Privacy Policy

ARCO Investment Management Pty Ltd (ARCO) is committed to safeguarding the personal information that we receive.  We will hold personal information in confidence in accordance with the Australian Privacy Principles (“APPs“) and the Privacy Act 1988 (Cth) as amended (“Privacy Act“).

What is personal information?

Under the Privacy Act, personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

What personal information do we collect and why do we collect it?

We (through the registrars of our funds) may collect personal information from the investor (including your staff or representatives) in the funds.  This information includes, but is not limited to, name, date of birth, contact details, Tax File Number, home address, country of residence, investment information and bank account information.  We collect this information to facilitate your investment in the relevant funds and to comply with relevant laws, for example anti-money laundering and counter terrorism financing laws.  We usually collect this information directly from you (or from your staff or representatives. However, in certain circumstances, ARCO may collect personal information about you from third parties, such as your financial adviser, the Administrator or third-party service providers of ARCO.

We also collect information about individuals who are, or who are employed by, our shareholders, potential shareholders, service providers, advisors and suppliers. We may collect information about other individuals we deal with in our day to day business.

We usually only collect business or work contact details. If individuals deal with us in their personal capacity we will collect the other information we need to provide our products and services. We collect this information to facilitate the relevant business purpose.  We may also collect personal information from people who send us correspondence.  Information collected includes name and contact details.  We collect this information to deal with correspondence.  We collect this information directly from the relevant individuals and not from third parties.

We will not generally collect sensitive (for example information on race, religion) or health information.

What if the information is incomplete or inaccurate?

ARCO may not be able to process your application to subscribe to the funds or provide you the services you are seeking.

How do we use and disclose personal information?

We use an investor’s personal information to process and administer their investment in our funds.  We may disclose the information to our service providers including our administrators, any third-party service provider it may engage to provide custody, administration, technology, auditing, mailing, printing or other services and their professional advisers (including legal and accounting firms, auditors, consultants and other advisers).

The service providers, including such third parties, may use and disclose your personal information for a purpose described in this Privacy Statement. The disclosure by ARCO of personal information to such third parties may involve the transfer of your personal information to recipients located outside of Australia. Where this is the case ARCO will take reasonable steps to satisfy itself that the third party that ARCO discloses the information to is compliant with the Australian Privacy Principles or a similar regime. In providing ARCO with your personal information, you consent to the possibility that your personal information may be transferred outside of Australia for processing or the other purposes detailed above and for receiving additional information about the full range of services offered by ARCO including subscribing to our newsletters.

Where we disclose information to a third party, confidentiality arrangements will be in place.

ARCO may also collect certain personal information from you and/or disclose your personal information to government or regulatory bodies where permitted or required to do so by law. For example, ARCO may be required to collect and disclose certain information in order to comply with the identification and verification requirements imposed under the AML/CTF Act. For certain investors, ARCO may also be required to collect and disclose certain personal information to the Australian Taxation Office in order to comply with FATCA and CRS.

How do we protect the confidentiality of personal information?

We will take reasonable steps to ensure that any identifiable personal information that we have collected is stored securely.  The measures utilised include password protection to our systems, restricting access to our systems and education of staff.

Our website

You are not required to provide us with any personal information when visiting our website.

When you visit our website, or download information from it, our Internet Service Provider makes a record of your visit and records the following information: your internet address, your domain name if applicable, the date and time of your visit to the website, the pages you accessed and documents downloaded, the previous website you have visited and the type of browser you are using. This information is only used for statistical and website development purposes.

We make limited use of cookies on our website. A cookie is a small message given to your web browser by our web server. The browser stores the message in a text file, and the message is then sent back to the server each time the browser requests a page from the server. We only use cookies to improve the functionality of our website, not to store any of your personal information.

Most Internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer, giving you the choice whether to accept it or not.

Access to personal information, corrections and complaints

You have a right to access any personal information we hold about you (although there are some exceptions to this) and correct any personal information that may be incorrect by contacting ARCO at the address below. We may deny such a request in some circumstances, if we do this we will explain why.

Please note that the personal information we hold about you will be information that you (or your representative) have provided.

ARCO will respond to requests for access or correction within a reasonable time. ARCO may ask you to pay its reasonable costs of responding to your request.

You may also make a complaint to ARCO concerning a breach of the Privacy Act by writing to the address below.  We will acknowledge your complaint within 10 Business Days of receipt and will endeavour to resolve the complaint within 30 days.

Additional information

ARCO may change this Privacy Policy at any time. We will make this Privacy Policy available to anyone who requests it, free of charge, either at our offices or through our website.

For further information about privacy issues, see the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

If you have a privacy concern, complaint or query, please contact +61 (3) 9660 9500 or by mail at:

Privacy Officer, ARCO Investment Management Pty Ltd

Level 2, 121 Flinders Street

Melbourne Vic 3000

Email:  privacy.officer@ARCOim.com

Telephone: +61 3 9660 9500