RHCD Funds Pty Ltd and its related entities (‘RHCD Funds’) is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (“Privacy Act”).
In this Privacy Policy, any mention of ‘RHCD Funds’, ‘we’, ‘us’ and ‘our’ refers to RHCD Funds, Carpe Diem Partners Pty Ltd and its related entities.
The Information RHCD Funds Collects and Holds
Whenever it is reasonable and practicable to do so, RHCD Funds will only collect personal information which is reasonably necessary for it to:
- Provide you with quality products or services;
- Consider applications you make to RHCD Funds; and
- Maintain your contact details.
RHCD Funds generally holds personal information relating to:
- The products and services RHCD Funds provides or has provided to you;
- Your financial interests; and
- Personal details such as your name, address, phone and email address, bank account details and Tax File Numbers.
Without this information, RHCD Funds would not be able to provide the respective financial services to you.
Sensitive Information
RHCD Funds generally does not collect sensitive information about you, unless it is required by law and you have consented to the collection of this information.
How RHCD Funds Collects Your Personal Information
When collecting, using or disclosing personal information, RHCD Funds will take such steps as are reasonable in the circumstances to ensure that the information is accurate, up-to-date and complete.
Collecting Personal Information
RHCD Funds will only collect personal information in a lawful and fair manner. Wherever possible, personal information will be collected directly from the individual, unless it is unreasonable or impracticable to do so. Sensitive information (e.g. Tax File Numbers and Bank Account Details) will only be collected where the individual consents to the collection of that information.
Using Government Identifiers
Unless permitted by law, RHCD Funds will not adopt a government related identifier (e.g. a Tax File Number) of an individual as its own identifier and it will only disclose such identifiers for the purposes of verifying the identity of the individual, or as permitted by law or as is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
The Purpose for which RHCD Funds Collects, Holds, Uses and Discloses Personal Information
RHCD Funds collects, holds, uses and discloses personal information for the purposes it was disclosed to RHCD Funds. This includes administering its managed investment schemes and communicating with shareholders, investors and clients.
Disclosing Your Information
RHCD Funds will record in writing, circumstances where it uses or discloses personal information for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
Personal information collected by one entity within the RHCD Funds group of companies may be used by another entity within the group provided that the personal information is held, used and disclosed for the same primary purpose.
RHCD Funds does not normally disclose personal information about its shareholders, investors and clients to outside parties, except those contracted to provide services to RHCD Funds. These may include:
- Government statutory bodies such as the Australian Taxation Office (ATO), the Australian Securities and Investment Commission (ASIC), the Australian Securities Exchange (ASX);
- Professional advisers and contracted service providers engaged by RHCD Funds – e.g. auditors, lawyers, platform operators, fund managers, investment providers, custodian, insurer and consultants;
- Your financial advisor or any other person that you have consented to for the purpose of managing your investment in RHCD Funds.
With consent, RHCD Funds will disclose your personal information to an accountant, financial consultant or other person or organisation you nominate. Your personal information may also be disclosed to the Australian Taxation Office or other government authorities or agencies as required by law.
Marketing
From time to time we may use your personal information to provide you with offers you may find of interest, changes to our organisation, or new products or services being offered by us.
If you do not wish to receive marketing information, you may at any time decline to receive such information by emailing us at info@rhcdfunds.com.au. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
How RHCD Funds Holds and Protects Your Personal Information
RHCD Funds will ensure that in relation to any personal information it holds that it will take such steps as are reasonable in the circumstances to protect the information from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure.
If other organisations provide support services, RHCD Funds requires them to appropriately safeguard the privacy of the information provided to them.
If RHCD Funds holds information which it no longer needs (for any purpose for which the information may be used or disclosed) or it is no longer required to keep, it will take such steps as are reasonable in the circumstance to destroy the information or to ensure that the information is de-identified.
Can an Individual Remain Anonymous when Dealing with RHCD Funds?
Given the nature of RHCD Funds products and services, other than providing general publicly available information (such as the RHCD Funds website), it is not practical for RHCD Funds to deal with individuals who wish to remain anonymous or would prefer to identify themselves only by way of pseudonym.
How an Individual May Access and Seek Correction of Personal Information Held by RHCD Funds
Generally, RHCD Funds will provide you with access to your personal information in the manner you request and within a reasonable period of time after the request is made. You can request RHCD Funds to correct any personal information it holds about you.
To apply for access or to request a correction to your personal information, contact the Privacy Officer.
There are no charges for requesting access to your personal information. However, RHCD Funds may charge a fee to provide access, provided that such fee is not excessive.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious. An explanation will be provided to you if we deny you access to the personal information we hold about you.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the information. At the time of the request, otherwise, we will provide an initial response to you within 7 days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days. If we refuse to correct personal information we will provide you with our reasons.
Complaints
An individual may complain to RHCD Funds about a breach of the Privacy Act by email to info@rhdcfunds.com.au
We will acknowledge your complaint within 5 business days and will provide you with a decision on your complaint within 30 business days.
If you are not satisfied with the outcome, you can contact the Australian Privacy Commissioner through www.oaic.gov.au to discuss your concerns.
Is RHCD Funds Likely to Disclose Personal Information to Overseas Recipients?
It is unlikely that RHCD Funds will disclose your personal information to an overseas recipient.
If at some future time, RHCD Funds chooses to disclose personal information about an individual to an overseas recipient, it will either obtain the individual’s informed consent prior to doing so, will be required to do so by Australian law or prior to doing so will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Privacy Act in relation to the information.
Contacting Us
If you would like more information about how we manage your personal information, please email us at info@rhcdfunds.com.au
Changes in our Privacy Policy
We may, without notice, amend this Policy from time to time for any reason and will update the Policy accordingly. We ask that you visit our website periodically in order to remain up to date with such changes. We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices. As a result we may change this Privacy Policy from time to time or as the need arises.