Privacy Policy & Complaints

Privacy Statement

Paradice Investment Management Pty Ltd (ABN 64 090 148 619, AFS Licence No. 224158) (referred to below as Paradice, we, us, our) maintains a policy of strict confidence concerning any Personal Information that you provide to us. The meaning of Personal Information is discussed in section 1 below.

We are committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (together the Privacy Act). As part of our commitment and to explain how we collect, store, use and disclose your Personal Information, we have developed our privacy statement (Privacy Statement).

We have formulated this Privacy Statement on an “FAQ” – style basis to assist in your understanding of this Privacy Statement.

1. What Personal Information do we collect and hold?

“Personal Information” means information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. We may obtain Personal Information to provide you with our services and products, to manage our relationship with you or for such other purposes described in this Privacy Statement. The types of Personal Information we may collect include your full name, contact details (such as your residential address, telephone number and email address), date of birth, tax file number, Australian business number, your financial details (including bank account details) and interests and the products and services we have provided to you.

We collect Personal Information when you:

• visit our website (Website) to read or download information;
• contact us;
• make an enquiry about our products or services;
• become one of our clients;
• provide information for Anti-Money Laundering and Counter-Terrorism Financing purposes;
• communicate with our representatives and service providers; or
• participate in marketing activities

Sometimes, we may need to collect Personal Information about individuals who are not our clients (for example, business contact details of a company representative with whom we deal or your representative or agent, such as your accountant).

Generally, we will not collect sensitive information about you (such as your race, political or religious beliefs or your health) unless for some reason we need to do so in order to provide you with our products or services. If we do need sensitive information, we will seek your consent when we collect the information (unless an exemption applies).

Where you do not provide us with the Personal Information that we request, we may not be able to provide you with the full scope of our services and products.

2. How is Personal Information collected and stored?

This depends on how you deal with us and the products and services you might request from us.

We may collect Personal Information about you from an application form or verbally over the course of correspondence if you call us or speak directly with our staff. We hold the Personal Information in both physical and electronic storage facilities including paper-based files and computer and cloud databases. In addition, if you access the Website, this will mean that we will collect Personal Information electronically.

Some of our pages on the Website use “cookies”, which are small files that may be placed on your hard disk for record-keeping purposes. Cookies help us remember who you are and may collect and store your server address, top level domain name (e.g. .com, .gov, .net etc), the date and time of your visit, country your service address is located in, the type of browser you used, the pages viewed and any downloads made, the previous site you visited and the site you visited next.

Cookies can make your subsequent visits to the Website simpler and more efficient, for example, by saving site preferences. We may also use the information to assist in improving the Website, marketing and product development.

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. (However, by not accepting cookies, some pages on the Website may not display properly or you may not be permitted to access certain information.) A server cannot determine an individual’s name, email address, or any other personal information other than that noted above by using cookies.

Once we receive information from you, via email or any other means, the information is stored in a secure environment.

We take the security of Personal Information seriously and we take reasonable steps to protect the Personal Information we hold from loss, unauthorised access, interference, destruction, misuse, modification or disclosure using both physical and electronic security measures.

By providing us with your Personal Information over the internet you accept that such information will be transmitted at your own risk as the security of such information cannot be guaranteed.

3. How do we use the Personal Information we collect?

We use Personal Information only for the purposes for which it is collected. These purposes are:

• providing you with the relevant products or services requested (including verifying your identity and assessing your application);
• managing our relationship with you;
• managing and administering your investments;
• communicating with you about your investments;
• if you have requested it, sending you information about us and our products and services;
• the development of our products and services;
• marketing and research, including communicating with you about products and services which we believe may be of interest to you;
• statistical purposes;
• improving the content of the Website;
• general internal purposes;
• general product development; and
• complying with laws, regulations, rules, directions or requests from regulatory or government agencies.

We carry out our marketing activities in compliance with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth). We will only use Personal Information we collect from you to send commercial electronic messages or contact you by telephone for marketing purposes if you have provided your express or inferred consent.  If you would like to stop receiving marketing communications from us, please contact our Privacy Officer (details below) and you will be removed from our mailing list.

