Privacy Policy
Personal Information
- This Privacy Policy applies to the collection of personal information by or on behalf of Polar 993 Limited ACN 642 129 226 and Polar 993 Advisory Pty Ltd ACN 649 554 932, collectively known as Polar 993, its related companies and the funds or managed investment schemes that Polar 993 or its related companies act as trustee of or responsible entity for (Polar 993, we, us, our).
- At Polar 993, we seek to protect the personal information we collect, in accordance with the Privacy Act 1988 (Cth). This Policy outlines how we collect, store, manage, use and disclose personal information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected.
- When providing you with quality products or services—whether through consumer-facing services conducted by Polar 993 or investment-related services provided by Polar 993 and its related entities we collect certain information. Details of Polar 993’s information collection and use can be found in our Privacy Collection Statement.
- It should be noted that Polar 993 may use your information to manage ongoing requirements as well as our relationship with you. For example, we may:
- de-identify your data for our own purposes including market research and fraud mitigation; and
- use your personal information for related purposes which would reasonably be expected without your permission. For example, we may from time to time use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you.
- We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
- We may also use your information internally to help us improve our services and help resolve any problems.
How do we protect your personal information?
- We have security policies and systems in place to protect your personal information, which are reviewed, monitored and updated on a regular basis. We take reasonable steps to protect the personal information we hold from loss, interference, destruction, unauthorised access, modification or disclosure using both physical and electronic security measures. We implement multiple layers of security controls throughout our systems so that in the event that one control fails, or a vulnerability is exploited, there are other measures still in place to protect your personal information. Relevant measures include firewalls, data encryption, limiting physical access to data centres and controls over access to information.
- The people within our organisation who handle your personal information are only those who have the need to access it and they have the training and skills to protect your personal information from unauthorised access or misuse.
- Our website uses industry standard security protocols to protect the personal information you disclose in using our online facilities. We use encryption to provide more secure communications when using our online facilities. In addition, when you use our online facilities you must read and accept terms and conditions relating to privacy and security.
- If you provide us with your personal information over the internet you accept that such information will be transmitted at your own risk as the security of such information cannot be guaranteed.
- You are responsible for keeping your account details, including user name and password, confidential and secure.
How long do we keep your personal information?
- We will only retain personal information for as long as we consider, in our reasonable opinion, to be necessary to comply with applicable law or for the relevant purposes (as set out in this policy).
- When we no longer need your personal information, we will where reasonably possible seek to delete, destroy or de-identify it in accordance with our record retention policy and any applicable laws.
Checking, Updating or Changing the Information Polar 993 Holds
- We take reasonable steps to ensure that all information we hold is as accurate as possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.
- You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
Concerns and Complaints
- If you have any concerns about whether we have complied with the Privacy Act or this Privacy Policy when collecting or handling your personal information, please write to the Privacy Officer, Polar 993, Level 5, 476 St Kilda, Melbourne, VIC 3004, who will treat your complaint promptly and confidentially and escalate to the Compliance Officer as required. The Privacy Officer may be contacted at compliance@polar993.com
- We will consider your complaint through our internal complaints resolution process and we will try to respond with a decision within 30 days of receiving such a complaint.
- If you are not satisfied with the manner in which we deal with your complaint you may refer it to the Office of the Australian Information Commissioner (OAIC). You can contact the OAIC Online: by visiting www.oaic.gov.au, Email: enquiries@oaic.gov.au, Phone: 1300 363 992 or Mail: GPO Box 5218 Sydney NSW 2001
Consent
- By asking us to assist with your investment needs, you agree that we may collect and use your personal information for the purposes described above.
Tell us what you think
- We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact us.
Privacy Collection
- “Personal information” is any information that can identify you or that can reasonably enable your identity to be determined. At Polar 993 we are committed to protecting your privacy.
- Polar 993 may collect personal information (including sensitive information) from you or a third party through a number of different ways (e.g. application forms, third parties that verify your identity) and for a range of reasons, depending on our particular dealings or interactions with you. The types of information collected by Polar 993 may include:
- your name, date of birth, address, email address or other similar contact details;
- documents to confirm your identity including passport, driver’s licence, tax file number and other government issued documents;
- information regarding your finances and financial status; and
- gender, marital status, solvency records and criminal history.
