e.g. professional memberships, ethnic origin, criminal record and health information).
3. How we collect and manager personal information
How we collect personal information
We will generally collect your personal information from you directly. Sometimes it may be necessary for us to collect your personal details from a third party such as your personal representative or professional advisor.
We may also collect personal information about you from your use of our websites and information you provide to us through contact mailboxes or through the registration process on our website.
Where you provide us with personal information about someone else
Holding personal information
SPF holds personal information in hard copy and electronic formats. We take security measures to protect the personal information we hold including physical (for example secured premises and storage of files in lockable cabinets) and technology (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates) security measures. We also have document retention policies and processes.
Purpose for collecting, holding, using and disclosing personal information
SPF collects, holds and uses personal information for a number of purposes including:
- to provide investment products;
- to provide professional services;
- to respond to requests or queries;
- to maintain contact with our clients;
- to keep our clients informed of our products, performance and developments;
- to notify of seminars and other events;
- to verify your identity;
- for administrative purposes, including processing payment transactions;
- for recruitment purposes;
- for purposes relating to the employment of personnel;
- when engaging service providers, other SPF member companies, contractors or suppliers relating to the operation of our business;
- to manage any conflict of interest or independence obligations or situations;
- to conduct surveys;
- for seeking feedback;
- to meet regulatory obligations;
- as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including SPF’s business) or entering into an alliance, joint venture or referral arrangement;
- to perform internal statistical analysis, including f our databases or websites;
- for any other business related purposes.
If you do not provide us with the personal information we have requested, we may not be able to complete or fulfil the purpose for which such information was collected, including providing you or our clients with services we were engaged to perform or interests in investments applied for.
The types of third parties to whom we may disclose your personal information include:
- experts or third parties contracted as part of an engagement;
- our service providers;
- our professional advisers;
- other SPF member companies;
- as part of an engagement, if you are a customer, an employee, a contractor or supplier of services to one of our clients, then we may disclose your personal information as part of providing services to that client;
- as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including SPF’s business) or entering into an alliance, joint venture or referral arrangement; or
- government or regulatory bodies or agencies, as part of an engagement or otherwise, (e.g. the Australian Taxation Office).
We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you. However, we may share non personal, de-indentified or aggregated information to them for research or promotional purposes.
Disclosure of personal information overseas
We may store, process or back-up your personal information on servers that are located overseas (including through third party service providers).
In some circumstances, SPF may use third party service providers to carry out its functions. Some of these providers may be located overseas.
4. Direct marketing
SPF may also use your personal information for the purpose of marketing its investment products or services. if you do not want to receive marketing material from us, you can contact us as detailed below:
- for electronic communications, you can click on the unsubscribe function in the communication; or
- for hard copy communications, you can email email@example.com ; or
- through our contact details below.
5. Privacy on our websites
Cookies and web beacons
Cookies and web beacons may be used on some SPF websites, primarily used to enhance your online experience and to make our sites more user friendly.
Cookies are small text files placed on your computer when you first visit the site. Most browsers now recognise when a cookie is offered and permit you to refuse or accept it. If you are not sure whether your browser has this capacity, you should check with the software manufacturer, your company's technology help desk or your internet service provider.
A web beacon is a clear picture file that is placed on a website or in an email that is used to monitor the behaviour of a user visiting the website or sending an email. When the HTML code for the web beacon points to a site to retrieve the image, at the same time it can pass along information such as an IP address of the computer that retrieved the image, the time the web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookies values.
You have several choices regarding your use of SPF websites. In general, you are not required to provide personal information when you visit our websites. However, if you apply to receive information about our products, services, events and updates or wish to apply for employment, provision of certain personal information will generally be required.
Links to third party websites
We understand the importance of protecting children's privacy, especially in an online environment. In particular, our websites are not intentionally designed for or directed at children under the age of 13. It is our policy to never knowingly collect or maintain information about anyone under the age of 13, except as part of a specific engagement to provide professional services, including investment products, which necessitates such personal information be collected.
7. Gaining access to personal information we hold
You can request access to your personal information, subject to some limited exceptions permitted or required by law. Such request must be made in writing to the Privacy Officer. Please see the 'How to contact us’ section for details.
SPF may change reasonable costs for providing access to your personal information.
8. Keeping personal information current
If you believe that any personal information SPF has collected about you is inaccurate, not up-to- date, incomplete irrelevant or misleading, you may request correction. To do so, please contact the Privacy Officer and we will make reasonable steps to correct it in accordance with the requirements of the Privacy Act. Please see the 'How to contact us' section for details as to how to contact the Privacy Officer.
If you wish to make a complaint to SPF about our handling of your personal information, you can contact the Privacy Officer as set out in the ‘How to contact us section. You will be asked to set out the details of your complaint in writing in a form provided.
SPF will endeavour to reply to you within 14 days of receipt of the complaint form and, where appropriate, will advise you of the general reasons for the outcome of the complaint. In some circumstances, the Privacy Officer may decline to investigate the matter, for example if the matter relates to an act or practice that is not an interference of the privacy of the person making the complaint. If you are not satisfied with the outcome of your complaint, you can refer our complaint to the Office of the Australian Information Commissioner.
10. How to contact us
Steller Property Funds
840 Dandenong Road
Caulfield East VIC 3145
Phone: 03 8658 8341