- 1.How and why Ellerston Capital collects personal information
- 2.Will your personal information be given to anyone else?
- 3.How is your personal information stored?
- 4.Your right of access and correction
- 5.Online collection of personal and non-personal information
- 6.How you may access or correct your personal information?
- 7.Additional Privacy information & How to contact Ellerston Capital
1. How and why Ellerston Capital collects personal information
Ellerston Capital needs to collect personal information in order to conduct its business.
Investors: Ellerston Capital retains a number of service providers for custodian, registry and administration services. These service providers collect personal information about investors in Ellerston funds on behalf of Ellerston Capital.
Business contacts: Sometimes, Ellerston Capital needs to collect personal information from people we do business with. This will usually happen when we collect the name and business contact details of a person who is the contact in a government agency or company we deal with, or in one of our contractors or suppliers.
Website users: Ellerston Capital may also collect personal information through its website (for example, if you e-mail our webmaster with a question about our website).
Ellerston Capital’s policy is only to use personal information collected from its business contacts or the users of its website for the business purpose for which it was collected, and not for any other purpose.
We do not collect personal information that we do not need.
2. Will your personal information be given to anyone else?
Ellerston Capital will not sell, rent or trade personal information about you to or with others without your consent. Personal information collected by Ellerston Capital may be disclosed to related bodies corporate of Ellerston Capital (including, without limitation, Consolidated Press Holdings Limited) and third parties to whom we outsource specialised functions (such as mailing houses or printing companies), and if so, we take steps to ensure that those parties:
- comply with the NPPs when they handle personal information about you (regardless of whether they are a small business, and would otherwise be exempt from the NPPs); and
- are authorised only to use personal information in order to provide the services or to perform the functions required by Ellerston Capital.
The only other time Ellerston Capital would make disclosures of personal information is if we are required to do so by law, or if the disclosure is permitted under the Privacy Act.
3. How is your personal information stored?
Ellerston Capital takes physical, electronic and managerial steps to ensure that the personal information it holds is secure from unauthorised access, destruction, use, modification or disclosure. Ellerston Capital only permits your details to be accessed by authorised personnel, and we educate our staff about their responsibilities under the NPPs.
4. Your right of access and correction
Under the Privacy Act, you have the right to seek access to information which Ellerston Capital holds about you (although there are some exceptions to this). You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date.
Please note that the personal information we hold about you will be information that you have provided.
If you request, Ellerston Capital shall provide access to personal information to which you have a right of access under the Privacy Act. It will assist Ellerston Capital to process your request if you can specify the personal information you are seeking access to (e.g. by providing details of when you provided personal information to us, and in what context).
Ellerston Capital may ask you to pay its reasonable costs of responding to your request. Ellerston Capital’s policy is to consider requests for access or correction within a reasonable time.
5. Online collection of personal and non-personal information
Our website automatically collects other information when you visit our website. For example, for each visitor to our website, our server automatically recognises and stores the visitor’s domain name, but not their email address.
Our website contains links to other websites, for your convenience and information. When you access a website other than our website, please understand that Ellerston Capital is not responsible for the privacy practices of that site. We suggest that you review the privacy policies of each site you visit.
6. How you may access or correct your personal information?
“If you have a complaint related to how Ellerston Capital has managed your personal information, please contact us using the contact information below. We may ask you to place your concerns in writing in order for us to fully understand and investigate the issues you have raised. We will acknowledge any complaint in writing within five business days and make every effort to resolve your issue within a reasonable time of us being notified.
If a complaint remains unresolved, you may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. The Commissioner may be contacted on the privacy hotline: 1300 363 992.
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 OAIC.
7. Additional privacy information & How to contact Ellerston Capital
For further information about privacy issues, see the Australian Federal Privacy Commissioner’s website at www.privacy.gov.au.