Your privacy is very important to us.
Wenlock Capital Pty Ltd (‘Wenlock’) recognises the importance of ensuring that its clients have confidence in the way Wenlock handles personal information. This document sets out the policy of Wenlock for management of personal information.
We are committed to ensuring the privacy of your information and recognise that you are concerned about your privacy and about the confidentiality and security of information that Wenlock may hold about you.
Wenlock Capital Pty Ltd (“Wenlock Capital”) abides by the Australian Privacy Principles (APPs) which is a part of the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988. This privacy statement is made on behalf of Wenlock Capital as investment manager of the Wenlock Global Fund (the ‘Fund’). The Responsible Entity for the Fund is Equity Trustees Pty Ltd
INFORMATION WE COLLECT
As a financial services organisation and to administer the Fund, we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/ or contains information about you (“personal information”).
The information we collect from you will depend on what services we provide to you and may include the following:
your full name, address and contact details;
your e-mail address;
your tax file number;
bank account details;
identification and verification information;
personal financial information about your assets, liabilities, investment preferences and risk profile; and
details of specific transactions.
2. CONSEQUENCES OF NOT PROVIDING INFORMATION
If you do not give us your personal information, we may not be able to provide details of the products and services we offer.
If you elect not to provide us with the personal information referred to above; we may elect to withdraw our services if we believe we are unable to provide you with a complete service.
3. OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION.
We are committed to being open and transparent about how we use personal information. We will generally state the purposes for its use and to whom it may be disclosed. If any of our documents do not clearly state the purposes for which we will use your personal information please ask us and we will clearly explain them to you.
We will not use your personal information for any purpose other than for which it was originally collected, unless you have given us your consent to do so, or unless it is reasonably expected that we will use the information for another purpose (a secondary purpose). An example of a secondary purpose is providing information in a court of law or dispute resolution.
Should we receive personal information that we have not asked for, we will establish whether the information could have been assessable and contained in a Commonwealth record and if the collection of this personal information was reasonably necessary or directly related to our service. Should the above not apply, we will as soon as practicable destroy the information.
While we may send you marketing material from time to time that we think will be useful to you, we are conscious of the need to respect your privacy. Unless you are informed otherwise, the personal information we hold is used for informing you of any relevant information relating to your holding of units in the Fund, enhancing customer service and giving you ongoing information about Wenlock Capital.
If, at any time, you do not wish to receive this information, you may contact us with this request. We will endeavour to meet your request within 2 weeks. We maintain a register for those individuals not wanting direct marketing material. Please refer to the end of this document for our contact details.
Wenlock Capital takes its obligations to protect your information seriously, this includes when we operate throughout Australia and overseas. As part of our operations some uses and disclosures of your information may occur outside your State or Territory and/or outside of Australia. We will obtain your consent prior to doing so.
4. INFORMATION COLLECTION POLICY
We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us. Generally, collection of your personal information will be effected in either face to face interview, over the telephone or by way of an online client engagement form. From time to time additional and/ or updated personal information may be collected through one or more of these methods. We will only collect, maintain and use personal information about you if it is necessary for us to adequately provide to you the services you have requested including:
Accounting for financial products transactions;
Causing statutory audits to be conducted as required by law;
Maintenance and service of our information technology systems; and
In the course of reviews by external consultants
5. INFORMATION DISCLOSURE
We will not use or disclose personal information collected by us for any purpose other than:
the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure;
where you have consented to such disclosure;
where the National Privacy Principles authorise use or disclosure 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.
This may involve the disclosure of your personal information. We are also obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission.
We may use the personal information collected from you for the purpose of providing you with direct marketing material, however you may, by contacting us by any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow two weeks for your request to be actioned.
We may disclose your personal information to external contractors for the following purposes:
audit of company accounts; and
compliance framework review.
6. STORAGE OF PERSONAL INFORMATION
Your personal information is generally held in your client file. Information may also be held in a computer database. 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 and any sensitive information is treated as highly confidential. All record movements off premises are recorded in a central register. After hours access to our premises is controlled by allowing only personnel with security passes to access the premises. All computer- based information is protected through the use of access passwords on each computer. Data is backed up and stored securely off site. In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in a secure off-site storage facility, and destroyed after an appropriate period of time that complies with legislative and professional requirements (usually 7- 10 years).
7. ACCESS TO YOUR PERSONAL INFORMATION
You may at any time, by contacting us by any of the methods detailed below, request access to your personal information and we will (subject to the following exceptions) provide you with access to that information either by 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, prior to providing access in accordance with this policy, require you to provide evidence of your identity.
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. We will not provide you with access to your personal information if:
(a) providing access would pose a serious threat to the life or health of a person; (b) providing access would have an unreasonable impact on the privacy of others; (c) the request for access is frivolous or vexatious; (d) the information related to existing or anticipated legal proceedings between us, and would not be discoverable in those proceedings; (e) providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations; (f) providing access would be unlawful; (g) denying access is required, or authorised by or under law; (h) providing access would be likely to prejudice certain operations by, or on behalf of an enforcement body, or an enforcement body requests that access not be provided on the grounds of national security. We will endeavour to respond to any request for access within 14 to 30 days depending on the complexity of the information and/ or the request. If your request is urgent please indicate this clearly. In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal.
8. CORRECTION OF PERSONAL INFORMATION
We will endeavour to ensure that, at all times, the personal information about you which we hold is up to date and accurate. In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate, incomplete or outdated, you may contact us by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness or out datedness and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.
10. ADDITIONAL PRIVACY INFORMATION
Further information on privacy in Australia may be obtained by visiting the web site of the Office of the Federal Privacy Commissioner at www.privacy.gov.au.
11. CONTACT DETAILS
If you have query relating to our privacy practices, please contact us at:
Wenlock Capital Pty Ltd
Level 2, 22 Atchison Street