About this policy
We recognise your privacy is important to you. This policy has been produced by Quattro Asset Management to provide you with information on the collection, storage, use and disclosure of your personal information by Quattro Asset Management and its related companies (“Quattro Asset Management”). When referring to personal information, we mean information or a statement of opinion about a person whose identity is apparent or can reasonably be ascertained.
Quattro Asset Management abides by the National Privacy Principles established under the Privacy Amendment (Private Sector) Act 2001. A summary of the National Privacy Principles is available by contacting our office. Our contact details are provided at the end of this document.
Information collection policies
As a financial services organisation, we are subject to legislative and regulatory requirements that we obtain and hold the personal information of clients. Information we hold about you may include things such as your contact details, bank account details and tax file numbers.
We will not collect any personal information about you unless you have knowingly provided that information to us or authorised a third party to provide that information to us.
Information use and disclosure policies
We will not use or disclose personal information collected by us for any purpose other than:
(a) the purposes for which it was provided or a related secondary purpose where you would reasonably expect us to use or disclose the information; or
(b) where you have consented to such disclosure; or
(c) where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.
We are obliged under the Corporations Act 2001 to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission. In addition, we may contract external parties to conduct due diligence, compliance or financial audits. This may involve the disclosure of your personal information.
If you choose to invest in a scheme promoted by us, your information may be used to:
(a) Advise the Australian Tax Office (ATO) of your tax file number. If you choose not to provide us with your tax file number, tax may be deducted from you by the ATO, at the highest marginal tax rate.
(b) Enter your details on the register of the members of the scheme, which is available for inspection in accordance with the Corporations Act.
(c) Communicate with you about your investment.
(d) Make deposits of distributions to your nominated bank account.
(e) Provide details to mortgage providers and your bank in accordance with your express authority.
We may use the personal information collected from you for the purpose of providing you with direct marketing material that may be of interest to you, however you may request not to receive such information and we will give effect to that request. Please allow two weeks for your request to be actioned.
Your personal information may be provided to other companies within the Quattro Asset Management. It is a condition of our agreements with each of our representatives and staff that they adopt and adhere to this privacy policy. If you have any concerns in this regard, you should contact us.
Document storage and security policies and practices
Your personal information is generally held in computer databases.
We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential. All computer-based information is protected through the use of access passwords on each computer, and data is backed up each evening and stored securely off site.
In the event you cease to be a Quattro Asset Management client, any personal information we hold about you will be maintained on site or in a secure off site storage facility for up to seven years in order to comply with legislative and professional requirements. After that time the information will be destroyed. Please note that if you are an investor in a syndicate or scheme, your records will be maintained for a period of seven years after the termination of that syndicate or scheme.
Gaining access to your personal information
You may request access to your personal information at any time and we will require you to provide evidence of your identity prior to providing access in accordance with this policy. We will provide you with access to information by either providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held.
We will not provide you access to personal information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result.
The National Privacy Principles place other restrictions on accessing your personal information. Restrictions include where the provision of access would have an unreasonable impact on the privacy, or would pose a serious and imminent threat to the health, or any individual; the request for access is frivolous or vexatious; or the provision of access is unlawful or would be likely to prejudice a criminal investigation.
If we decline your request for access, we will provide you with an explanation for that refusal.
We will try to ensure that, at all times, the personal information we hold about you is accurate and up to date. If you can show us that the personal information we hold about you is inaccurate, incomplete or outdated, and we agree that the information requires correcting, we will take all reasonable steps to correct it.
How a privacy complaint may be made
We are committed to providing you with a fair and responsible system for handling complaints. If at any time you have any complaints in relation to privacy, please contact us. We will try to resolve any concerns you may have to your satisfaction within seven days, however if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.
Additional information about privacy in Australia may be obtained by visiting the web site of the Office of the Federal Privacy Commissioner at www.privacy.gov.au
Quattro Asset Management
(ABN 55 115 913 810 AFSL 299074)