Apostle Funds Management Pty Limited (AFSL No. 458375) (“Apostle”) is committed to safeguarding the personal information that they receive. Apostle will hold it in confidence in accordance with:

The Australian Privacy Principles (“APPs”) in the Privacy Act 1988 (Cth) as amended (“Australian Privacy Act”) if you are an Australian resident; and

The Information Privacy Principles in the Privacy Act 1993 (“New Zealand Privacy Act”) if you are a New Zealand resident.

What is personal information?

Under the Australian 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. Under the New Zealand Privacy Act personal information is any information about an individual (a living natural person) as long as that individual can be identified.

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

Apostle (through the registrars of the relevant products or solutions) may collect personal information from investors in Apostle investment products and solutions from the investor (including their staff and representatives). This information includes, but is not limited to, name, date of birth, contact details, gender, Tax File Number, country of residence, investment information and bank account information. We collect this information to facilitate your investment in the relevant product or service and to comply with relevant laws, for example anti-money laundering and counter terrorism financing laws. We collect this information directly from the investor (or their staff and representatives) and not from third parties.

Apostle may also collect personal information from people we do business with in order to fulfil the relevant business purpose. This will usually happen when we collect the name and business contact details of a person who is an adviser, supplier or other business contact. We collect this information to facilitate the relevant business purpose. Apostle 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?

Apostle may not be able to provide you with the products or services you are seeking.

How do we use and disclose personal information?

We use an investor’s personal information to facilitate their investment in the investment product or service. Investors are deemed to have consented to such information being processed for the purposes referred to above and for receiving additional information about the full range of services offered by Apostle and its affiliates (you will need to email Apostle if you do not want to receive this additional information). Other personal information will be used to facilitate the business purpose for which it is provided. Apostle may disclose the information to its affiliates and service providers. Where we disclose information to a third party, confidentiality arrangements will be in place.

Personal information may be disclosed to the relevant investment manager of the Apostle investment product or service, who may be located overseas. The country they are located in will be set out in the relevant offering document. Apostle will not generally disclose any personal information to any other overseas party.

Apostle may be required by relevant laws to disclose personal information to a regulator (such as the Australian Taxation Office) or to a court or tribunal.

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

Our website may collect non-personal information when you visit our website. Our website also uses cookies. A ‘cookie’ is a packet of information that allows the server (the computer that houses the web site) to identify and interact more effectively with your computer. This information does not typically identify individual users and it is unlikely to be personal information.

Links to other websites

Our website may have links to external third party websites that may benefit the user. External websites should contain their own privacy statements and we recommend you review them when using their websites. Please note, however, that third party websites are not covered by our Privacy Policy and these websites are not subject to our privacy standards and procedures.

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 Apostle 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.

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

You may also make a complaint to Apostle concerning a breach of the Australian and New Zealand Privacy Acts by writing to the address below. We will acknowledge complaints and provide a final response within 45 days of receipt of the complaint

Additional information

Apostle 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 or New Zealand Privacy Commission at www.privacy.org.nz.

If you have a privacy concern, complaint or query, please contact +61 (2) 8278 9554 or by mail at:

Privacy Officer
Apostle Funds Management Pty Limited
Level 14, 50 Pitt Street
Sydney NSW 2000