Overview

Bacena Capital Pty Ltd is committed to protecting the privacy of the people we deal with and seeks to uphold high standards of privacy practice and security. This policy explains how we handle personal information.

Whenever we handle personal information, we seek to ensure that appropriate standards of privacy practice and security are applied.

This policy outlines why we need to collect personal information, how we collect it, what we do with it, how it is stored, and who we might share it with. The policy also describes how you can access or correct information we hold about you, ask further questions, or make a complaint. We will update this privacy policy when our information handling practices change. Updates will be published on our website and through our email lists.

Collection of your personal information

For most products and services, we must collect ‘personal information’ such as your name, identity details, contact details, transaction information, and other personal details where needed (such as your tax file number and financial information).

Sensitive Information

Generally, we do not collect sensitive information about you unless required by law or where you consent to us doing so (only where it is relevant to your product). Sensitive information includes information relating to race, political or religious beliefs, sexual orientation, criminal history and association memberships. We may collect information about your affiliation with specific organisations, such as professional associations.

Why do we collect personal information?

We collect personal information about you that is reasonably necessary to:

• provide you with our products or services;
• consider applications and approaches you make to us;
• conduct marketing;
• maintain your contact details; and
• fulfil our legal obligations, such as those relating to taxation, anti-money laundering and counter-terrorism financing

or as otherwise authorised by you.

Without such information, we may be unable to process your application or provide you with an appropriate level of service.

How we collect your information

We collect personal information about you directly from you – this can be in person, in documents you give us, from telephone calls, emails or from transactions you undertake with us.

We may also collect your personal information from third parties, including public sources, your adviser(s), agents, referrers, brokers, our related companies and service providers (including credit reporting bodies and information service providers).

How we store your information

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. We protect personal information against misuse or loss where this occurs.

We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints.

How we use your information

We use personal information about you for the purpose for which it was provided to us, including to:

• process applications for investments in our managed funds;
• administer and manage our products and services (including monitoring, auditing, and evaluating those products and services); and
• communicate with you and deal with or investigate any complaints or

We may also use your personal information for related purposes, which would reasonably be expected without your permission. For example, we may occasionally use your personal information to inform you of investment opportunities or provide information about products and services that interest you. However, if you do not want to receive such communications, you can tell us by using the methods listed below.

While we may sometimes share personal information with companies we do business with (e.g. in product development, joint venture arrangements or distribution arrangements), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.

When your information is disclosed

We may disclose personal information outside of Bacena Capital Pty Ltd:

• 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 auditing, accounting, legal, mailing, marketing, insurance, identity verification, trustee, website and technology services);
• to your nominated financial adviser with your permission; and
• as contained in the terms and conditions of our product or

It is unlikely that any parties to whom we disclose personal information operate outside Australia. However, where this occurs, we will take steps to protect 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 possible. If you feel our information about you needs to be more accurate or complete, you can contact us anytime to ask for corrections.

Keeping information secure

We use security procedures and technology to protect the information we hold. Access to and use of personal information within Bacena Capital Pty Ltd seeks to prevent misuse or unlawful disclosure of the information, including internal policies, training, and staff monitoring.

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 it or permanently de-identify it according to relevant laws.

How you can access or correct your information

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 explain 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 note your requested correction with the information.

Contact Us

If you have any questions or complaints regarding privacy or information handling, please write to L2, Elkhorn Plaza West, 29 Elkhorn Avenue, Surfers Paradise, 4217, Australia, or enquiries@bacena.com.au or call us on 1300 000 009. Please mark communications to the attention of the Chief Executive Officer. We will respond to let you know who will be handling your matter and when you can expect a further response.

Suppose your concerns still need to be resolved to your satisfaction. In that case, you can lodge your complaint with the Financial Ombudsman Service (details below), an external dispute resolution service we are a member of.

Financial Ombudsman Service Limited:
Telephone:    1800 367 287
Email:             privacy@fos.org.au
Facsimile:      03 9613 6399
Website:        www.fos.org.au.

Policy updated: Saturday, December 21, 2024