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Introduction
This policy applies to personal information collected by JM Funds Security (ACN 632 484 201) and JM Funds Management (ACN 632 413 864) and all of its wholly-owned subsidiaries, together referred to in this Policy as “JM Capital Group”, “us”, “our” or “we”. It outlines how JM Capital Group collects and uses your personal information in accordance with the Privacy Act 1988 and the Australian Privacy Principles.
How we deal with your personal information.
When you make contact with JM Capital Group, you usually have to identify yourself by providing your personal information. We may not be able to do business with you or answer your inquiry if we are not able to identify you.
The type of information we collect and hold
Depending on the type of contact you have with us, we may collect and hold a range of different kinds of personal information about you. This may include your name, current and previous addresses, date of birth, telephone number, email address, bank account, and credit card details, credit history, concession or discount entitlements, shareholdings, qualifications, proof of right to work, and information about the services provided to you. This is not an exhaustive list. For more details on the information we collect and hold depending on the type of contact you have with us, please see the relevant collection statement on our website at https://www.jmfundsgroup.com/privacy-policy
How personal information is collected
Directly from you: Unless it is unreasonable or impracticable to do so, we try to collect your personal information directly from you. We may contact you through our website, by social media, by telephone, through letters and emails, or in person.
From third parties: We may also collect personal information about you from third parties, including your authorized representative, our agents or third parties with whom we have business relationships.
Why we collect your personal information.
We collect your personal information so we can identify you and interact with you for the purposes of:
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providing products and services to you;
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Managing and administering the products and services; and
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Letting you know about our other products and services.
When we disclose your information to or collect your information from a third party.
We may disclose your personal information to third parties in the conduct of our business. If third parties act on our behalf, we may ask them to hold, use and disclose your personal information in accordance with the Privacy Act. We may disclose your personal information to other third parties (often referred to as service providers) that we engage or we are engaged by for the purposes of their work. These third parties include :
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any organisations involved in providing, managing or administering our products or services such as settlement agents, custodians or external dispute resolution services;
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your financial adviser;
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any fund administrator and custodian where you have invested in one of our managed funds;
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any financial institution who holds an account for you;
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any professional advisers appointed by us;
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businesses that may have referred you to us; and
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other Moelis Australia associated entities located globally.
These third parties may provide us with personal information they have collected from you in the course of providing relevant products or services.
Like other financial services companies, there are situations where we may also disclose your personal information where it is:
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required by law (such as to the Australian Securities and Investments Commission or AUSTRAC);
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required by the relevant operating exchange such as ASX or Chi-X under the respective market operating rules and that information may be used by the market for its purposes (for example, in the course of compliance activities);
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authorised by law (such as where we are obliged to disclose information in the public interest or to protect our interests);
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necessary in discharging obligations (such as to foreign governments for the purposes of foreign taxation); and
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required to assist in law enforcement (such as to a police force).
Our Credit Reporting Collection Statement.
Where we provide products or services to you on credit (that is, you will pay for those products or services after we start providing them to you), we are a credit provider for the purposes of the Privacy Act. JM Capital Group Credit Reporting Collection Statement is our Credit Reporting Policy for the purposes of the Privacy Act. It describes how we comply with our credit reporting obligations.
Security and hold of collected information
Securing your information: We store information in different ways, including in hardcopy and electronic form. Our security safeguards include:
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technical solutions, security controls and internal processes to help us protect your information from misuse, interference, loss or unauthorized access, modification or disclosure;
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confidentiality requirements for employees and contractors;
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document storage security policies, systems, and site access restrictions; and
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website security systems, including firewalls and data encryption on our websites.
Information held overseas: We may hold overseas or disclose to third parties overseas your personal and credit-related information. Your personal and credit-related information will most likely be held in those countries listed in our Collection Statements. Where your personal or credit-related information is held overseas, we or the overseas service providers may disclose your information when required by Australian or foreign law.
Our websites
Your protection: Our Privacy Policy applies to the use of our websites and to any personal information you provide via our websites.
Information we collect: We may collect information from our websites that is not personal information, because it does not reveal your identity. We may use or disclose that information to try to locate a person where we believe unlawful or inappropriate activity has occurred in connection with our website, or when required or authorized by law.
How we use cookies: We or a third party engaged by us may send a “cookie” to recognize your computer and greet you each time you visit any of our websites. The cookies are used to:
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review traffic patterns on our website;
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advertise and target our products and services on a website; and
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review customer interest in our online advertising.
How to opt-out of receiving cookies: If you do not wish to receive cookies or publicly available advertising identifiers provided by operating systems like iOS and Android, you can set your browser or device to opt-out.
Access to and correction of personal informaiton
Ensuring your information is correct: We rely on the personal and credit-related information that we receive to conduct our business. We take reasonable steps to make sure the personal and credit-related information we collect, use and disclose about you is correct, complete and relevant for the purpose for which we collect it.
Providing you with access to your information: When you request the information we hold about you, we will try to provide you with a way to access it. For example, we may make the information available to view at our office, or we may post or email it to you. Subject to exceptions permitted by law, we will provide access within a reasonable time. We may charge a fee to cover our costs of providing access, however, we will not charge you a fee for making the request for access or for making any changes to your personal or credit-related information. We may refuse to give you access to your personal or credit-related information in line with the Privacy Act.
Correcting your information: If you believe that any personal or credit-related information we hold about you is not correct, out of date, incomplete, or misleading, then you may ask us to correct it using the contact details in section 11 of this document. We will consider whether the information requires correction and notify you of our review.
Telling a third party about a correction: If we correct any personal information, you may ask us to notify a third party of that correction. We will take reasonable steps to do so.
Complaints handling
Contact us: If you believe that your privacy has been breached or you have a complaint about our handling of your personal or credit-related information, please contact us using the details below. We will investigate your complaint and provide you with a response.
Contact a dispute resolution provider: If you are not satisfied with our response, then you may lodge a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au). If your complaint relates to credit-related information, you may also make a complaint to a third-party dispute resolution provider instead of the Office of the Australian Information Commissioner. We will tell you who the dispute resolution provider is when we write to you about your credit-related complaint.
For privacy complaints or inquiries about our Privacy Policy, you can contact us:
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Any questions: If you have any questions about this Privacy Policy or how we handle your personal information, please contact us using the contact us page on our website at https://www.jmfundsgroup.com/contact
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Different formats of this policy: If you wish to access this policy in a different format, please contact us using the email or postal address below.
Our Privacy Officer: If you feel your complaint or question is not being handled appropriately, please contact our Privacy Officer: Post to The Privacy Officer JM Capital Group, Suite 5B, Level5, 199 Geroge Street, Brisbane, QLD 4000 or email info@jmfunds.com.au with Privacy Officer in the subject line.
How to contact us
You can contact us:
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By website: https://www.jmfundsgroup.com/contact/
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By email: info@jmfunds.com.au
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By telephone: +61 (7) 3211 2171
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By mail: JM Capital Group, Suite 5B, Level5, 199 George Street, Brisbane, QLD 4000
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In-Person: JM Capital Group, Suite 5B, Level5, 199 George Street, Brisbane, QLD 4000
Changes to this policy
This Policy is subject to change from time to time as JM Capital Group considers necessary. We will publish material changes by making them available on our website.