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We recognise that your privacy is important to you. This policy has been prepared by KM Property Funds Ltd and its related entities (‘KM Property Funds’) to provide you with how we protect your privacy and how we comply with the requirements of the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles. This policy also describes:
KM Property Funds Ltd is the responsible entity of managed investment schemes (‘Funds’) and holds Australian Financial Services Licence (AFSL 442806).
In the course of providing investment management services we may collect:
In some circumstances, we may also hold other personal information you provide to us. Your personal information will be used to identify you, process your application, establish and manage your investment and maintain our records or a related purpose, which would reasonably be expected without your permission. KM Property Funds may not be able to do these things without your personal information.
We collect personal information from you in a variety of ways, including: when you interact with us electronically or in person; when you access our website; and when we provide our services to you. For example, we may request that you provide your personal information when you fill out an application form for one of our Funds or submit information to us via our website. By completing the application form, you consent for the purpose of the Spam Act 2003 (Cth) to receiving commercial electronic messages and other promotional communications from KM Property Funds or any other entity associated with KM Property Funds.
We may also receive personal information by direct communication including email, letters, over the telephone and through financial transactions. There may be other occasions when we collect your personal information from you or from other sources, such as from your authorised financial adviser or our related bodies corporate. We will only do so where it is not reasonable and practical to collect the information directly from you.
Your personal information is held in an internal client management system and in a registry system maintained by a third party specialist registry service provider. Generally your personal information is stored electronically with hard copy records retained and archived with an archival service provider. The external service provider is contractually required to hold personal information in accordance with the Privacy Act.
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our uses of personal information include but are not limited to:
We may also need to collect personal information in order to comply with our legal obligations, such as the AML/CTF laws, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
Your personal information may be disclosed to tax and regulatory authorities, service providers who provide services in connection with your investment to KM Property Funds (e.g. Registry, technology administration and mailing services) or KM Property Funds may provide information about you to your nominated financial adviser.
We only collect sensitive information reasonably necessary for one or more of these functions or activities if we have the consent of the individuals to whom the sensitive information relates, or if the collection is necessary to lessen or prevent a serious threat to life, health or safety or another permitted general situation.
We may from time to time use your personal information to inform you of investment opportunities or to provide information about products and services, which we expect, may be of interest to you. However, if you do not wish this to occur, we are happy for you to inform us by contacting the Privacy Officer (contact details below) and we will not send this information to you.
We do not disclose your personal information to overseas recipients at this time. We will notify you if circumstances change regarding overseas disclosure and will comply with the Act in all relevant aspects.
Access to and use of personal information within KM Property Funds is appropriately limited to prevent misuse or unlawful disclosure of the information. Where information collected is no longer required, we delete the information or permanently de-identify it. As a general rule, the retention period is 7 years from the date of final invoice or closure of fund.
We take all reasonable steps to protect your personal information – ensuring the personal information we hold, use and disclose is accurate, complete and up‑to‑date. These steps include ensuring that the personal information is accurate, complete and up-to-date at the time of collection and when using or disclosing the personal information.
On an ongoing basis we maintain and update personal information when individuals advise us or when we become aware through other means that their personal information has changed.
Please contact us if any of the details you have provided change. You should also contact us if you believe that the information we have about you is not accurate, complete or up-to-date.
Under the Australian Privacy Principles, you may request access to the personal information we hold about you, or request that we change the personal information, by contacting us which we may need to verify your identity. In the case of access and correction requests, please provide as much detail as you can about the particular information you seek, in order to help us locate it.
We will provide the reasons if your request for access to or correction of personal information is denied. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.
When you visit our website KM Property Funds does not directly collect information from users of the website. Your email address will not be recorded unless you send us a message. It will not be automatically added to a mailing list.
KM Property Funds does not try to identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the service provider's logs.
Where you contact us, we may store information such as your name, company, postal address, telephone number, type of request and possible further information to enable us to respond to your request. We will only use such personal information for the purpose for which it has been provided.
We will not provide your information to any organisation outside KM Property Funds nor will we send you information related to our products without your approval.
Cookies As is very common for companies, we use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. We use cookies to improve the experience of people using our website. You can configure your web browser to reject cookies, but you then may not be able to use all or part of our website.
Third party websites The KM Property Funds share registry may collect information from users of their website on our behalf. Where such information is collected, the share registry will request the information from you directly. Neither the registry nor KM Property Funds will release your personal information to anyone outside KM Property Funds without your permission. We recommend you review the Privacy Statement contained on the share registry website to obtain full details of that company's privacy policy.
If you wish to make a complaint about a breach by us of the Australian Privacy Principles, you may do so by providing your written complaint by email, letter, or by personal delivery to any one of our contact details as noted below. You may also make a complaint verbally. Where you express any concerns that it has interfered with your privacy, we will respond to let you know who will be handling your matter and when you can expect a further response.
We will respond to your complaint within a reasonable time (usually no longer than 20 days after receipt of the complaint). We may seek further information from you in order to provide a full and complete response.
If you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner who may investigate your complaint further.
Please be aware that we may change this Privacy Policy in the future. The revised versions will be uploaded onto our website, so please check back from time to time.
You can contact us about this Privacy Policy or about your personal information by contacting:
Privacy Compliance Officer KM Property Funds Ltd GPO Box 2985, Melbourne, VIC, 3001 Email: [email protected] Telephone: +61 3 8623 3333
If you have any complaints about our privacy practices, please feel free to send in details of your complaints to:
Complaints Officer KM Property Funds Ltd GPO Box 2985, Melbourne, VIC, 3001 Email: [email protected] Telephone: +61 3 8623 3333