At Defender AM, we are committed to protecting our privacy in accordance with the Privacy Act 1988 (Cth). This Policy describes our current policies and practices for collecting, handling, using and disclosing personal information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected.
What information do we collect and how do we use it?
When we want to provide you with quality products or services (this may include consumer facing services conducted by Defender AM or services and advice provided by entities involved in the investment activities undertaken by Defender AM and its related entities), we ask you for the information we need to, consider applications and approaches you make to us, conduct marketing and social functions, maintain your contact details, fulfil our legal obligations, such as those relating to taxation and anti-money laundering and counter-terrorism financing, administer and manage our products and services (including monitoring, auditing, and evaluating those products and services), model and test data (in a controlled environment), develop scores, risk assessments and related analytical tools, communicate with you and deal with or investigate any complaints or enquiries.
This can include a broad range of information ranging from your name, address, contact details and age to other information about your personal affairs including name, identity details, photos, contact details, transaction information and other personal details where needed (such as gender, marital status and financial information).
We also use your information to enable us to manage your ongoing requirements and our relationship with you and therefore we may also: De-identify your data for our own purposes including market research and fraud mitigation, use your personal information for related purposes which would reasonably be expected without your permission. For example, we may from time to time 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.
We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
We may also use your information internally to help us improve our services and help resolve any problems.
What if you don’t provide some information to us?
If you do not provide us with some or all of the information that we ask for, we may not be able to accept investor applications and / or issue units in the relevant MIS.
How do we hold and protect your information?
We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
Access to and use of personal information within Defender AM seeks to prevent misuse or unlawful disclosure of the information – this includes internal policies, auditing, training and monitoring of staff.
If other organizations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.
Where the personal information we collect is no longer required, we delete the information or permanently de-identify it in accordance with relevant laws and our records management policy.
We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include storage on the cloud. Where this occurs, we take steps to protect personal information against misuse or loss.
We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints.
Will we disclose the information we collect to anyone?
We may share personal information within Defender AM, and may disclose personal information outside Defender AM:
as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator
to our service providers, who provide services in connection with our products and services (including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, data processing, data analysis, information broking, mailing, marketing, research, investigation, insurance, identity, verification, maintenance, trustee, securitization, website and technology services) as contained in the terms and conditions of our product or service.
We may also disclose your personal information (on a confidential basis) in connection with the undertaking of our principal investment activities including, but not limited to the management of any parts of our business or assets, and the provision of any debt to another party. However, we will take all reasonable steps to ensure that they protect your information in the same way that we do.
In some circumstances the parties to whom we disclose personal information may operate outside of Australia – this includes locations in: Australia; Austria; Brazil; Canada; China; Denmark; France; Germany; Hong Kong; India; Indonesia; Ireland; Japan; Luxembourg; Malaysia; Mexico; Netherlands; New Zealand; Philippines; Russia; Singapore; South Africa; South Korea; Spain; Switzerland; Taiwan; Thailand; United Arab Emirates; United Kingdom; United States of America. Where this occurs, we take steps to protect personal information against misuse or loss.
How can you check, update or change the information we are holding?
We take reasonable steps to ensure that all information we hold is as accurate as 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.
You can contact us 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 (if we can). 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.
What happens if you want to complain?
Specific responsibilities of the Board include:
• Protecting the reputation of the Group
• Appointment and removal of the Chief Executive Officer and any senior executives
• Ensuring appropriate resources are available to senior management
• Providing strategic direction for the Group’s corporate strategy
Day to day management of the Group and implementation of Board policies and strategies is carried out by the Managing Director.
The Group’s management comprises the Chairman (Christopher Bregenhoj) and Benjamin Doyle as Non-Executive Directors, James Manning as Managing Director and Christopher Bregenhoj as Company Secretary. The objective of the Group’s executive reward framework is to ensure reward for performance is competitive and appropriate for the results delivered.
The board ensures that executive reward satisfies the following criteria for good reward governance practices:
• Competitiveness and reasonableness
• Acceptability to shareholders
• Capital management
The remuneration structure for directors, secretaries and any senior managers is based on the following factors:
• Experience of the individual concerned
Performance of senior executives is reviewed by the Board as part of the ordinary course of meetings of the Directors.
There have been no departures from Principle 1 during the period ending 31 March 2015.