Ironbark Asset Management Pty Ltd (ABN 53 136 679 420) (Ironbark) and its related bodies corporate has practices in place to comply with the Australian Privacy Principles (“APPs“) set out in the Privacy Act 1988 (Cth) (Privacy Act).
- What personal information does Ironbark collect?
- How does Ironbark collect and store personal information?
- How does Ironbark use your personal information?
- How will personal information be disclosed to others?
- How can you access or correct your personal information?
- How can you complain if you have concerns about how Ironbark has managed your personal information?
- What can you do if you have not received a reason to your complaint or are unhappy with the outcome?
WHAT PERSONAL INFORMATION DOES IRONBARK COLLECT?
Personal information is information or an opinion about you from which you can be reasonably identified. The personal information that Ironbark may collect will depend on the circumstances of collection, including whether we collect the information from you as a customer, supplier, contractor, stakeholder, job applicant or some other capacity.
Ironbark collects personal information so that we can provide you with our financial products and services and comply with our legal obligations such as those under taxation laws, the Corporations Act and Anti-Money Laundering and Counter-Terrorism Financing Act. If Ironbark does not collect your personal information, we may not be able to provide you with a financial product or service.
The financial product or service we are providing will also determine what information we will collect about you. Some personal information that Ironbark may collect and hold about you includes: your name, contact details, date of birth, citizen ship, tax file number (TFN), employment details, financial information and banking details. In some cases, we may collect information about your family (eg details about your spouse, dependents or beneficiaries where we are providing you with the relevant services).
In addition, Ironbark may collect personal information about individuals who are not customers eg business contact details of a company representative with home we deal with.
In the context of recruitment Ironbark may collect and hold the following kinds of personal information about you: your name, contact details, date of birth, citizenship, employment references, civil, credit and criminal records, regulatory accreditation (such as RG146 qualification), media (including social media), directorships, property ownership, government issued documentation (eg Driver’s licence, passport or Medicare details) and credential information.
If the employment context, Ironbark may also collect and hold the personal information listed above, as well as your TFN, financial information, banking details and other personal information that may be collected in your use of Ironbark’s systems or assets. This information may be collected to assist us monitor compliance with our internal policies and perform other necessary functions and activities.
Generally, we will not collect sensitive information about you (such as your race, political beliefs or religion). We may collect information bout your health if necessary to provide you with a financial product or service. If we need sensitive information, we will ask for your consent when we collect this information, where no exemption applies. There may also be circumstances, for example, in the employment context, where we will ask to sight sensitive information, such as, your current vaccination status, in relation to Covid-19 or another relevant virus. Once sighted, we will not retain this information on our database.
HOW DOES IRONBARK COLLECT AND STORE PERSONAL INFORMATION?
Depending on how you choose to interact with us, we may collect your personal information when you contact us or our service providers by telephone, email or digitally through our website or social media channels, complete an application form or when you meet one of our Ironbark representatives.
Ironbark may collect information about you from third parties. For example, Ironbark may collect personal information from:
- our service providers;
- your employer;
- corporate clients, where we are providing services;
- referees, in the case of prospective employees.
Information collected through Ironbark’s website
Ironbark may collect information based on how you use Ironbark’s website or digital media. Ironbark uses “cookies”, analytic tools and other data collection methods to collect anonymous information on website users and their activities. Cookies are small text files that are placed on your computer by the websites that you visit. Cookies are widely used in order to make websites work or for efficiency, as well as to provide information to the owner of the website.
Information Ironbark collects may include (but is not limited to) how the website is found, which pages are viewed, the frequency a visitor may come to the website. This information is combined into an overall picture of the nature of the person who uses our website and does not individually identify you.
This information is collected for use within Ironbark and by preferred vendors for our analysis, to measure the success of our digital advertising and social media, and to improve our ability to provide relevant information and content to users.
No attempt is made by Ironbark to personally identify you, except when you submit a digital form. If you complete and submit a form on our website, a social media channel, you agree to enter your information onto those platforms. The information we collect is stored, accessed and used by us to administer those platforms as required.
If you access your account information online through a secure area, we will collect information about your visit using cookies to track your use of our website. This information is collected for security purposes and to protect the integrity of your account details. This principle applies if your secure information may be accessed by an agreed third-party provider that may host your information on behalf of Ironbark. You can authorise third parties (such as, your financial adviser) to have access to your information on a secure website; terms and conditions apply in these circumstances.
