Collection
Reed Funds Management Ltd (RFML) only collects personal information from a unit-holder that is necessary for its functions and activities.
Information is only collected with the approval of the unit-holder, by lawful and fair means.
If possible, personal information collected about an individual will only be collected from that individual. If all or part of this information is not collected, an application may not be accepted.
At or before the time (or, if that is not practicable, as soon as practicable after) RFML collects personal information about a unit-holder from them, we must take reasonable steps to ensure that you are aware of any law that requires the particular information to be collected
Information is collected for the purpose of:
- maintenance of registers if investors in accordance with the requirements of the Corporations Act;
- facilitation of distribution payments and corporate communications including our financial results, annual reports, newsletters and other information that we may wish to communicate to our unit-holders;
- formal notices to investors required to be given under the Corporations Act and our Constitution.
Unit-holders are able to access their personal information by contacting the Privacy Officer at RFML using the following details:
Reed Funds Management Ltd
17 Duporth Avenue
Maroochydore Qld 4558
PO Box 1176
Maroochydore Qld 4558
Telephone: 1800 882 585
Fax: 07 5479 4222
Operating a registered scheme requires RFML to disclose specific unit-holder information to our external service providers. Information may be disclosed to the following external service providers, when necessary:
- Custodian
- Registry
- Legal
- Accounting
- Compliance
If an individual’s personal information is collected from someone other than the individual, then RFML will ensure that the individual has been made aware of the matters listed above.
Use and Disclosure
RFML will only use the personal information we collect from unit-holders for the purpose unit-holders have provided it and for the purpose disclosed at the time of collection or otherwise as set out in this Privacy Statement. We will not use unit-holder’s personal information for any other purpose unless:
- directly related to the primary purpose of collection, and
- the individual would reasonably expect RFML to use or disclose the information for this purpose, or
- unit-holders has given consent, or
- it is authorised or required by law. In this case, RFML will make a written note of the use or disclosure.
- It is not sensitive information and the use of the information is for the secondary purpose of marketing
- Where we have reason to believe that unlawful activity has been, is being or may be engaged in, we may use or disclose your personal information as a necessary part of our investigation of the matter or in reporting our concerns to relevant persons or authorities;
- We reasonably believe that the use or disclosure of personal information is reasonably necessary by or on behalf of an enforcement body.
We will not disclose any information to any person without unit-holder approval unless it is in accordance with the Corporations Act 2001 or required by other laws or regulations.
Data Quality
RFML will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up-to-date.
Data Security
RFML will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure.
RFML will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed under the Use and Disclosure terms as above.
Openness
RFML has set out this document to declare its policies on the management of personal information. This document is available to any person who asks for it.
Access and Correction
Personal information about an individual unit-holder may be accessed by that individual unless prevented by circumstances such as if providing access would have an unreasonable impact on the privacy of other individuals or where denying access is required or authorised by law or an enforcement body.
Where we deny access to your personal information or refuse to correct personal information we will provide reasons for doing so.
Where a unit-holder requests access to their personal information which we hold, we may charge a fee to provide this access.
Identifiers
RFML has its own identifiers of unit-holders. It will not adopt other identifiers assigned by an agency or service provider, nor disclose this information unless for example the use or disclosure is necessary for the organisation to fulfil its obligations to an agency or external service provider.
Anonymity
It is not practicable to enter into transactions with RFML while remaining anonymous.
Transborder Data Flows
Whilst RFML may have unit-holders from countries outside Australia, RFML does not transfer personal information to countries other than Australia, other than to unit-holders resident outside Australia.
Sensitive Information
RFML will not collect sensitive information about individuals unless the individual has consented or it is required by law.