If it is no longer necessary for us to have your Personal Information, we will take reasonable steps to destroy it in a secure manner or remove identifying features from it. This is subject to any legal or regulatory obligation that we have to keep Personal Information for a specific period of time.

4. Will we disclose Personal Information?

This Privacy Statement is designed to maintain the confidentiality of all Personal Information we hold and prevent its misuse.

Personal Information may be disclosed or handled by parties other than Paradice where it is necessary in the provision of services to you and, in doing so, Paradice takes reasonable steps to ensure that any third party to whom Personal Information is disclosed is bound by confidentiality and privacy obligations. Circumstances where Personal Information may be disclosed include:

• for legal reasons, disclosures may need to be made to law enforcement agencies, government agencies, courts, tribunals, regulatory bodies or external advisers;
• in the public interest where, for example, a crime, fraud or misdemeanour may be committed or suspected;
• where disclosure is related to the supply of our products or services including to affiliated entities and financial institutions;
• to protect the rights, property or personal safety of a Paradice employee, affiliate, or another Paradice client;
• for accounting and audit purposes;
• where specifically requested or authorised by you, for example, to legal and professional advisers or employers;
• where some or all of the assets and operations of the business are or may be transferred to another party by way of sale of some or all of Paradice’s business; or
• with your consent – such consent may be implied or express and may be in verbal or written form.

We may disclose Personal Information to third parties to whom we contract out specialised functions, such as mailing houses, printing companies and professional advisers. If we do so, we take steps to ensure that those contractors comply with the Privacy Act and are authorised only to use Personal Information in order to perform the functions required by us.

Some of the third parties noted above may be located outside Australia, however, we will not transfer Personal Information overseas unless we have a reasonable belief that it will be collected, used or disclosed by the recipients in a manner consistent with this Privacy Statement.

5. How do I access, correct and update my Personal Information?

Under the Privacy Act, you generally have a right to seek access to information which we hold about you within a reasonable time of your request being made. However, in some circumstances, we may not be able to disclose this information. If we cannot provide information we hold to you, we will write to you to explain why we cannot do so.

You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. If you believe that the information we hold about you is incorrect or inaccurate, please notify one of our representatives as soon as you can. Following satisfactory identification, we will consider any requests for access in an appropriate and timely fashion.

In order to provide you with access to your Personal Information, we ordinarily require you to contact us by letter, email or telephone and outline the nature of your enquiry. For privacy and security reasons, we generally do not provide you with your Personal Information over the phone. In some circumstances we may not be able to provide the requested information to you or there may be a cost to doing so (for example where the information may be timely to compile). However, we will provide a response in writing either by mail or email as soon as possible.

We endeavour to keep and maintain the Personal Information we hold accurate, complete and up to date. You can assist us in our efforts by keeping us informed of any changes to your Personal Information by notifying us in writing as soon as possible. We may also ask you to review, confirm and advise us of changes to your Personal Information.

If you have any questions about this Privacy Statement, if you wish to complain about how we have handled Personal Information about you, or if you wish to access or correct your Personal Information, please contact our Privacy Officer. See section 10 below for the Privacy Officer’s contact details.

6. How do we keep Personal Information Secure?

As mentioned above, we will use reasonable steps to maintain a secure system for storing Personal Information. Technological and operational policies and procedures are in place to protect Personal Information from misuse and loss and from unauthorised modification or disclosure which include password controls, firewalls, multi-factor authentication and encryption.

We will not transfer Personal Information overseas unless we reasonably believe that it will be collected, used or disclosed by the recipients in accordance with this Privacy Statement.

We may retain Personal Information for longer than the minimum legal requirement where it is determined appropriate for operational, legal or service improvement purposes.

7. Do you use Government Identifiers?

We do not use tax file numbers, Medicare numbers or any other Government identifier for the purposes of identifying clients to whom we provide products or services. The only circumstance in which we may collect such information is where we are required by law to do so.

