The privacy of your personal information is important to K2 Asset Management Ltd ('K2'). We are committed to maintaining the privacy and confidentiality of your personal information.
Collection of Personal Information
What is personal information?
Under the Privacy Act 1988 (Cth) personal information is defined as information or an opinion, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. It includes your name, age, gender, contact details and financial information.
Why we collect information
We collect personal information so that we may:
- administer our investor and potential investor relationships;
- make, maintain and manage investments for an investor including in any K2 Fund from time to time;
- provide information to the responsible entity and the administrator and custodian of a K2 Fund or of your investment;
- unless the investor or potential investor informs us otherwise, to provide information on our products and services including future products and services we may offer.
We may also use personal information for other purposes such as:
- assisting our investors and potential investors with queries;
- in conducting reviews or audits of our processes and systems; and
- taking measures to detect and prevent frauds.
What personal information we collect
We collect personal information on investors and potential investors through application and other forms, phone, fax and email. The personal information collected includes:
- Name, gender, marital status and date of birth
- Contact details
- Identification/ passport details
- Tax file number, exemption reason, nationality or country of residenceBank account information
- Investment information
Dealing with Personal Information
How we deal with personal information
As part of administering and managing your investments we may disclose the personal information we collect to other organisations which are involved in providing, administering or managing the investments or any K2 Fund such as the responsible entity, custodian and administrator, auditors and any other relevant service provider. Some of these organisations are located outside Australia.
From time to time we may also use and disclose personal information when seeking expert help to improve our processes, systems, products and services. These third parties and organisations are or will be bound by confidentiality agreements when handling your personal information.
Disclosure to Financial Adviser, Authorised Representative and other representatives or agents
If you:
- used a financial adviser who recommended your investment in a K2 Fund; or
- nominated an Authorised Representative (as indicated on your application form) to act on your behalf,
then details of your investments may be provided to your current financial adviser or Authorised Representative as the case may be.
Where you have provided your consent, we may also provide personal information to your representatives or agents including your legal advisers and accountant.
Disclosure required by law
We may be authorised or obliged to disclose information by law for example, when we are served with a court order. We may also be required by an enforcement body, a government agency or regulator to produce information and records, for example, pursuant to taxation or social security laws.
Accuracy of Your Personal Information
We aim to ensure that the personal information we keep about you is accurate, complete and up-to-date. Please contact us (see "Our details and Contacting Us on Privacy" below), if any details you have provided change or if you believe that the information we have about you is not accurate, complete or up to date.
Security of Your Personal Information
We are committed to keeping secure the personal information you provide to us. Our security measures include but are not limited to:
- restricting access to our computer systems and physical records to authorised persons;
- requiring employees to use unique passwords to gain access to systems; and
- providing secure storage for physical records.
Access to Your Personal Information
You can request us to provide you with access to the personal information we hold about you by writing to us (see "Our details and Contacting Us on Privacy" below). We will respond to your request as soon as possible and there is no charge to make a request or to access your personal information.
Access to your personal information is subject to some exceptions allowed by law. Factors affecting a right to access include:
- access would have an unreasonable impact on the privacy of others;
- the information relates to a commercially sensitive decision making process;
- access would be unlawful;
- access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function or negotiations with you;
- legal or dispute resolution proceedings; or
- denying access is required or authorised by law.
If we deny access to your personal information, we will let you know why in writing.
Jointly held Information
Where we hold your personal information in conjunction with that of another person (eg. where you jointly conduct or hold an account), we will allow each individual access to their own personal information and to the joint information (eg account balances and transaction details) but not to the personal information of the other individual(s).
Changes to How We Manage Privacy and Personal Information
We may change the way we manage privacy and personal information and this privacy policy from time to time for any reason. We may publish those changes and any updated privacy policy on our website.
Our Details and Contacting Us on Privacy
If you have any questions, complaints about our privacy and information handling practices or would like further information on our privacy and information handling practices, you can contact us:
By Mail
The Client Services Manager
K2 Asset Management Ltd
Level 32, 101 Collins Street
Melbourne 3000
By Telephone
Client Services Manager on (03) 9691 6191 (9am to 5pm Monday to Friday)
By Fax
Client Services Manager on (03) 9691 6170
By email
information@k2am.com.au
For more information about privacy in general, you can visit the Federal Privacy Commissioner's website www.privacy.gov.au
