Privacy

Collection of Personal Information

The type of personal information DeGroup collects and holds depends upon its dealings with relevant individuals. It includes:

names; addresses; birth dates; telephone numbers; email addresses; financial information; trust or fund name; bank account details; tax file numbers; any information that is required to be collected by law.

DeGroup only collects personal information that is reasonably necessary for its dealings with relevant individuals.

DeGroup usually collects personal information directly from the individuals it deals with. However, DeGroup may collect such information from third parties, for example an individual’s agent, where this is reasonably necessary to allow DeGroup to deal with the individual. In such circumstances DeGroup will take reasonable steps to inform the individual that it holds the individual’s personal information, unless that is apparent from the circumstances in which the information is provided.

If DeGroup inadvertently collects unsolicited personal information from an individual we will, within a reasonable time after collecting any such personal information, determine whether or not we may have collected it in any event under APP 3. If we determine that we could not have collected the personal information, we will, as soon as practicable and where it is lawful and reasonable to do so, destroy the personal information or ensure that it is de-identified.

You do not have to identify yourself (or you may choose to use a pseudonym) when dealing with DeGroup, except where:

• DeGroup is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have not identified themselves; or
• it is impracticable for DeGroup to deal with individuals who have not identified themselves.

DeGroup does not generally collect sensitive personal information (including that relating to religious views, personal health, ethnicity or political opinion). However, in certain circumstances DeGroup may collect some sensitive information if it is reasonably necessary to allow DeGroup to deal with the individual and the individual has provided consent to DeGroup to do so.

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For what purpose do we collect Personal Information?

We are authorised to collect tax file numbers by tax law. It is not compulsory for you to provide your tax file number in order to receive all of our services but, if you don’t, tax law requires us to deduct tax from your distributions at the highest marginal rate. We do require tax file numbers for our mortgage investments as, without them, the trustee may incur substantial withholding tax liabilities.

We may use your personal information for direct marketing purposes. If you do not wish to receive marketing communications from us, you can let us know by e-mailing or telephoning us at the contact address below.

We will not use or disclose your personal information for any purpose other than as set out in this policy, or for a related purpose in circumstances where you would reasonably expect such use or disclosure, where you have consented to such use or disclosure or in circumstances otherwise authorised by the APPs.

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To whom do we disclose Personal Information?

Personal information about an individual is not disclosed to anyone without the consent of the individual concerned or where required by law, except in the following circumstances:

• As DeGroup outsources certain functions such as its securities registry and custodial services, it needs to disclose investor personal information to these entities.
• The need to disclose personal information to others is generally restricted to consultants such as auditors, accountants and lawyers, insurance companies, property managers and estate agents, and is consistent with normal business practices and service delivery.
• DeGroup may sometimes disclose personal information to overseas recipients. However, DeGroup will only do so in accordance with the APP’s.
• To assist in locating a missing person.
• To establish, exercise or defend a legal or equitable claim.
• For the purposes of a confidential alternative dispute resolution.
• Where necessary to lessen or prevent a serious threat to any individual’s life, health or safety or to public health or safety, and it is unreasonable or impracticable to obtain your consent.
• Where necessary in order for DeGroup to take appropriate action in relation to a reasonable suspicion of unlawful activity, or misconduct of a serious nature.

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Cookies

Our web site may use cookies which allow us to identify your browser while you are using our site.  Cookies do not identify you; they simply allow us to track usage patterns so that we can measure the level of interest in various areas of our site. Most web browsers are set up to accept cookies. You can re-set your browser to refuse all cookies or to receive a warning message with each cookie which you can then refuse by turning it off in your browser. Your internet service provider should be able to assist you to set your preferences.

Unless you provide an e-mail address in the course of your visit to our website, we cannot identify you.

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The security of your Personal Information

We treat your personal information as confidential. Access to our premises is controlled by allowing only personnel with security passes to access the premises. All electronically held information is protected through the use of firewalls and access passwords on each computer.

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Updating and accessing your Personal Information

DeGroup takes reasonable steps to correct personal information to ensure that, having regard to the purpose for which the information is held, it is accurate, up-to-date, complete, relevant and not misleading if either:

• DeGroup is satisfied that it needs to be corrected, or
• an individual requests that their personal information be corrected.

If you become aware of, or believe at any time that information we hold about you is inaccurate, incomplete or outdated, you may contact us by any of the methods set out below and provide us with evidence of the inaccuracy, incompleteness or out datedness. We will, if we agree that the information requires correcting, take all reasonable steps to correct the information.

In most cases, you are entitled to access your personal information. We will endeavour to respond to any request for access within two to four weeks, depending on the complexity of the information or the request. Under the APPs, access can be denied in certain circumstances. We will give you our reasons for denying access if we do so. If the request is complex or time consuming, we may charge a fee for giving you access.

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