This policy explains how we handle your personal information, which we collect in the course of our dealings with you as an investor in the Impact Investment Fund (the Fund).
The information we collect and hold
We collect personal information about you, which is reasonably necessary to consider your application for units in the Fund; maintain your contact details; and fulfil our legal obligations under applicable laws relating to taxation and Anti-Money Laundering and Counter-Terrorism Financing.
We hold personal information relating to your investment in the Fund, for example your application for units, or requests for redemptions; your name, contact details and identification information (including government-issued tax numbers); records of our interactions with you, including by telephone, email and online; and your enquiries or complaints.
We do not collect information about your financial position because we do not provide financial product advice that takes into account your financial objectives.
We do not collect sensitive information about you. (Sensitive information includes information relating race, political or religious beliefs, sexual preferences, criminal convictions, membership of professional or trade associations or unions and health information.)
How that information is used
We only use and disclose personal information about you for the purpose for which it was disclosed to us or for related purposes. For example, we may use and disclose personal information to process applications, administer and manage our obligations as the Trustee of the Fund including reporting on the performance of the Fund, monitoring, auditing, communicating with you and dealing with any complaints or enquiries.
We may also use and disclose your personal information (on a confidential basis) in connection with acquisitions, mergers or changes in control of our business or assets.
We may from time to time also use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, we do respect your right to ask us not to do this.
We do not sell personal information to other organisations to allow them to do this.
We may share personal information with Impact Investment Fund Pty Ltd, the Manager of the Fund.
We may also disclose personal information to third parties as required by relevant laws or rules, such as those relating to Anti-Money Laundering and Counter-Terrorism Financing; or to service providers who provide services to the Fund including for example archival, auditing, accounting, legal, business consulting, banking, payment, delivery, data processing, data analysis, website and technology services; or to your nominated financial adviser (with your permission).
The Fund’s website is hosted by Digital Ocean Accordingly your personal information may become available to third parties in the United States. However we take steps to protect your personal information against misuse or loss.
Keeping information accurate and up to date
We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.
Keeping information secure
We use security procedures and technology to protect the information we hold. Access to and use of personal information within this company seeks to prevent misuse or unlawful disclosure of the information.
If other organisations provide support services, we require them to safeguard the privacy of the information provided to them appropriately.
Where the personal information we collect is no longer required, we delete the information or permanently de-identify it.
How you can access or correct your information
You can contact us as set out below to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
Dealing with us online
When you visit our websites you will browse anonymously unless you have logged into a client portal or accessed the website from a personalised communication from us.
If you are an anonymous visitor, the information we collect is not capable of personally identifying you.
Once you have accessed our website from an e-mail or other personalised communication sent to you or provided us with personal information by completing a form online, we may be able to identify you. If we have identified you, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our website, irrespective of how you access our sites (e.g. by clicking a link in an advertisement or from a third party website). In addition we may combine that information about your use of the Fund’s website with certain other online and offline information we have about you in order to tailor your online experience and provide you with further information. If you would prefer not to be identified you can delete the cookies and reconfigure the cookie preferences on your internet browser (see below).
A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes. Cookies are generally used on the Fund’s website to –
- monitor traffic – we use tracking companies to gather anonymous information about how people are using our site, this information includes time of visit, pages visited, and some system information about the type of computer you are using. We use this information to enhance the content and services offered on the site;
- collect identifiable information about your use of our websites – if we have identified you as a result of you logging into the Fund’s website or accessing our website from an e-mail or other personalised communication sent to you or providing us with personal information by completing a form online.
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences).