Licensee: Acumen Investors Pty Ltd (‘Acumen Investors’)
Australian Financial Services Licence (‘AFSL’) Number 526 972
1. OBJECTIVE OF THE POLICY
The objective of the policy is to define how Acumen Investors will deal with investor information.
2.INTRODUCTION
Under the legislation, an organisation must set out in a document clearly expressed policies on its
management of personal information. The organisation must make the document available to anyone who asks for
it. On request by a person, an organisation must take reasonable steps to let the person know, generally,
what sort of personal information it holds, for what purposes, and how it collects, holds, uses and
discloses that information. Where an individual requests access to personal information that the
organisation is holding about them, a reasonable fee may be charged for the provision of this information.
This must not be excessive and must not be charged in relation to the lodgement of the application (that is,
a lodgement fee).
3.RESPECTING YOUR PRIVACY
Acumen Investors understands that you are concerned about how we deal with your private and financial
information. Our aim is to deliver the best possible service and we will only collect the information
necessary to enable us to do so. Acumen Investors’ websites will not collect information about individuals
using our websites except where it is knowingly provided. In order to provide financial services to our
investors, we need to request and retain some personal information. This allows us to process applications,
administer your accounts and provide you with information. We may also use your personal details to
communicate with you about products and services and comply with relevant laws. We consider all information
about our investors to be private and confidential. These laws regulate the way organisations:
4. HOW WE COLLECT YOUR PERSONAL INFORMATION
Wherever practicable, Acumen Investors will collect information about you directly from you. We generally
collect your information when you complete the Application Forms for various providers of services. We may
also collect information directly from you on the phone or via electronic means such as an email.
However, it may be necessary at times to collect information about you from other external sources, such as:
5. WHAT KIND OF INFORMATION WE will COLLECT AND HOLD
To establish and administer your account, and to comply with relevant legislation, we may collect all or
some of the following:
6. THE PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED, HELD, USED AND
DISCLOSED
Generally, we only use and disclose information about you for the purpose for which it was disclosed to us
or related purposes which would reasonably be expected. Those purposes include:
7. HOW WE STORE YOUR PERSONAL INFORMATION
We store your personal information in a variety of ways which includes both electronic and paper form. The
security of your personal information is paramount and we take reasonable steps to protect it from misuse,
interference, loss, unauthorised access, modification or disclosure. We do this in a number of ways
including:
- Document security policies
- Confidentiality requirements of our employees and contractors
- Security measures for access to our systems
- Restricting access to personal information only to persons who require access to carry out their responsibilities;
- Secured access to our offices; and
- Electronic security systems such as firewalls and data encryption on our websites.
8. TO WHOM MAY WE DISCLOSE YOUR INFORMATION
There are circumstances under relevant legislation where we are required to disclose certain information and
there are other circumstances where some information may also be provided. We may be required by law to
disclose your personal information. For instance, we may be required to provide details to:
We may also provide some information to market research companies for the purpose of analysing our client base. We may provide our clients’ contact details to market research companies to undertake research on behalf of Acumen Investors. For example, we may run investor satisfaction surveys, or run focus groups on proposed products or services. These agencies must return all records of this information to Acumen Investors. Acumen Investors retains ownership of this information and will ask you if you do not wish to receive further information. You can contact us at any time if you no longer wish us to contact you for marketing purposes.
9. OVERSEAS DISCLOSURE
We may need to share some of your information (including credit information) with organisations outside
Australia. We may store your information in “the Cloud” or other types of networked or electronic storage.
As electronic or networked storage can be accessed from various countries via an internet connection, it’s
not always practicable to know in which country your information may be held. If your information is stored
in this way, disclosures may occur in those countries. Overseas organisations may be required to disclose
information we share with them under a foreign law. In those instances, we will not be responsible for that
disclosure.
10. DATA QUALITY – KEEPING YOUR PERSONAL INFORMATION UP TO DATE
Acumen Investors relies on the accuracy of the personal information provided by its clients. We aim to
ensure that it is accurate, up-to-date and complete. If any of your details change, or you have any concerns
regarding its accuracy you should contact us.
11. HOW AN INDIVIDUAL MAY ACCESS THEIR PERSONAL INFORMATION AND SEEK ITS
CORRECTION
You may request access to any personal information we hold about you. We reserve the right to charge a
reasonable fee to cover our costs. Generally, if it is incorrect, we will correct it at your request.
However, this is subject to some exceptions allowed by law, for example:
- If access to information would pose a serious threat to the life or health of an individual;
- if access to information would have an unreasonable impact on the privacy of others;
- if the request is frivolous or vexatious;
- if the information relates to a commercially sensitive decision-making process;
- if providing access would be unlawful;
- if access would prejudice enforcement activities relating to criminal activities or a security function;
- if providing access would reveal the intentions of Acumen Investors in relation to negotiations with you in such a way to prejudice those negotiations;
- denying access is required or authorised by or under law.
12. COMPLAINTS ABOUT A BREACH OF THE AUSTRALIAN PRIVACY PRINCIPLES
If you believe that we have mishandled your personal information, in turn, breaching the Australian Privacy
Principles, you can seek to have the issues addressed. You should initially contact Acumen Investors in
writing with the details of your complaint, together with the rectification you are seeking. The complaint,
addressed to the Privacy Officer, must be in writing in accordance with the Privacy Act 1988. Refer to
section 13 for contact details for our Privacy Officer. From receipt of your written complaint, the Privacy
Officer has 45 days to respond. In the event that the Privacy Officer is unable to resolve your complaint,
you may lodge a complaint with the Information Commissioner.
You can lodge a written complaint with the Information Commissioner by:
Submitting an online form or hard copy through the Information Commissioner’s
website: www.oaic.gov.au; Email at enquiries@oaic.gov.au
13. CONTACTING ACUMEN INVESTORS
If you have any questions relating to this privacy statement, or concerns about the way in which we have
handled your personal information, please do not hesitate to contact us at;
The Privacy Officer, Acumen Investors Pty Ltd
PO Box 707 Chatswood NSW 2057
Tel: +61280051218
Email: contact@acumeninvestors.com.au; Re: Privacy Policy
.