Privacy Policy

November 2016

This Privacy Policy applies to information collected by Kinetic Investment Partners Pty Limited ABN 28 009 568 496 (“we”, “us” or “our”). It outlines how we manage your personal information and safeguard your privacy.

We understand your concerns about privacy and the security of your personal information. Your privacy is important to us and we have practices in place to comply with the Privacy Act 1998 (Cth) and the Australian Privacy Principles (“APPs”).

By providing us with your personal information, you consent to us using, disclosing and otherwise handling your personal information in accordance with this Privacy Policy, as updated from time to time.

What personal information is collected?

Personal information is information or an opinion about an identified, or reasonably identified, individual.

The type of personal information we may collect from you will vary depending upon the financial service we provide to you. Personal information collected could include – your name, date of birth, address and contact details.   The Australian Government’s Anti-Money Laundering Act may also require us to collect additional personal information from you.

We also collect information from you when you visit our website. Your use of the website will determine the amount and type of information that we collect from you. Some of this information will not be personal information because it will not reveal your identity.

We use third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful on our website. Our web analytics providers use “cookies” to collect information.

The only personal information which we collect about you when you use a website is what you tell us about yourself. We will record your email address if you send us an email.

Cookies

Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Most web browsers are set to accept cookies. However, if you do not wish to receive any cookies you may set your web browser to refuse cookies.

How is personal information collected?

Personal information may be collected by us pursuant to an Investment Mandate Agreement. There are also several related purposes for which your personal information may be collected and these could include assisting in the processing of an application, and comply with Australian taxation laws, the Corporations Act, the Anti-Money Laundering and Counter Terrorism Financing Act (AML/CTF Act) and other laws and regulations. In addition, we may collect personal information about individuals who are not clients of us, for example business contact details of a company representative with whom we deal.

What if you do not provide certain information?

We may need to request a Tax File Number (TFN) or Australian Business Number. It is not compulsory to provided either however failure to do so or the absence of an exemption for either may result in withholding tax being deducted from distributions at the highest marginal rate (plus Medicare levy and any other levy applicable).

To comply with our obligations under the AML/CTF Laws, we must collect certain information, supported by original or certified copies of relevant documents. If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you with our services.

Use and disclosure of your personal information

We may collect, use and disclose your personal information for the primary purpose of providing the services requested by you and :

  • to any third-party service provider engaged to provide custody, reporting, administration, technology, auditing, registry, mailing or printing services in relation to your investment or service provided by us;
  • to the Australian Tax Or other governmental recovery body, where and to the extent required or by law;
  • to any professional advisers, including legal and accounting firms, auditors, consultants and other advisers;
  • within Kinetic;

subject to our professional obligations

 Use of service providers

We may contract out some of our administrative and support functions such as mailing, settlement services, document and data storage or identity verification services to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.

Storage and security of information

We store personal information in a combination of computer storage facilities and paper-based files. These are held on our premises and systems as well as offsite using trusted third parties. We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure.

Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.

Access and correction

You may contact us to request access to the personal information we hold about you at any time. You may also ask to correct information about you that you believe is inaccurate, incomplete or out of date.

Prior to providing you with any information we will need to verify your identity before giving you access, or correcting your information.

In certain circumstances, we may not be able to correct or provide you with access to your information. In the circumstances, will write to you to explain and provide the reasons why. We take all reasonable precautions to ensure the personal information we collect, use and disclose accurate, complete and up-to-date. However, we recommend that you advise us if there is any error in your personal information and that you update us on any changes to your personal information such as name or address.

Identifiers

We do not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as its own identifier.

Trans-border data flows

At present, we do not disclose personal information to recipients in foreign countries.

Direct Marketing

We will not use your personal information for direct marketing purposes unless:

  • we have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and
  • we have provided you with a simple means to ‘opt-out’ from receiving direct marketing; and
  • we have not received such a request from you

We will not use any sensitive information collected from you for direct marketing purposes.

Changes to our Privacy Policy

We may make changes to this Privacy Policy from time to time for any reason and will make concerted efforts to update the website in a timely manner.

Contacting us

If you would like more information about how we manage your personal information or if you wish to change your contact information, please contact us on +61 3 8657 5692, or write to us at the following address:

The Privacy Officer
Kinetic Investment Partners Pty Limited
Professional suites Level 2,

120 Collins Street
Melbourne VIC 3000
Email: kinetic@kineticip.com.au

Complaints about your privacy

If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. When we write to you about our decision, we will explain how you may access an external dispute resolution scheme or make a complaint to the office of the Australian Information Commissioner (OAIC). The Commissioner may be contacted on the privacy hotline: 1300 363 992 or email enquiries@oaic.gov.au.