References in this Privacy Policy to “we”, “our” or “us” are references to the HH Companies. The HH Companies are bound by the Privacy Act 1988 (Cth) (which includes the National Privacy Principles).

1. Overview

This Privacy Policy explains our information handling practices in relation to personal information collected by us:

directly from you - for example, when you provide information by phone or in person, in application forms or other agreements or through the www.hunterhall.com.au website (website);
from third parties such as credit reporting agencies or your representatives; or
otherwise as part of the normal operation of our services.

By using our website or using any of our products or services, you confirm that you have read and agree to the terms of this Privacy Policy. By accepting this Privacy Policy, you expressly consent to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy.

2. Collection of personal information

We collect personal information about you so that we can provide our products and services to you. If you do not provide us with the personal information we require, we may not be able to offer all our products and services to you. The type of personal information that we collect may include:

name and address;
telephone number;
Tax File Number;
bank account details; and
email address.

We may also obtain copies of original documents including your passport or driver’s licence to verify your identity as may required by law.

The information that you provide to us may include:

personal information that is required - if you wish to use a particular product or service or participate in an activity, you must provide your personal information;
personal information that is optional - you may choose to provide some personal information that is not required but which may improve or broaden the products or services that we can offer you; and
permissions - from time to time, we may ask you to confirm that you agree to a particular activity - for example, you may be required to expressly agree that you would like to receive a Monthly Performance Report.

When browsing the website, we may collect aggregated information which tells us about visitors to the website but not the identity of those visitors. For example, we may collect information about the date, time and duration of visits and which pages of the website are most commonly accessed. We may also collect internet address domain names, the previous websites visited and the types of browser visitors are using. This information is used by us for internal research, statistical and website development purposes. We do not use ‘cookies’ in our website and we do not collect ‘click-stream’ data.

3. Use of personal information

Personal information is collected, held and used by us for the purpose of managing your investment and providing our products and services to you. This may include using the personal information to enable us to perform a number of essential functions, for example making distributions and redemptions, making dividend payments and sending various communications, including dividend statements, tax statements and annual reports.

We may share your personal information among the HH Companies, including any located outside Australia. In particular, personal information received by an HH Company may be disclosed:

to the other HH Companies;
to its employees, agents, contractors and service providers; and
to the employees, agents, contractors and service providers of each of the other HH Companies.

An example of such use is that HHV may disclose personal information such as your name and telephone number directly to HHIML, HHL or their employees, agents, contractors and service providers.

If a third party acquires or wishes to acquire, or makes inquiries in relation to acquiring, an interest in any of the HH Companies we may disclose information about our investors to that third party. We may also use the information to send investors marketing materials about the products and services. The content of emails or ‘contact us’ messages which you send to HH Companies may be monitored by our employees, agents, contractors and service providers for purposes including compliance auditing and maintenance or where email abuse is suspected.

4. Disclosure

In managing your investment and providing our products and services to you, we may disclose your personal information to related parties or unrelated third parties, including:

our service providers and specialist advisors;
external contractors, including contractors for the provision of IT support, print and mail services;
our agents;
the external custodian for the HH Companies;
the relevant share registry;
the external auditors of the HH Companies and the Hunter Hall Funds;
regulatory authorities as required from time to time to fulfill legal and regulatory reporting, including the Australian Taxation Office, the Australian Securities and Investments Commission, the ASX and AUSTRAC;
your financial advisor, financial planner or broker; and
law enforcement agencies, government agencies, courts or external advisors where permitted or required by law.

We will take reasonable steps to ensure that contracts we have with third parties to whom we may disclose personal information include requirements to comply with the requirements of the Privacy Act and this Privacy Policy. You may elect for your personal information not to be disclosed to third parties by notifying our Investor Relations Department (details below).

5. Accuracy of personal information

We seek to ensure that the personal information we hold is accurate and up-to-date. We realise that this information changes frequently with changes of address and other personal circumstances. Please contact our Investor Relations Department (details below) if you would like to check the personal information we have about you, or to advise us of changes.

6. Storage and security

We regard the security of personal information as a priority and use a number of secure physical and electronic mechanisms to protect it. Unfortunately, no data transmission over the internet can be guaranteed as completely secure. While we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us and individuals do so at their own risk. A username and password may be essential for you to use some sections of the website, for example the “Client Secure Access” area of the site. For your own protection, we require you to keep these details confidential and to change your password regularly (if applicable). Where we no longer require any personal information that we hold, we will destroy it or remove details which may identify an individual.

7. Marketing communications

If you do not wish to receive any marketing information about the products or services of HH Companies, please contact our Investor Relations Department (details below).

8. Access to information

You may obtain access to any personal information that we hold about you, unless one of the exceptions in the National Privacy Principles applies. To make a request to access information that we hold about you, please contact our Investor Relations Department (details below) in writing. We will require you to verify your identity and to specify what information you require. We may charge a fee to cover the cost of verifying the application, and locating, retrieving, reviewing and copying any material requested.

9. Complaints

If you consider that any action of the HH Companies breaches this Privacy Policy or the Privacy Act, you can make a complaint by contacting our Investor Relations Department (details below).

10. Changes to Privacy Policy

The HH Companies will review this Privacy Policy from time to time and may update it from time to time. If we make changes, we will place the amended Privacy Policy on the website. A hard copy may be obtained at any time by contacting our Investor Relations Department (details below).

11. Contact us

If you have any questions about your personal information or this Privacy Policy, please contact our Investor Relations Department:

Telephone:   1800 651 674
Email:           invest@hunterhall.com.au
Address:       GPO Box 3955, Sydney NSW 2001