Rights to privacy
Paragon IM Pty Ltd (‘Paragon’, ‘we’ or ‘our’) understands the importance of protecting an individual’s right to privacy. This privacy policy sets out how we aim to protect the privacy of your personal information, your rights in relation to your personal information managed by us and the way we collect, use and disclose your personal information.
In handling your personal information, we are required to comply with the Privacy Act 1998 (Cth) (‘Act’) and the ten National Privacy Principles (‘NPPs’) under the Act. This policy may be updated from time to time.
What kinds of personal information does Paragon collect?
Personal information is information that identifies an individual or from which an individual’s identity can reasonably be ascertained. During the provision of our services, we may collect your personal information.
Generally, the kinds of personal information that we collect are your name, date of birth, address, telephone number, e-mail address, IP address, driver’s licence details, passport details, tax file number, bank account and credit and/or debit card details as well as any other information that may be required under Australian anti-money laundering legislation for identification and other purposes. In some circumstances, we may also hold other personal information provided by you.
We may also collect statistical information relating to your use of this website, including:
- your server address;
- your top level domain name (for example .com, .gov, .au, .uk etc);
- the pages you accessed and documents downloaded;
- the website you visited immediately prior to accessing this website; and
- the type of browser you are using.
Is sensitive personal information collected?
Paragon will not collect sensitive personal information from you. Sensitive personal information is information about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information, biometric information or biometric templates.
How does Paragon collect personal information?
Generally, we collect your personal information directly from you, by requesting that you provide your personal information when you fill out an application form or other similar document or submit information to us via our website. There may be other occasions when we collect your personal information from you or from other sources, such as from a publicly maintained record or from an information services provider.
Why do we need your personal information?
We collect your personal information for the purposes of:
- providing access to our website and other related services;
- responding to queries you submit to us;
- facilitating our internal business operations;
- providing you with information about our products or services that may be of interest to you;
- processing your investment application and establishing your investment in our funds or products;
- administering any investment you have with us, including communicating with you about your investment;
- advising the Australian Tax Office and other governmental authorities of your tax file number;
- making deposits of distributions to your nominated bank account;
- accounting, billing and other internal administrative purposes;
- complying with our legal requirements under any applicable laws, including the anti-money laundering legislation; and
- any other legal requirements which we must comply with.
You are under no obligation to provide your personal information to us. However, without receiving certain information from you, we may not be able to provide our services to you.
Who do we disclose your personal information to?
We disclose your personal information for the purpose for which we collect it. That is, generally, we will only disclose your personal information for a purpose related to the provision of funds management services or any related purposes. The types of organisations to which we may disclose your personal information to include:
- your financial advisers or other professional advisers;
- any third party service provider which we may engage to provide custody, administration, technology, auditing, mailing, printing or other services;
- Government authorities where required to by law; and
- our professional advisers (including legal and accounting firms, auditors, consultants and other advisers).
Security of your personal information
We will take reasonable steps to ensure that the personal information we hold is protected against misuse, loss, unauthorised access, modification or disclosure.
Can you access or correct the personal information that we hold about you?
Under the Act, you have a right to access your personal information that is collected and held by us. If at any time you would like to access or change the personal information we hold about you, or you would like more information on our approach to privacy, please let us know.
To obtain access to your personal information, we may request that you provide us with proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected.
We will take all reasonable steps to provide access to your personal information within 30 days from your request. In less complex cases, we will attempt to provide information within 14 days.
If providing you with such access requires a detailed retrieval of your personal information, a fee may be charged for the cost of such retrieval and supply of information.
What happens if personal information security is breached?
We implement corrective plans if our security measures are breached or your personal information is lost or inadvertently accessed by an unauthorised person. You and the Privacy Commissioner will be advised if we assess the data breach is likely to cause you serious harm.
Notifiable Data Breaches
Paragon is required to notify individuals and the Office of the Australian Information Commissioner (OAIC) about ‘eligible data breaches’.
An eligible data breach occurs when the following criteria are met:
- there is unauthorised access to or disclosure of personal information held by us (or information is lost in circumstances where unauthorised access or disclosure is likely to occur);
- this is likely to result in serious harm to any of the individuals to whom the information relates; and
- we have been unable to prevent the likely risk of serious harm with remedial action.
We will conduct an assessment if it is not clear if a suspected data breach meets these criteria. The assessment will determine whether the breach is an ‘eligible data breach’ that triggers notification obligations.
Additional information
Further information on privacy in Australia may be obtained by visiting the website of the OAIC at www.oaic.gov.au. We regularly review their website to keep informed of issues and developments in privacy law and changing legal obligations.
How to contact us
For further information or enquiries regarding your personal information, please contact Bennelong Funds Management at client.experience@bennelongfunds.com or call 1800 895 388.
Privacy complaints
Please direct all privacy complaints to Paragon in writing.
At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and us.
Upon receipt of your complaint, we will commence an investigation into your complaint.
You will be informed of the outcome of your complaint following the completion of the investigation.
In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Federal Office of the Privacy Commissioner.