Centennial Asset Management Privacy Statement
This Privacy Statement is made on behalf of Centennial Asset Management (ACN 605 827 745) (“Centennial”) and its related bodies corporate.
Centennial recognises an individual’s right to privacy and understands the protection and confidentiality of your personal information is important to you.
Centennial is bound by the Privacy Act 1988 (Cth).
This Privacy Statement outlines the type of personal information we collect, how that information is collected, used, stored and protected, and to whom we may disclose your personal information. We may also provide you with additional information about how Centennial will use your personal information at the time that it is collected.
Any information that identifies you is deemed to be “personal information” and we primarily collect this when you complete the application form for units in a Fund, the Trustee, the Custodian, the Administrator and any other entity involved in the administration of the Fund and their respective agents (in this section, we or us), as well as any information you provide through our website, and when you phone or contact our staff.
The type of personal information Centennial collects from you includes – your name, contact details (such as your address and telephone number), date of birth, investment details, bank account information and tax file number. The Corporations Act 2001 (Cth) requires us to collect your name, address and date of birth. The Government’s anti-money laundering laws may also mandate us to collect additional personal information from you.
When browsing our website Centennial’s webservers may automatically collect standard information as part of the HTTP web protocol – your IP address, browser type, operating system, access times, referring sites, pages viewed and other anonymous information.
Centennial uses your personal information to administer your investment, comply with relevant laws and communicate with you on an ongoing basis about your investment and the market.
Centennial may use information that you provide through our website or over the phone for analysis to improve our products and services.
Staff may also use personal information to verify your identity over the phone.
In some circumstances Centennial may disclose your personal information to persons/entities outside of Centennial. For example:
- Centennial uses agents and external service providers to help us provide our services to you (such as our registry provider, mailing houses, printing companies and external consultants).
- From time to time we may be required to provide your details to a governmental or regulatory body (such as ASIC, ATO, AUSTRAC, or a law enforcement agency).
- A court order may require us to disclose certain information.
Centennial takes steps to ensure that our agents and third parties keep your personal information confidential and use it only for the purposes for which they, and Centennial, are authorised.
You may also authorise us to disclose information we hold about you to your financial adviser, administrator or other person nominated by you. Your express consent is required. If you nominate an individual contact within an Advisory firm or Administrative firm, Centennial deems (in order to protect the privacy of our Investors) that you give authority to the firm and not the individual contact.
Exemptions Note: Centennial intends to rely on some of the exemptions permitted under the Privacy Act. For instance, the exemption for disclosing personal information to our related bodies corporate. Similarly, the employer exemption relating to employee records (we have, however, adopted a number of measures designed to protect the privacy of our employees).
Centennial regards the security of your personal information as a priority and has a number of physical and electronic protection measures in place.
You should be aware that the Internet is not a secure environment. Whilst Centennial takes reasonable steps, we cannot guarantee the security of information you provide to us via our website or that we make accessible to you via the secure investor site. No personal data is stored on our public website. Personal data is stored on our secure investor site.
In many circumstances you can request access to personal information we hold about you. Sometimes it is not possible for us to give you access in which case we will explain why.
You may also ask us to correct information which we hold about you which is inaccurate, incomplete or out of date.
If you have any questions about this Privacy Statement, or wish to make a complaint about how Centennial has handled your personal information, or wish to access or correct your personal information held by us, please contact us:
Centennial Asset Management Pty Ltd
Gateway Building, Level 20
1 Macquarie Place, Sydney
Telephone: 02 8071 9215 / Email: firstname.lastname@example.org