8. What about the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)?

In order to comply with this legislation, in most cases, we must obtain, verify and record Personal Information that verifies clients who wish to invest using our services. The Personal Information we collect for this specific purpose includes your full name, date of birth and residential address. We are obliged by law to store this information for a minimum of seven years. We will not disclose the Personal Information we collect for the purposes of this legislation to any third party unless:

• we have informed you of the recipients of your Personal Information and obtained your consent to disclose it to them; or
• we are obliged to disclose your Personal Information by law.

9. What about links and references to Third Party Websites?

The Website may contain links and references to third party websites. We encourage you to read the privacy policies or statements on these third-party websites as they may differ from ours.

If you are an investor in a registered managed investment scheme that we manage (Fund), the responsible entity of the Fund, Equity Trustees Limited (Equity Trustees), will also collect Personal Information from you.  The Product Disclosure Statement or Reference Guide for the relevant Fund will explain how you can access Equity Trustees’ privacy statement and contact them if you have privacy related concerns.

10. How do I contact your Privacy Officer?

Please contact our Privacy Officer if you:

• have any questions about this Privacy Statement;
• would like us to stop sending you communications;
• wish to make a complaint about how we have handled your Personal Information (including if you think we may have breached the Privacy Act); or
• would like to access or correct your Personal Information held by us.

Our Privacy Officer can be contacted at:

Paradice Investment Management Pty Ltd

Level 27, The Chifley Tower, 2 Chifley Square

Sydney NSW 2000

Telephone: +61 2 8227 7400

Email: investorrelations@paradice.com

When you contact us, please include your email address, name, address and telephone number and clearly describe your complaint. Our Privacy Officer will investigate the complaint and respond to you promptly.

11. What if you are still not happy?

As an Australian Financial Services licensee, Paradice is a member of an external disputes resolution scheme, the Australian Financial Complaints Authority (AFCA). AFCA may be able to assist with any complaints about privacy where it arises from one of our financial services, and we have not been able to resolve your complaint. You can contact AFCA on the details below:

Online: www.afca.org.au

Phone: 1800 931 678

Email: info@afca.org.au

Post: GPO Box 3, Melbourne VIC 3001

Our AFCA membership number is 62913.

You can also contact the Office of the Australian Information Commissioner (OAIC) by email to: enquiries@oaic.gov.au, by telephone on 1300 363 992 or by post to OAIC, GPO Box 5218, Sydney NSW 2001. Website: www.oaic.gov.au.

12. Can this Privacy Statement Change?

This Privacy Statement is subject to change from time to time, as we consider necessary.

This Privacy Statement was last updated in February 2023.

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Complaints

Paradice Investment Management Pty Ltd (Paradice) is committed to handling complaints in an efficient, timely, satisfactory and professional manner.

Once a retail client has invested in a registered scheme, complaints about the product will be referred to, and dealt with by, the product issuer and responsible entity, Equity Trustees Limited (EQT).

How to make a complaint

You can make a complaint on any matter related to Paradice funds to EQT, as issuer of the Paradice funds.  EQT has an established complaints handling process and is committed to properly considering and resolving all complaints. If you wish to lodge a complaint, please write (or contact):

Phone
1300 133 472

Post
Equity Trustees Limited
GPO Box 2307
Melbourne VIC 3001

Email
compliance@eqt.com.au

Further details on EQT’s complaints and resolution policy and handling procedure can be found here:  https://www.eqt.com.au/complaints-and-resolution-information and in the Paradice funds Product Disclosure Statements.

Paradice’s Complaints Handling Policy can be provided on request when you contact investorrelations@paradice.com.

We will do our best to assist you in resolving your complaint, however if an issue has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority (AFCA).

AFCA provides fair and independent financial services complaint resolution that is free to consumers.

Contact details are:

Website www.afca.org.au

Email info@afca.org.au

Telephone 1800 931 678 (free call)

Address Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001