Privacy Policy
About this policy
Seven Fields recognise the importance of your privacy to you. This policy has been produced by Seven Fields Pty Ltd ABN 58 105 363 120 to provide you with information on the collection, storage, use and disclosure of your personal information by Seven Fields Pty Ltd ABN 58 105 363 120 and its related companies ("Seven Fields"). When referring to personal information, we mean information or a statement of opinion about a person whose identity is apparent or can reasonably be ascertained.
Seven Fields abides by the National Privacy Principles established
under the Privacy Amendment (Private Sector) Act 2001. A
summary of the National Privacy Principles is available by
contacting our office. Our contact details are provided at the end
of this document.
About us
Seven Fields Management Limited ('SFML'), a company in the Seven
Fields group, holds Australian Financial Services Licence No.
233189. Representatives of SFML may provide investors with general
advice only on the investment products that are included on our
approved product list.
Information collection policies
As an organisation, we are subject to legislative and regulatory
rulings that requires we obtain and hold the personal information
of clients. Information we hold about you may include your contact
details, bank account details and tax file numbers.
We will not collect any personal information about you unless you
have knowingly provided that information to us or authorised a
third party to provide that information to us.
Information use and disclosure policies
We will not use or disclose personal information collected by us
for any purpose other than:
(a) the purposes for which it was provided or a related
secondary purpose where you would reasonably expect us to use or
disclose the information; or
(b) where you have consented to such disclosure; or
(c) where required or authorised under law, in circumstances
relating to public health and safety and in connection with certain
operations by or on behalf of an enforcement body.
We are obliged under the Corporations Act 2001 to
maintain certain transaction records and make those records
available for inspection by the Australian Securities and
Investments Commission. In addition, we may contract external
parties to conduct due diligence, compliance or financial audits.
This may involve the disclosure of your personal information.
If you choose to invest in a scheme promoted by us, your
information may be used to:
(a) Advise the Australian Tax Office (ATO) of your tax file
number. If you choose not to provide us with your tax file number,
tax may be deducted from you by the ATO, at the highest marginal
tax rate.
(b) Advise the Australian Transaction Reports and Analysis Centre
(AUSTRAC) of any suspicious transactions or any other information
as required under the Anti-Money Laundering and
Counter-Terrorism Financing Act 2006.
(c) Enter your details on the register of the members of the
scheme, which is available for inspection in accordance with the
Corporations Act.
(d) Communicate with you about your investment.
(e) Make deposits of distributions to your nominated bank
account.
(f) Provide details to mortgage providers and your bank in
accordance with your express authority.
We may use the personal information collected from you for the
purpose of providing you with direct marketing material that may be
of interest to you, however you may request not to receive such
information and we will give effect to that request. Please allow
two weeks for your request to be actioned.
Your personal information may be provided to other companies
within the Seven Fields. It is a condition of our agreements with
each of our representatives and staff that they adopt and adhere to
this privacy policy. If you have any concerns in this regard, you
should contact us.
Document storage and security policies and
practices
Your personal information is generally held in computer
databases.
We will at all times seek to ensure that the personal information
collected and held by us is protected from misuse, loss,
unauthorised access, modification or disclosure. At all times your
personal information is treated as confidential. All computer-based
information is protected through the use of access passwords on
each computer, and data is backed up each evening and stored
securely off site.
In the event you cease to have a relationship with Seven Fields client, any personal information we hold about you will be maintained on site or in a secure off site storage facility for up to seven years in order to comply with legislative and professional requirements. After that time the information will be destroyed. Please note that if you are an investor in any of our investment products, your records will be maintained for a period of seven years after the termination of that investment product.
Gaining access to your personal information
You may request access to your personal information at any time
and we will require you to provide evidence of your identity prior
to providing access in accordance with this policy. We will provide
you with access to information by either providing you with copies
of the information requested, allowing you to inspect the
information requested or providing you with an accurate summary of
the information held.
We will not provide you access to personal information which would
reveal any confidential formulae or the detail of any in-house
evaluative decision making process, but may instead provide you
with the result of the formulae or process or an explanation of
that result.
The National Privacy Principles place other restrictions on
accessing your personal information. Restrictions include where the
provision of access would have an unreasonable impact on the
privacy, or would pose a serious and imminent threat to the health,
or any individual; the request for access is frivolous or
vexatious; or the provision of access is unlawful or would be
likely to prejudice a criminal investigation.
If we decline your request for access, we will provide you with an
explanation for that refusal.
We will try to ensure that, at all times, the personal information we hold about you is accurate and up to date. If you can show us that the personal information we hold about you is inaccurate, incomplete or outdated, and we agree that the information requires correcting, we will take all reasonable steps to correct it.
How a privacy complaint may be made
We are committed to providing you with a fair and responsible
system for handling complaints. If at any time you have any
complaints in relation to privacy, please contact our Privacy
Officer at one of the contact points referred to below. We will try
to resolve any concerns you may have to your satisfaction within
seven days however, if you are unhappy with our response, you are
entitled to contact the Office of the Privacy Commissioner who may
investigate your complaint further.
Our contact details:
To: The Privacy Officer
Seven Fields Pty Ltd
Address: Ground Floor, 62 Charlotte St, Brisbane QLD 4000.
Telephone: (07) 3120 3322
Facsimile: (07) 3120 3399
E-mail: info@sevenfields.com.au
Additional information about privacy in Australia may be obtained by visiting the web site of the Office of the Federal Privacy Commissioner at www.privacy.gov.au
Seven Fields Pty Ltd ABN 58 105 363 120
Last Updated: 19 August 2011