Securing personal information
Ironbark holds your personal information in secure computer storage facilities (both in-house and with our service providers); on paper-based files; as well as in other formats. Ironbark takes all reasonable steps to protect your information from loss and unauthorised access, destruction, use, modification, or disclosure. Access to personal information held by ironbark is controlled to prevent misuse or unauthorised disclosure of that information. Ironbark have implemented a range of technical security measures such as secure authentication, password controls, encryption, firewalls and anti-virus technology to prevent unauthorised access to your information. Any vendor engaged by Ironbark is required to comply with similar protection measures.
HOW DOES IRONBARK USE YOUR PERSONAL INFORMATION?
Ironbark may collect, hold, use or disclose your personal information to provide you and our corporate clients with a range of financial products and services such as:
- Establishing and managing your investment in our investment funds;
- Providing our corporate clients with trust, fund or fiduciary services; or
- Participation in an event that is hosted by Ironbark.
We may also collect, hold, use or disclose your personal information to:
- Consider any feedback (including a complaint) that you raise with or involving Ironbark;
- Prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
- Identify you or establish your tax status under any Australian or foreign legislation;
- Comply with any relevant laws, regulations, codes of practice and court orders; or
- Consider applicants for employment or business programs.
Personal information collected about you may be used by different companies within the Ironbark group, but only if it is necessary for Ironbark to provide you with our financial products or services.
Ironbark may use your personal information collected to identify a financial product or service that may be of interest. If at any time you no longer wish to be notified about other services, please contact us. Privacy specific contact details are included at the end of this policy.
We may use your information for other purposes required or authorised by or under law and regulation (including purposes for which you have provided your consent).
HOW IS PERSONAL INFORMATION DISCLOSED TO OTHERS?
Ironbark does not sell, rent or trade personal information to, or with, third parties. In some circumstances your information will be disclosed to Ironbark’s related parties or service providers that perform a range of services on our behalf. Examples include:
- Mailing house or printing service
- Custodian and administrators
- Registry and platform providers
- Auditors and solicitors
- Insurance providers
- Information technology service providers
- Other consultants.
When we disclose your information to our service providers, we will take all reasonable steps to ensure they are authorised to only use personal information in order to perform the functions required by Ironbark.
Depending on the nature of the financial product or service that Ironbark provides, we may disclose your personal information to your nominated representative (such as, your financial adviser) and their respective service providers.
We may also disclose your personal information to law enforcement agencies, courts or government agencies where required to comply with specific legal requirements.
With your consent, we may disclose your personal information to other third parties and for other purposes. That consent may be written, verbal or implied from your conduct.
HOW IS PERSONAL INFORMATION DISCLOSED TO OTHERS?
You may contact us to request access to the personal information we hold about you at any time. You may also ask us to correct information that you consider is inaccurate, incomplete or out of date. When doing so we will need to verify your identity before giving you access or correcting your information. In certain circumstances, Ironbark may not be able to correct or provide you with access to your information. In these circumstances, we will write to you to explain and provide the reason why this access cannot be granted.
HOW TO COMPLAIN ABOUT HOW YOUR PERSONAL INFORMATION IS MANAGED?
Where you may have a complaint relating to how Ironbark has managed your personal information, please contact us using the information below. Resolving your concerns may require Ironbark to share your personal information with third parties in this process, including our service providers or regulatory bodies. We acknowledge that any privacy related complaint will be acknowledged within a business day of being received and we will make every effort to resolve your issues as quickly as possible thereafter.
If we cannot resolve your complaint within 30 business days, we will contact you to advise you of the maximum response timeframe for your complaint.
WHAT SHOULD YOU DO IF YOU HAVE NOT RECEIVED A RESPONSE TO YOUR COMPLAINT WITHIN THE MAXIMUM RESPONSE TIME OR YOU ARE UNHAPPY WITH THE RESPONSE?
If a complaint remains unresolved or you are unhappy with the outcome, you may contact the Australian Financial Complaints Authority (AFCA) or apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined.
When we write to you about your complaint decision, we will explain how you may access an external dispute resolution scheme or make a complaint to the OAIC.
The OAIC may be contacted on 1300 363 992.
AFCA may be contacted as follows:
Phone 1800 931 678
Address Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001
NEED FURTHER INFORMATION?
Privacy Officer, Ironbark
Level 14, 1 Margaret Street, Sydney NSW 2000
© Copyright March 2022 – Ironbark Asset Management Pty Ltd (ABN 53 136 679 420)