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(Parkstone Funds Management, we, us, or our) provides the online investor portal (Investor Portal, and overall our Services) for investors to consider, invest and monitor the performance of investment opportunities created, managed, or administered by us or another company in the Parkstone Funds Management group (a Parkstone Funds Management Group Company) (each a Scheme).
At Parkstone Funds Management, we respect the privacy rights of our users and recognise the importance of protecting the Personal Information we collect about you. This privacy policy is designed to outline the way in which we manage the Personal Information we hold about our investors, prospective investors, prospective employees, visitors to our Investor Portal and website, and how we comply with the privacy laws that we are legally obliged to comply with, including the Australian Privacy Act 1988 (Cth) (Australian Privacy Act) and the Australian Privacy Principles (APPs).
Personal Information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be Personal Information regardless of whether it is true.
You consent to us collecting, holding, using and disclosing your Personal Information in accordance with this policy.
This privacy policy is governed by Australian law. For more information about privacy issues in Australia and protecting your privacy, visit the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.
When handling Personal Information, we will comply with applicable privacy laws, including the Australian Privacy Act and the APPs.
Unless a term has been defined in this privacy policy, it uses the same definitions as those used in our terms and conditions (Terms and Conditions) (Terms).
In general, and depending upon the nature of your connection with Parkstone Funds Management, the type of Personal Information we collect and hold includes (but is not limited to):
• your name, addresses, contact details, date of birth, place of birth, tax identification number, tax residency status and citizenship;
• information about your bank account details and financial and personal circumstances, including your source of funds (in some cases evidence of this), and transactional and financial information relating to your user account;
• in the case of prospective employees, occupation, employment history and/or details, education and qualifications, testimonials and feedback;
• documents that verify your identity and other personal details; and
• other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations.
We collect your Personal Information in a number of ways when you use the Investor Portal or Services. These can broadly be categorised as follows:
This is the Personal Information about you that you enter into the Investor Portal or Services yourself, including any Personal Information you provide through the registration or investment process, through any contact with us (e.g. telephone calls, face to face meetings, Investor Portal enquiry forms or emails, or through the use of the services and facilities available through our websites and social media channels) or when you use the Services. If you don’t want to provide your Personal Information, you don’t have to, but it may restrict the function of some parts of the Investor Portal or Services.
We may receive Personal Information about you from third parties, for example:
• we may use third parties to analyse traffic at our Platform, websites and social media channels, which may involve the use of cookies;
• where a third party provides security-related or identity verification services;
• in some circumstances we might collect Personal Information about an individual from a third party (for example, an employment reference from another person and, including without limitation, for the purposes of our compliance with our anti-money laundering and sanctions compliance obligations); and
• from publicly available websites.
Some Personal Information is automatically collected when you perform any action on, or interact with, any part of our Investor Portal or Services, including:
• clickstream data, which is a record of how you navigate or click through our Investor Portal or Services; and
• information obtained through the use of cookies, web beacons and similar storage technologies. Please refer to the section of this privacy policy entitled “Cookies and Tracking” for further information, including information on how you can disable these technologies.
Whenever you lodge a support query using our “Help” or “Contact us” features on the Investor Portal, we collect your name and email address, in order to be able to reply to you and provide the support or advice requested.
We collect, hold and use your Personal Information:
• to create and manage your User Account within the Investor Portal;
• to review your eligibility to create or continue to use a User Account with us;
• to process your application to become an investor and other matters in connection with the operation of the Investor Portal and your User Account, including, without limitation, transfers, deposits, payments, generating reports and record keeping of investment portfolios;
• to provide our Investor Portal and Services and otherwise carry out our obligations under the Terms; and
• to bill you (or the Investment Entity on whose behalf you are acting) and to collect money that is owed.
Such collecting, holding and use is necessary for the performance of the contract between you (or the Investment Entity on whose behalf you are acting) and us.
We also collect, hold and use your Personal Information:
• to verify your identity, including (as applicable):
• to check your identity against databases maintained by Government agencies and other databases (for example, the Document Verification Service maintained and provided by the Commonwealth of Australia);
• to identify, prevent or investigate any actual or suspected fraud, unlawful activity or threats to our systems; and
• to comply with our legal obligations, including (but not limited to) in relation to our anti-money laundering and counter-terrorism financing obligations and general tax regulation.
