We collect Personal Information when you:
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 Personal Information that we request, we may not be able to provide you with the full scope of our services and products.
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 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 helps 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. 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 find out a name or email address, or anything about you by using cookies.
Cookie information is not stored or collected by us. Once we receive information from you, via email or any other means, the information is stored in a secure environment.
Paradice takes reasonable steps to protect the Personal Information it holds 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.
We use Personal Information only for the purposes for which it was collected. These purposes are:
If you would like to stop receiving 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 obligation we have to keep Personal Information for a specific period of time.
Personal Information collected from you will only be used to send commercial electronic messages if express or inferred consent has been obtained.
In some circumstances, however, Personal Information may be disclosed outside Paradice. For example:
Personal Information may be disclosed to third parties to whom we contract out specialised functions, such as mailing houses, printing companies and professional advisers. If 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 in other countries where laws in relation to the processing of Personal Information are not consistent with the Australian Privacy Act. While we take steps to try and ensure that these third parties do not breach the Australian Privacy Act in relation to your Personal Information, the overseas recipient may breach the Australian Privacy Act. By providing us with your Personal Information you accept that we may make disclosure to overseas recipients on this basis.
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, there are some exceptions to this.
You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. Our policy is to consider any requests for access or correction in an appropriate and timely fashion. If we disagree with you about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement in our records.
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. Unless prohibited by law, a response will be made to you in writing either by mail or email as soon as possible. For privacy and security reasons, we generally do not provide you with your Personal Information over the phone. Where we do provide you with your Personal Information we provide you with a hard copy print-out of the relevant Personal Information from our current databases, or with photocopies of records which are held only on current paper files.
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.
As mentioned 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. However, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information transmitted to us (e.g. by email) and you do so at your own risk.
As noted previously, we may provide third parties noted in Paragraph 4 above with your Personal Information. Some of these third parties may be in other countries where laws in relation to the processing of Personal Information are not consistent with the Australian Privacy Act. While we take steps to try and ensure that these third parties do not breach the Australian Privacy Act in relation to your Personal Information, the overseas recipient may breach the Australian Privacy Act. By providing us with your Personal Information you accept that we may make disclosure to overseas recipients on this basis.
We do not use tax file numbers, Medicare numbers or any other Government identifier for the purposes of identifying clients with products or services. The only circumstances in which we may collect such information is where we are required by law to do so.
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 collected 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. The Personal Information collected for the purposes of this legislation will not be disclosed to any third party unless:
The Website may contain links and references to third party websites. We encourage you to read the privacy policies on these third party websites as they may differ from ours.
Please contact our Privacy Officer, Lee Kho, if you:
Our Privacy Officer, Lee Kho, can be contacted at:
Paradice investment Management Pty Limited
Level 27, The Chifley Tower, 2 Chifley Square
Sydney NSW 2000
Telephone: +61 2 8227 7400
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.
If you consider that we have failed to resolve the complaint satisfactorily, and you are an individual located in Australia, you can complain to the Office of the Australian Information Commissions by visiting www.oaic.gov.au or by writing to GPO Box 5218 Sydney NSW 2001.