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Privacy Policy

PRIVACY POLICY

Introduction

This privacy policy applies to Allswell Communities Pty Ltd (‘Allswell’, ‘we’, ‘us’ or ‘our’) and its related entities, which includes Eighth Gate Capital Management Pty Ltd and Eighth Gate Pty Ltd which holds Australian financial services (‘AFS’) licence number 476599.

About this policy

We recognise that your privacy is important to you. This policy has been prepared to provide you with information on the collection, storage, use and disclosure of your personal information by us. When referring to personal information, we mean information that identifies an individual or from which an individual’s identity can reasonably be ascertained.

Collection of personal information

Generally, we will only collect personal information from you that is reasonably necessary for, or directly related to, one of more of the functions and activities of our business. For example, we may request that you provide your personal information when you complete an application form to invest in one of our managed investment schemes or submit information to us via our website. There may be other occasions when we collect personal information about you from other sources, such as from our related bodies corporate, a publicly maintained record or from an information services provider. We may also share personal information about you with our related entities.

Information we hold about you may include things such as your name, date of birth, telephone numbers, email address, bank account details, investment information, tax file number, Government related identifiers (e.g., drivers licence, Medicare or passport number) as well as any other information that may be required under Australian anti-money laundering legislation for identification and other purposes. In some circumstances, we may also hold other personal information you provide to us.

We do not collect or hold sensitive information, such as health information, racial or ethnic origins, religious affiliation or political opinions.

Personal information held by us is not organised by Government related identifiers. Government related identifiers are only used by us to verify the identity of our clients in connection with our business, e.g., as part of our requirements under Australian anti-money laundering legislation.

Use and disclosure of personal information

We will not use or disclose your personal information for any purpose other than:

Under no circumstances will we sell or receive payment for only disclosing your personal information to another party. However, if we sell, merge or transfer our business, then your personal details will be provided to the new owners and managers of the business.

As a general rule, we will not disclose your personal information to an overseas recipient without your consent, unless the disclosure is required by law. If disclosure to an overseas recipient is required, then we will take reasonable steps to ensure the recipient complies with the Australian Privacy Principles.

Disclosure of personal information

The types of organisations to which we may disclose the personal information you provide us with include:

Information storage and security

We will take reasonable steps to ensure that the personal information we hold is protected from misuse, loss and unauthorised access, modification or disclosure. We store personal information in our computer databases and we may also utilise the services of third party storage providers (including ‘cloud’ providers), which store data in foreign jurisdictions, such as the United States, North America, Asia (including China, Korea and Hong Kong), United Kingdom, European Union or any other country in which the provider or its affiliates, subsidiaries or service providers maintain facilities.

Various security measures are in place to safeguard personal information, including restricted staff

access, password restricted access, internet based security tools (e.g., firewalls, virus protection programs), an information technology disaster recovery plan, and we perform regular back-ups and secure off site storage of date. Where we utilise third party storage providers, then we must take reasonable steps to ensure they use adequate security technologies and procedures.

In the event you cease to be a client, personal information we hold about you will be maintained for at least as long as we are required to comply with legislative document retention requirements. After that time, we may destroy your personal information or put it beyond use, e.g., de-identify the personal information so we cannot use the information.

Accessing your personal information

You may request access to your personal information at any time. Upon confirmation of your identity, we will provide you with access to information by either providing you with copies of the information requested or allowing you to inspect the information.

We will not provide you with access to personal information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result.

The Australian Privacy Principles place other restrictions on accessing your personal information. Restrictions include the following:

If we decline your request for access, we will provide a written explanation to you for the refusal.

Correcting your personal information

We will take reasonable steps to ensure that the personal information we collect is accurate, up to date and complete. If you provide evidence to us that the personal information we hold about you is inaccurate, incomplete or out of date, then we will take all reasonable steps to correct it.

Complaints about privacy

We are committed to providing you with a fair and responsible system for handling complaints. If at any time you have any complaints in relation to privacy, please contact our Privacy Officer and provide details of your complain in writing. We will try to resolve any concerns you may have to your satisfaction within a reasonable time (usually 30 days). If you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner (telephone 1300 363 992) who may investigate your complaint further.

More information on privacy

We are required to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. A summary of the Australian Privacy Principles, a copy of the Privacy Act and additional information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. Before providing us with personal information, please check the Privacy Policy on our website.

This Privacy Policy was last updated in January 2016.

Our contact details

Allswell Communities Pty Ltd
ABN 24 167 206 564

Telephone:          + 61 7 (07) 3505 0388

Email:                    info@allswellcommunities.com.au

Address:               80 Petrie Terrace, Brisbane, Queensland 4000  Australia

Website:                www.allswellcommunities.com.au

Any questions or complaints may be directed to our Privacy Officer.