- Polar 993 may also be required or authorised by law to collect certain personal information from you and/or disclose your personal information. For example, we may be required to collect and disclose certain information in order to comply with the identification and verification requirements imposed under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth). For certain investors, Polar 993 may also be required to collect and disclose certain personal information to the Australian Taxation Office in order to comply with the Foreign Account Tax Compliance Act.
- We use the personal information to:
- process and administer your application for investment in any Polar 993 funds or managed investment schemes;
- provide you with promotional information updates regarding Polar 993 or invitations to events, subject to our legal obligations and your ability to opt out;
- maintain your contact details;
- fulfil our legal obligations, such as those relating to taxation and anti-money laundering and counter-terrorism financing;
- establish, administer, manage evaluate and improve our products and services (including monitoring, auditing, and evaluating those products and services);
- manage and administer any investment you make in the Polar 993 funds or managed investment schemes and otherwise perform its duties as a trustee or responsible entity;
- model and test data (in a controlled environment);
- develop scores, risk assessments and related analytical tools; and
- communicate with you and deal with or investigate any complaints or enquiries.
- If you do not provide the personal information requested by Polar 993 or provide incomplete or inaccurate information, Polar 993 may not be able to accept or process your application for investment in the Polar 993 funds or managed investment schemes, may be limited in the services Polar 993 can provide with respect to the administration of any investment you subsequently make in the Polar 993 funds or managed investment schemes or may not be able to properly respond to your queries or requests for information.
- We may share personal information within Polar 993, and may disclose personal information outside Polar 993:
- as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator;
- to our service providers, who provide services in connection with our products and services (including but not limited to archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, data processing, data analysis, information broking, mailing, marketing, research, investigation, insurance, identity, verification, maintenance, trustee, securitization, website and technology services); and
- as contained in the terms and conditions of our product or service.
- We may also disclose your personal information (on a confidential basis) in connection with the undertaking of our principal investment activities including, but not limited to the management of any parts of our business or assets, and the provision of any debt to another party. However, we will take all reasonable steps to ensure that they protect your information in the same way that we do.
- In some circumstances the parties to whom we disclose personal information may operate outside of Australia – this includes locations in: Austria; Brazil; Canada; China; Denmark; France; Germany; Hong Kong; Israel; India; Indonesia; Ireland; Japan; Luxembourg; Malaysia; Mexico; Netherlands; New Zealand; Philippines; Russia; Singapore; South Africa; South Korea; Spain; Switzerland; Taiwan; Thailand; United Arab Emirates; United Kingdom; United States of America, but may include other locations in future. Circumstances in which we will do this include where:
- you have asked us to or we have your consent to do so;
- we have outsourced a business activity or function to an overseas service provider;
- we reasonably believe that the overseas recipient is subject to a law or binding scheme that protects the information in a way that is substantially similar to the way the information is protected under the Privacy Act and the Australian Privacy Principles, and there are mechanisms you can access to take action to enforce that protection; or
- the disclosure is required or authorised by or under an Australian law or a court/tribunal order.
- Please note that the laws on processing personal information in other countries may be less stringent than in Australia. When we disclose your personal information overseas, we will take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia, including the Australian Privacy Principles.
- We may from time to time use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you. We will always give you the option of electing not to receive these communications and you can unsubscribe at any time by notifying us that you wish to do so.
- For queries or information regarding privacy matters please contact the Polar 993 Privacy Compliance Manager, who can be contacted at compliance@polar993.com
- Our Polar 993 Privacy Policy contains information about how you can access and seek correction of personal information held by Polar 993, how you can make a complaint to Polar 993 about a breach of the Privacy Act 1988 (Cth), and how Polar 993 will respond to and deal with such a complaint.
- The Polar 993 Privacy Policy and this Privacy Collection Statement sets out details of how Polar 993 will collect, store, manage, use and disclose personal information it collects. The Polar 993 Privacy Policy is available from us on request.