2. Personal information we collect
Generally, we only collect personal information that is reasonably necessary for, or directly related to, one of more of the functions and activities of our business. For example, we may request that you provide your personal information when you instruct us to provide services, acquire products, invest with us or interact with us, e.g., via our website. There may be other occasions when we collect personal information about you or from other sources, such as from our related entities, a publicly maintained record or from an information services provider. We may also share personal information about you with our related entities or third parties in connection with the operation of our business.
The types of personal information we collect may include:
- Names, occupation, contact and address details.
- Information in identification documents (e.g., passport or driver’s licence details).
- Information about shareholders, beneficiaries and beneficial owners.
- Tax file numbers and other government-issued identification numbers.
- Date of birth and gender.
- Financial, asset and investment related information.
- Bank account details.
We do not collect or hold sensitive information, such as health information, racial or ethnic origins, religious affiliation or political opinions. Personal information held by us is not organised by Government related identifiers.
3. Collection and use of personal information
3.1 How we collect personal information
Generally, we will collect your personal information directly from you, e.g., when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a form, questionnaire or survey or when you use our website or our social media. Your personal information may also be collected as part of the identification and verification activities we conduct on you or persons related to you, such as beneficial owners.
Sometimes it may be necessary for us to collect personal information from a third party. For example, we may collect your personal information from a publicly available record, from an information provider, from your personal representative or a relation. We may also collect personal information about you from your use of our website and information you provide to us through any registration process on our website.
3.2 Providing personal information about someone else
3.3 Holding personal information
In the event you cease to be a client or investor of RAG, personal information we hold about you will be maintained for at least as long as we are required to comply with any legislative requirement. After that time, we may destroy your personal information or put it beyond use, e.g., de-identify the personal information so it cannot be used to identify you.
3.4 Purpose for collecting, holding and using personal information
RAG collects, holds and uses personal information for a number of purposes including:
- To provide products and services.
- To respond to requests or queries.
- To provide you with information about our products or services, such as marketing material.
- To operate our business, including entering details on a register of members and performing compliance reviews or audits.
- To maintain contact and keep you informed of our services, updates, industry developments and events.
- To verify your identity and otherwise comply with Australia’s anti-money laundering laws.
- For administrative purposes, including to process applications, distributions and payment transactions.
- For recruitment purposes and matters relating to the employment of our personnel, providing internal services or benefits to our staff.
- When engaging service providers, contractors or suppliers relating to the operation of our business.
- To manage any conflict of interest.
- For seeking your feedback or to conduct surveys.
- To meet any legal or regulatory obligations, e.g., providing the Australian Taxation Office with tax file numbers.
- As part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including RAG’s business) or entering into an alliance, joint venture or referral arrangement.
- To perform internal statistical analysis, including of our databases and website.
- For any other business related purposes.
If you do not provide us with the personal information we have requested, we may not be able to complete or fulfil the purpose for which such information was requested or collected, including providing you with the services or products we were engaged to perform.
3.5 Disclosure of personal information
The types of third parties to whom we may disclose your personal information include:
- Our employees; contractors, real estate agents and service providers.
- Your financial advisers or other professional advisers.
- Any third party service provider that we may engage to provide due diligence, compliance, custody, administration, technology, auditing, mailing, printing or other services.
- Service providers to verify your identity.
- Government authorities such as the Australian Taxation Office or the Australian Securities and Investments Commission where required to by law or where reasonably requested.
- Our professional advisers, including experts, legal and accounting firms, auditors, consultants and other advisers.
- As part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including RAG’s business) or to enter into an alliance, joint venture or referral arrangement.
- Our related bodies corporate or any other company within the RAG group.
We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you.
4. Information storage and security
We take reasonable security measures to ensure that the personal information we hold is protected from misuse, loss and unauthorised access, modification or disclosure, including physical security measures.
We store personal information in our computer databases and we may also utilise the services of third party storage providers, which store data in the ‘cloud’ or in an overseas country, e.g., United States, North America, Asia, European Union or any other country in which the provider or its affiliates, subsidiaries or service providers maintain facilities. In the event that your personal information is held in an overseas country the information will not be protected by the Australian Privacy Principles. By providing your details, you consent to your information being disclosed and held in this manner.
Various security measures are in place to safeguard personal information, including restricted staff access, password restricted access and internet based security tools (e.g., multi-factor authentication, firewalls and virus protection programs). Despite this, as our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
5. Privacy on our website
5.1 Automatic collection of personal information
Cookies and other technologies may be used by us on our website and through email to automatically collect certain types of information. The collection of this information allows us to customise your online experience, market products and services to you, improve the performance, usability and effectiveness of our online presence and to measure the effectiveness of our marketing activities.
5.2 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It is not linked to personally identifiable information. We may use IP addresses to analyse trends, administer the website, track user’s movement, and gather broad demographic information.
When you access our website, we may send a “cookie” which is a small data file that is transferred to your computer when you allow your web browser to accept a cookie. This enables us to recognise your web browser. It also enables us to keep track of your activity on our website for a period of time. Cookies also make it easier for you by saving your passwords and preferences.
5.4 Location-based tools
We may collect and use the geographical location of your computer or mobile device when you access or use this website. This location data is collected for the purpose of providing you with information regarding services or products which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
5.5 Social media features
Our website may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any RAG social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
5.6 Links to third party websites
5.7 Your choice
You have several choices regarding your use of our website. In general, you are not required to provide personal information when you visit our website. However, if you apply to receive information about our services, events and updates, wish to acquire products or services or apply for a job, provision of certain personal information will generally be required.
We understand the importance of protecting children’s privacy, especially in an online environment. In particular, our website is not intentionally designed for or directed at children under the age of 18. It is our policy to never knowingly collect or maintain information about anyone under the age of 18, except as part of a specific engagement to provide services or products that necessitates such personal information being collected.
7. Accessing your personal information
You can request access to your personal information, subject to some limited exceptions permitted or required by law. Such requests must be made in writing to our Privacy Officer. If we decline your request for access, we will provide a written explanation to you for the refusal.
Upon confirmation of your identity, we may provide you with access to information by either providing you with copies of the information requested or allowing you to inspect the information. We may charge reasonable costs for providing you access to your personal information.
We will not provide you with access to 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 (if applicable).
8. Correcting your personal information
We will take reasonable steps to ensure that the personal information we collect is accurate, up to date and complete. If you provide evidence to us that the personal information we hold about you is inaccurate, incomplete or out of date, then we will take all reasonable steps to correct it.
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 our Privacy Officer and provide details of your complaint in writing. We will try to resolve any concerns you may have to your satisfaction within a reasonable time (usually 30 days). If you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner (telephone 1300 363 992) who may investigate your complaint further.
10. More information
We are required to comply with the Privacy Act, which contains the Australian Privacy Principles. A summary of the Australia Privacy Principles, a copy of the Privacy Act and additional information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.
12. Our contact details