• to communicate with you (including responding to feedback and information requests relating to our Investor Portal and the Services, to let you know when we are experiencing technical difficulties, and to alert you of new features or developments);
• to communicate with, and comply with our obligations to, our third-party service providers, suppliers and other users of our Investor Portal and/or Services;
• to send administrative messages, reminders, notices, updates, security alerts, and other information relevant to your use of the Investor Portal and/or the Services;
• to engage third parties on your behalf;
• to track access to the Investor Portal and Services in order to help detect and prevent any fraudulent or malicious activity;
• to analyse and report on usage of the Investor Portal and Services, so we can improve the Investor Portal and Services;
• to send you (or Investment Entity on whose behalf you are accessing the Investor Portal) marketing and promotional messages and other information that may be of interest to you where you (or the Investor Entity on whose behalf you are accessing the Investor Portal) have consented to receiving such material. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link) or by emailing us at info@parkstone.com.au;
• to keep you informed of investments we consider may be of interest to you, unless you ask us not to provide you with this information;
• to protect and/or enforce our legal rights and interests, including defending any claim; and
• to comply with our legal obligations, including (but not limited to) in relation to our anti-money laundering and counter-terrorism financing obligations, and general tax regulation. This may include any notification and reporting obligations and any access directions imposed on us by an applicable Government agency, law enforcement agency or regulatory authority.
If you do not provide us with your Personal Information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.
We may disclose your Personal Information to:
• your professional advisers, your authorised signatories and your agents;
• other members of the Parkstone Funds Management group, including its subsidiaries (if any) and related parties;
• service providers and suppliers who provide necessary goods and/or services to us (including identity checks), and any other partners who help us market and sell the Investor Portal and/or the Services – for instance to manage customer relations, send out newsletters and/or to process payments;
• any business that supports us, including hosting or maintaining any underlying software, IT system or data centre that we use to provide our Investor Portal and/or Services;
• other companies, agencies or individuals that maintain databases against which your identity may be verified, which may include (but is not limited to) the Commonwealth of Australia Document Verification Service;
• our professional advisers (such as our lawyers who assist us to ensure we are complying with our legal obligations), and banks and other financial institutions as part of our obligations when paying or receiving funds on your behalf;
• social media sites on which we have a presence, to the extent that you interact with us via a social media site. We limit interactions on social media sites that may disclose Personal Information to the private messaging functions of those sites, unless you otherwise request or give permission;
• anyone who assists us to identify, prevent or investigate fraud, unlawful activity, misconduct or threats to our systems;
• other third parties to anonymise and aggregate statistical information;
• a person who can require us to supply personal information (e.g. a Government agency, regulatory authority or law enforcement agency);
• respond to due diligence requests and/or transfer personal information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition of our business; and
• any other person or entity authorised by you.
We may also disclose your Personal Information to others outside our group of companies where:
• we are required or authorised by law to do so;
• you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
• we are otherwise permitted to disclose the information under the Privacy Act 1988 (Cth).
The rights of disclosure in this section may, if applicable, be subject to further restrictions contained in data processing agreements with our third party service providers (as applicable).
At no time will Parkstone Funds Management sell your Personal Information to any third parties or transfer your Personal Information to any third parties, for a use not related to the provision or marketing of our products and services.
Parkstone Funds Management is located in Australia, so your Personal Information may be transferred and/or stored there.
We utilise the services of third party processors (or sub-processors, as applicable) in various countries who may access your Personal Information. Consequently, we may transfer Personal Information to persons or entities located in these countries. We take reasonable steps to make sure the overseas recipient will not breach the APPs.
While we take reasonable steps to maintain secure internet connections, the supply of Personal Information over the internet is at your own risk.
If you follow a link on our Investor Portal to another website, the owner of that website may have its own privacy policy that will apply to its use of your Personal Information processed on that website. We suggest you review that website’s privacy policy before you provide access to your Personal Information.
