This policy applies to VGI Partners Limited (ACN 129 188 450) and its related bodies corporate (collectively, “VGI” or “we”) and outlines our policy in dealing with personal information (i.e. information or an opinion relating to an individual which can be used to identify you as an individual or from which your identity can be reasonably ascertained) that we may collect.
VGI is committed to respecting your privacy and protecting the security of your personal information. To that end, VGI is bound by and will ensure that it complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles under that Act.
Personal information we may collect
The kind of personal information that VGI may collect includes information that is reasonably necessary for VGI to conduct its business, communicate with you, consider any investment applications and/or approaches that you make to us or provide you with appropriate services. The kind of personal information may include your full name, residential address, date of birth and copies of identification documentation. Regulatory and other laws may also mandate us to collect additional information from you.
VGI will not generally collect sensitive information about you unless required by applicable laws. Sensitive information is information about a person relating to race or ethnic origin, political opinions or religious beliefs, trade union or other trade association membership, sexual preferences, criminal record and health.
How we collect personal information
The way in which VGI may collect personal information about you includes:
- any messages or comments you submit to VGI via its website through the ‘Contact Us’ page, the email@example.com email address or the firstname.lastname@example.org email address;
- application forms, identification documentation or other documents that you may complete or provide to VGI;
- face to face meetings, interviews and telephone conversations;
- publicly available information; and
- information that we receive from third parties such as administrators or custodians or from your legal, tax or financial advisers (where you have authorised them to provide this information to VGI)
If you do not provide us with all the information we request, then VGI may not be able to process your investment application, manage or administer your investment or provide services to you.
Purpose of collection, use and disclosure of information
VGI collects your personal information primarily for the purpose of processing applications (including identifying you and confirming your eligibility to invest in the product or to utilise the service), managing and administering your investments and/or to providing services to you. VGI will also use your personal information for investment related communications.
VGI will only use or disclose your personal information:
- for the purpose for which you provided it or for related purposes (but only where you would reasonably expect your information to be used or disclosed for such related purposes);
- where you have consented to the use or disclosure; or
- to the extent that VGI is required to do so by law, including to comply with anti-money laundering, taxation or reporting requirements.
We may disclose your personal information to VGI’s related bodies corporate, and to other companies and individuals who assist us in providing services or who perform functions on our behalf such as administrators and custodians. These related bodies corporate and service providers may be located or operate overseas and therefore your information may be held outside Australia. VGI has contractual arrangements in place with its service providers which are designed to ensure that your personal information is kept confidential and secure.
VGI may also use your personal information to keep you informed of our services, events and investment opportunities. Please contact us via email@example.com if you do not wish to be contacted for these purposes.
VGI does not sell personal information to other companies or individuals.
Security of information
VGI regards the security of your personal information as paramount and takes reasonable steps to protect the security of personal information that it holds, in accordance with the Australian Privacy Principles. VGI also takes reasonable steps to protect such information from misuse, loss and unauthorised access, modification or unlawful disclosure. When personal information VGI collects is no longer required, it will take reasonable steps to destroy it.
Although VGI endeavours to provide a secure environment, and restricts VGI personnel access to personal information, the Internet by nature is not a secure environment. Information transmitted to VGI over the Internet cannot be guaranteed to be completely secure or error free, and as such VGI is not responsible for them. If you send an e-mail to VGI over the Internet, you are accepting the associated risks.
Accessing and correcting your information
VGI endeavours to ensure that the personal information it holds is accurate, up to date and complete. However please contact us via firstname.lastname@example.org and request a correction if you feel the information we hold about you is inaccurate, incomplete, out of date or misleading.
Privacy concerns or complaints
If you have any concerns or complaints about your privacy, please contact us via email@example.com. VGI will use its best endeavours to resolve your concern or complaint within five business days or if we are unable to do so within this time frame, we will contact you and let you know why. If you are unhappy with how we handle your privacy complaint, you may make a complaint to the Information Commissioner under section 36 of the Privacy Act 1988(Cth).
Links and Cookies
This website may contain links to other websites. Such websites are responsible for their own privacy practices and you should review the respective privacy policies or statements of those websites.
VGI may use third parties to analyse traffic at its website and may use ‘cookies’ (a packet of information placed on a user’s computer by a website for record keeping purposes) to do this, however, the information collected to conduct such analysis is anonymous.
Updates to this Policy