1. ABOUT THIS POLICY
Metrics is the appointed investment manager of retail and wholesale investment funds (“Funds”) and collects personal information in the course of providing management services.
We are committed to protecting your privacy and understand the importance of protecting your personal information. This Policy outlines the types of personal information that we usually collect about you, the purposes for which we collect it, to whom we disclose it, how we hold and keep it secure and your rights in relation to your personal information, including how to complain and how we deal with complaints.
We will handle your personal information in accordance with this Policy, legislation including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
In this Policy, personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified (anonymous data). Sensitive information is a subset of personal information that is generally afforded a higher level of protection by privacy laws. It includes your health information as well as information about your racial or ethnic origin, political opinions, membership of political, professional or trade associations or trade unions, religious beliefs, sexual orientation or practices and criminal record.
This Policy does not apply to the personal information of our employees.
2. TYPES OF PERSONAL INFORMATION WE COLLECT
As the appointed investment manager, Metrics collects personal information from individuals on behalf of the trustee or responsible entity of the Funds in respect of trust assets, about visitors to our website, as well as from contractors, job applicants and third parties with whom we deal, such as service providers and financial planners. The types of personal information we collect depends on your dealings with us and includes:
- name, address, email address and phone number; and
- identification documents, such as a passport and drivers’ licence
- information collected about trust assets in respect of individuals (eg loan guarantors), such as information in respect of a guarantor’s financial standing.
If you apply for a job or contract position with us, we may also collect the following types of information, including sensitive information, about you:
- employment history and qualifications;
- academic records;
- criminal history record;
- directorships; and
- eligibility to work in Australia.
3. DEALING WITH US ANONYMOUSLY OR USING A PSEUDONYM
Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us directly with a general question we will not record your name unless we need it to adequately handle your question.
However, for many of our functions and activities we and our partners usually need your name, contact information and other details to enable us to provide our services or products to you.
4. WAYS WE COLLECT YOUR PERSONAL INFORMATION
We generally collect personal information from you directly when you interact with us (eg via your interactions with our website, over the phone, via email, forms or in person). If you are an actual or potential investor, we may also receive your contact details from a Fund distributor or administrator. If you apply for a job or contract position with us, we may also collect personal information about you from third parties and publicly available sources, including:
- government departments to verify your entitlement to work in Australia;
- the police to obtain your criminal history record;
- academic institutions and professional bodies;
- your current or previous employers; or
- your referees.
5. PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION
We collect, use and disclose your personal information for the following purposes:
- providing our services as investment manager;
- to undertake research, planning, product development, risk assessment, risk modelling and marketing;
- undertaking identity verification (know your customer) checks on behalf of the trustee or responsible entity of a Fund;
- obtaining feedback;
- conduct or allow others to conduct direct marketing;
- communicating with you in various ways;
- the general management and conduct of our business;
- complying with our legal obligations, resolving any disputes and enforcing our agreements and rights with third parties; and
- considering your employment application.
6. DISCLOSING YOUR PERSONAL INFORMATION
In the course of conducting our business, we may disclose your personal information to:
- Metrics’ related entities;
- the trustee of a fund;
- organisations we contract to provide services on our behalf including marketing and distribution services;
- anyone to whom our assets or businesses (or any part of them) are transferred or sold; and
- government agencies, regulatory bodies and law enforcement agencies, or other entities or individuals as may be required, authorised or permitted by law.
7. DIRECT MARKETING
We, or Pinnacle Investment Management Limited may use your personal information to send you newsletters, including fund performance reporting, to identify a product or service that may be of interest to financial planners or wholesale investors or to promote events. We may, with your consent and if permitted to do so under Australian financial services laws, use the personal information we have collected about you to contact you from time to time whether by email, phone or post to tell you about new products or services that we believe may be of interest.
You can withdraw your consent to receiving direct marketing communications from us at any time by following the unsubscribe function in the marketing communication or contacting the General Counsel using the details set out below.
8. SECURITY AND STORAGE
We store your personal information in hard copy and electronically. Electronic information is stored with a third party storage provider and service providers with whom we share personal information are bound by obligations of confidentiality. We take all reasonable and appropriate steps (including organisational and technological measures such as encryption) to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
9. ACCESS TO AND CORRECTION OF YOUR INFORMATION
We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by applicable laws. If we no longer need to hold your personal information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.
We aim to ensure that the personal information collected from you is up to date, accurate and complete. You may request access to and correction of, the personal information we hold about you at any time by contacting our General Counsel. We will need to verify your identity. Subject to any applicable exceptions or requirements, we will provide you with access the personal information you request within reasonable time and usually within 28 days. If we decide to refuse your access or correction request, we will provide our reasons in writing and explain how to complain.
If you have a complaint about Metrics’ handling of your personal information, you can make a complaint in writing to our General Counsel using the details provided in this Policy. We will need to verify your identity. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
If you are not satisfied with our response, you may complain to the Australian Financial Complaints Authority (AFCA) via the AFCA website, www.afca.org.au or, alternatively, the Office of the Australian Information Commissioner (OAIC) via the OAIC website, www.oaic.gov.au.
11. CONTACT US
If you have a question or comment about this Policy or wish to make a complaint or exercise your privacy rights, please contact us using the following details:
Metrics Credit Partners Pty Ltd
2 Ridge Street
North Sydney NSW 2060
Phone: 1300 010 311
Last updated: February, 2019