1. Purpose of the policy

Equitable Investors Pty Ltd (Equitable Investors) understands the confidentiality of your personal information is important to you. Equitable Investors is committed to protecting the privacy of personal information obtained through its business activities and has practices in place to comply with the Australian Privacy Principles (APPs) [and the Notifiable Data Breaches (NDB) scheme] under the Privacy Act 1988 (Cth).

Personal information is any information about you that identifies you and/or contains information or an opinion about you.

2. Why we need your Personal Information and how we use it

Equitable Investors and its trusted partners may collect personal information that is reasonably necessary for, or directly related to, its functions or activities.

The "primary purpose" (the dominant or fundamental purpose for which that information is collected) is to establish, manage and provide our products and financial services.

Specifically, we collect information to provide services including:

• Management of our various investment funds (Managed Investment Schemes);

• Wealth management and portfolio administration services; and

• Stockbroking and trade execution services.

In order to fulfill that primary purpose, information may be required for the purpose of assessing your application and meeting legal and regulatory requirements, such as compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act, the Corporations Act and Australian taxation laws

Equitable Investors may use and disclose personal information about you so that we may:

• provide you with our products and services;

• keep you updated in relation to our funds' developments and activities;

• let you know about other products or services we offer, send you information about special offers or invite you to events  (including opportunities across our related entities and new funds);

• protect our business and other customers from fraudulent or unlawful activity;

• verify your identity using electronic means;

• consider any concerns or complaints you may have; and

• comply with relevant laws, regulations and other legal obligations

3. What kinds of Personal Information we may collect and hold

The specific types of information we collect... may vary depending on particular circumstances. In general, however, personal information Equitable Investors may collect and hold includes (but is not limited to) the following:

• your name, title and date of birth;

• contact details (including relevant addresses and telephone numbers);

• identification details, including government-related identifiers (such as... drivers licence or passport details);

• bank account information , financial records , and tax file number;

• transactional information including your trading history, contract notes, and portfolio valuations;

• market settlement details including Holder Identification Numbers (HINs) or Securityholder Reference Numbers (SRNs);

• nature of your business activities  [and your status as a "wholesale client" (as defined in the Corporations Act 2001);

• information received from you that may contain additional personal information, such as family relationships; and

• qualifications, memberships and other accreditations.

Sensitive information

Sometimes we need to collect and use sensitive information... including information or an opinion relating to a person’s racial or ethnic origin... political views... or criminal record. Unless you give us your consent, or if we are required or permitted by law, we will only use or disclose sensitive information for the purposes for which it was provided

4. How we collect Personal Information

Equitable Investors and our trusted partners only collect personal information that has been directly provided to us by our clients... associates of clients... or is otherwise available in the public domain where this information will assist us with the provision of services.

Recording of Communications

We may record telephone conversations with you, particularly those regarding trade instructions, stockbroking orders, or wealth management advice. This is to ensure accuracy, resolve disputes, and comply with our monitoring and record-keeping obligations under market integrity rules.

Using our websites 

Our website may use cookies to identify site users and their interests. We may also collect technical data such as your IP address, device type, and geographic location to administer our digital platforms. You may adjust the security settings in your web browser to limit the collection of such information

5. Notification of the collection of Personal Information

When we are provided with personal information about an individual from a third party, we seek to ensure the individual is aware of certain matters, such as Equitable Investors' identity, the fact that the information has been collected and consequences of not having collected the information.

6. Disclosure of Personal Information

Personal information is not disclosed to a third party unless the disclosure is necessary to support the delivery of the client services or is required by law.

The types of organisations we might disclose your personal information to include:

• The Australian Taxation Office (ATO) and other government bodies;

• Market operators (such as the ASX and Cboe) and clearing houses;

• Third-party clearing and settlement participants (brokers who execute or clear trades on our behalf);

• Investment platform operators and custodians holding assets on your behalf;

• Share registries;

• Our custodian, fund administrators, financiers, accountants and auditors, legal advisers, information technology providers and other professionals

Overseas disclosures

We may disclose personal information to recipients that are located outside Australia in some circumstances. These recipients may be located in the Philippines 

We also store electronic records (which may contain personal information) locally in Australia or on secure "cloud" storage facilities provided by operators with appropriate security regimes in place. It is not practical to list all of the countries in which the cloud storage servers are located, however they are likely to include the United States of America, and certain countries in Europe and Asia. 

7. How we store your Personal Information

Equitable Investors will take all reasonable steps to protect against the loss, misuse and/or alteration of the information under its control, including through appropriate physical and electronic security strategies.

We utilize a range of modern security practices to protect personal information, which may include:

• Appropriate physical security for our premises;

• Secure passwords and the use of Multi-Factor Authentication (MFA) for access to key systems/services;

• Data encryption where appropriate (both at rest and in transit);

• Secure "cloud" storage provided by operators with appropriate security regimes; and

• Regular staff training on cybersecurity threats and scams.

Only authorised Equitable Investors personnel and trusted third parties are provided access to personal information. When we consider information is no longer needed, we will destroy or de-identify these records.

8. Data breaches

In the unlikely event that a data breach occurs which is likely to result in serious harm to you (an "eligible data breach"), Equitable Investors will notify you and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act. We maintain a Data Breach Response Plan to manage such incidents effectively.

9. Accuracy of Personal Information

Equitable Investors will take all reasonable steps to make sure that any personal information collected, used or disclosed is accurate, complete and up to date. Under the Australian Privacy Principles, a person has the right to request access to any personal information that we may hold about them. Our policy is to provide written acknowledgement  within seven days and a written response within 30 days.

10. Contact Equitable Investors about Privacy

If you wish to make an enquiry about your personal information at Equitable Investors, or make a complaint because you believe that we may have breached the Australian Privacy Principles or a privacy code that applies to us, please contact us in one of the following ways:

• email our nominated Privacy Officer at privacy@equitableinvestors.com.au

• write to The Privacy Officer, Equitable Investors Pty Ltd, PO Box 18106, Melbourne, Victoria, 3001

We will respond to each request within a reasonable time. 

If a party has lodged a complaint with Equitable Investors and is not satisfied with our response, they may contact:

The Office of the Australian Information Commissioner (OAIC)

• Website: www.oaic.com.au

• Phone: 1300 363 992

11. Review

This policy will be reviewed by the Board of Directors of Equitable Investors Pty Ltd (“the Board”) at least annually or as circumstances change. The nominated Policy Officer will be responsible for regular review throughout the year and for recommending changes to the Board.