NORTHERN STAR FUNDNDS MANAGEMENT PTY LTD

Privacy Policy

Introduction

Northern Star Funds Management Pty. Ltd. (ACN 619 138 788) (we, us or our) is committed to protecting your privacy in accordance with applicable laws. This Privacy Policy (Policy) sets out how we may collect, store, use and disclose information (including personal information) you provide to us.

By visiting and using our website www.northernstarinvest.com (Website) or otherwise providing us with information, you consent and agree for your information to be handled in accordance with this Policy. You also confirm that any information you provide us on behalf of another person is done so with their authority, and you confirm you have their authority to consent to the use and management of their information as set out in this Policy.

You must not visit or use the Website or otherwise provide us with information if you do not consent to the collection and management of your information in accordance with this Policy.

What is personal information?

For the purposes of this Policy, “personal information” refers to any information or opinion about you from which you may reasonably be identified, irrespective of whether that information or opinion is in a material form or true. “Sensitive information” is an important category of your personal information and includes any information or opinion about your gender, race, ethnicity, health, religious beliefs, political affiliations and sexual orientation.

Why we collect personal information

We collect personal information about you which is reasonably necessary to:

• provide you with quality products or services
• consider applications and requests you make to us
• introduce you to fund managers of other SIV complying funds
• conduct marketing and social functions
• maintain your contact details
• fulfil our legal obligations such as those relating to taxation and anti-money laundering and counter-terrorism financing
• as otherwise authorised by you

Without such information, we may not be able to process your application or provide you with an appropriate level of service.

How we collect your information

The types of information we may collect from you depends on how you interact with us.

We may collect data and information (including personal information) from you when you:

• access the Website, such as your IP address, domain name, date and time of visit, browser used, previous sites visited, and information relating to the pages you access and documents you download
• fill out a form, register as a client, or otherwise access, request or purchase our products or services, such as your name(s) and email address and any other information you provide and
• engage with us through the Website or social media (such as Twitter, Instagram or Facebook)

 

How we hold your information

We may store personal information in physical and electronic records, at our premises and the premises of our service providers, which may include storage on the cloud. Where this occurs, we take steps to protect personal information against misuse or loss.

We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints.

How we use information

We may use information (including personal information) collected by us:

• to supply you with any products, services or information you request or purchase
• to contact you with information regarding our activities and opportunities we believe may be of interest to you, such as promotions, discounts, causes and upcoming events
• on an aggregate basis, to compile statistics and undertake analytics to improve our products and services and the access to, and the content of, the Website
• for website administration and customisation purposes
• to comply with any applicable laws, including court orders

How we disclose information

We may disclose your information to:

• our payment processors
• any person or on any platform or medium you authorise us to disclose your information
• contractors who assist us in our activities, such as information technology personnel, who are required to keep confidential your information, and only use that information for our purposes
• law enforcement agencies, government agencies and regulators, where we are authorised or required by law to do so

Generally, we only use and disclose any personal information collected by us for the purpose for which that information was collected. We may also use and disclose any such personal information for a range of other different purposes, including:

• to supply goods or services to you
• to third parties that assist us to manage or develop our business
• for our marketing purposes
• to gain understanding of your needs
• as required by law
• for our other business purposes

You can contact us at  info@.northernstarinvest.com if you do not wish your information to be used or disclosed in a particular way.  We will take reasonable steps to comply with your request, but this may limit your ability to access or use the Website or our products or services.

 

Please note that if you have elected to receive our marketing communications, but no longer wish to receive such communications from us, you may unsubscribe from these communications by clicking the “unsubscribe” link located at the end of such communications or emailing us at info@.northernstarinvest.com.

Cookies

We use cookies to manage some of the functionality available on the Website.

Cookies are small packets of data that are transferred from a website to your hard drive. Cookies allow the Website to identify your device and keep a record of certain pages you visit on the Website. This means that the Website will recognise your device when it accesses those webpages on a later date and will input your preferences.

Web browsers usually accept cookies automatically. You can configure your web browser to disable cookies or require the web browser to alert you when cookies are being used, but this may reduce the functionality available to you when accessing the Website.

Security

We will take reasonable steps to keep secure the personal information we collect. We do not take responsibility for the security of information which is outside of our control, such as when you provide it to us over the Internet. You are responsible for any information you submit using any application on the Website. Please note that any posts or comments you submit on the Website may be seen by third parties, who may collect, use and disclose that information.

Accessing or correcting your personal information

You may request to access or correct your personal information by contacting our Privacy Officer by email to info@.northernstarinvest.com.

We will respond to your request within a reasonable time and give you access or correct your information, unless we are authorised or required by law to refuse your request. If we refuse your request, we will usually explain why, and in the case of correction we will keep a record that you have disputed the accuracy or completeness of particular information.

Please note that we may require you to produce reasonable proof of your identity before we give you access or correct your personal information. We may also require you to pay our reasonable costs of providing access.

Changes

We may update this Policy at any time to reflect any changes in the way that we may collect, use or disclose personal information or to comply with applicable law, and you agree to be bound by such changes. These changes will be posted on the Website. All personal information held by us will be managed in accordance with the most updated version of this Policy. You can check the date this Policy was last amended at the end of this web page.

Contact us

If you have any questions about this Policy, or have a complaint about the way we have handled your personal information, you can contact us by email to info@northernstarinvest.com. We will use reasonable endeavours to respond to you within a reasonable time.

Privacy Policy updated April 2018.