We will keep your Personal Information:
• until we no longer have a valid reason for keeping it;
• until you request us to stop using it; or
• for as long as required by law e.g., we keep invoice information for 7 years to fulfil our tax obligations.
We will also take reasonable steps to destroy or de-identify Personal Information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.
We use web analytic tools to collect information about use of our Investor Portal and Services, with the goal of improving our Investor Portal and Services. These web analytic tools collect information such as how often users visit the Investor Portal and Services, what pages they visit when they do so, and what other sites they used prior to coming to the site.
We may use various technologies to collect and store information about you when you use the Investor Portal and/or the Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons, as described below.
A cookie is a piece of information that our web server may send to your machine when you visit our Investor Portal. The cookie is stored on your device, but does not identify you or give us any information about your device.
The types of cookies we use may include (but are not limited to):
• Session Cookies: These are temporary cookies that are erased when the user closes their web browser. They’re used to remember user activity within a single session, making it smoother to navigate the site.
• Persistent Cookies: Also known as permanent or stored cookies, they remain on the user’s device even after the browser is closed. These cookies can be used to remember a user’s login information, preferences, and other persistent information for future visits.
• First-Party Cookies: These cookies are set by the website the user is visiting, and they typically allow the website to keep track of the user’s activity during their visit.
• Third-Party Cookies: These are set by domains other than the one the user is visiting, often by advertising and tracking services. They can be used to track a user’s activity across multiple websites and build up a profile of their interests.
• Secure Cookies: These cookies can only be transmitted over an encrypted connection (i.e., HTTPS). They help to ensure that the user’s information is secure and prevent unauthorized access.
• HTTP-Only Cookies: These cookies can’t be accessed by client-side scripts, which makes them more secure against potential cross-site scripting (XSS) attacks.
• SameSite Cookies: These cookies help prevent Cross-Site Request Forgery (CSRF) attacks by allowing servers to assert that a particular cookie should not be sent along with cross-site requests.
With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you reject the use of cookies, you will still be able to access our Investor Portal but please note that some of its functions may not work as well as they would if cookies were enabled.
We take the protection of Personal Information seriously and we will take reasonable steps (using physical, electronic and procedural safeguards) to keep Personal Information in our possession safe from loss, unauthorised activity, or other misuse. Staff who handle your Personal Information are provided with training on how to do so appropriately.
We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.
We implement and maintain processes and security measures to protect Personal Information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
You may access or request correction of the Personal Information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your Personal Information.
There is no charge for requesting access to your Personal Information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct Personal Information in a reasonable time and will take all reasonable steps to ensure that the Personal Information we hold about you remains accurate, up to date and collected.
If you are based in the EU or the United Kingdom you may have the right, under the EU General Data Protection Regulation or the UK General Data Protection Regulation (as applicable), to:
• in certain circumstances, have your Personal Information erased;
• restrict the processing of your Personal Information;
• move, copy or transfer your Personal Information easily for your own purposes across different services in a safe and secure way;
• object to processing where we rely on our legitimate interests as the lawful basis for processing;
• withdraw your consent at any time, where our processing of your Personal Information is based on consent; and
• lodge a complaint with an appropriate supervisory authority, if you consider that our processing of your Personal Information has breached the EU General Data Protection Regulation or the UK General Data Protection Regulation (as applicable).
We will respond to any request made in respect of the above in accordance with the applicable privacy laws.
Please note that in certain circumstances we may refuse to respond to a rights request where we have the right to do so under applicable privacy law.
If you wish to exercise your rights under this privacy policy or any Applicable Privacy Laws, you can do this by emailing our Privacy Officer at info@parkstone.com.au. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your Personal Information, you should contact us. Our contact details are set out above.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
If you are located in the EU or the UK, you also have the right to complain to your Member State data protection authority or UK data protection authority.
From time to time we may make changes to this privacy policy (for example, to reflect any changes in our Services or any applicable privacy laws). Any changes to our policy will be published on our website. Where a change is significant, we’ll make sure we let you know – usually by displaying a notice on our Investor Portal or by sending you an email.
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