Privacy Policy:

This Privacy Policy sets out how and why April Invest Pty Ltd ABN 33 136 723 432 and related companies including April Group Pty Ltd ABN 73 118 432 170, April Manage Pty Ltd ABN 25 612 991 705 (“April”, “we” or “us”) collects, holds, stores, uses, discloses, secures and otherwise manages your personal information. By using any of our services or otherwise providing us with your personal information (or authorising it to be provided to us by someone else), you consent to your personal information being collected, held, stored, used, disclosed, secured and otherwise managed as set out in this Privacy Policy.

In this Privacy Policy, "personal information" means any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not.

April takes seriously its obligations under the Privacy Act 1988 (Cth) ("Privacy Act"), the Australian Privacy Principles (Schedule 1, Privacy Act) ("APPs"), and any other applicable privacy laws (together, "Privacy Laws"), and we are committed to protecting your privacy. When we request personal information, we will normally explain why we need it, how it will be used and who we may share it with. At all times we will comply with the terms of this Privacy Policy when handling your personal information.

 

What personal information does April collect?

April only collects personal information that is necessary to assist us in providing our services to our clients. April collects personal information when you:

  • interact with our website, 'www.aprilgroup.com.au' ("Website");
  • subscribe to receive communications from us;
  • engage us to provide you with our services or products; and
  • enquire about our services or products over the telephone, via email or via the share registry.

April generally collects personal information such as:

  • names, job titles, contact and address details;
  • information in identification documents (for example, passport, driver’s licence);
  • tax file numbers and other government-issued identification numbers;
  • date of birth and gender;
  • bank account details; and
  • other personal information required to satisfy our obligations under relevant legislation.

The types of personal information we collect from or about you will depend on the nature of your interactions with us.

In certain circumstances we may be authorised, required or permitted by law or a Court or Tribunal order to collect certain personal information about you. For example, we may need to collect your name, residential address, country of residence, date of birth, business name and directorship appointments (where applicable) and other types of personal information required by law, including but not limited to information required under the following:

  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter Terrorism Financing Rules Instrument 2007 (Cth) (“AML/CTF Laws”);
  • Income Tax Assessment Act 1997 (Cth) / Tax Administration Act 1953 (Cth); and
  • Superannuation Industry (Supervision) Act 1993 (Cth).

For certain investors, April may also be required to collect and disclose certain personal information to the Australian Taxation Office ("ATO") in order to comply with the Foreign Account Tax Compliance Act (US) ("FATCA").

You do not have to provide us with your personal information but if you do not provide us with the personal information that we need, we may not be able to provide our services or assistance to you or our clients on your behalf and may not be able to process any application by you for investment in our funds or other products.

Depending on the type of service requested, we may also seek to collect information about someone else from you (for example, details of the members of your company/fund or your employees/contractors). However, you must not provide us with personal information about another person unless you have clear consent from that person to do so, have told them that their personal information will be handled in accordance with this Privacy Policy and where they can find this Privacy Policy. On all occasions personal information is collected, held, used, disclosed and otherwise managed by us in accordance with this Privacy Policy and Privacy Laws.

 

Why does April collect and use personal information?

April only collects, holds and uses personal information for the purpose for which it was provided (which will normally be obvious at the time of collection), a related purpose, or as authorised, permitted or required by law. Such purposes may include:

  • the general management and conduct of our business;
  • establishing, maintaining and administering your account or your investment in any of April’s funds or other products;
  • conducting verifications, monitoring and reporting required under the AML/CTF Laws;
  • recording government related identifiers (as defined in the Privacy Act) including tax information such as TFN, ABN and country of residence, in accordance with the APPs and order to report to the ATO (and other relevant bodies as required by law) and withhold tax correctly from payments;
  • communicating with you or our clients regarding the status of your unit / share holdings, value, distributions or responding to your and/or our clients’ enquiries / information requests;
  • processing authorised payments to and from you;
  • providing you and/or our clients with the services requested (such as unit registry and investor relations services, accounting and fund administration services, payroll services and compliance services);
  • quality assurance and training purposes;
  • complying with our legal obligations; and
  • any other uses identified at the time of collecting your personal information.

In addition to the purposes set out above, April may collect, use and disclose your personal information to inform you of products, services or offers of April, its related companies or commercial partners (such as the Australian Medical Association) which may be of interest to you. Where you are an investor in a fund or other product of April, this may include providing you with direct marketing information regarding the other funds or products of April or its related companies. If you do not wish to receive such material, you can opt out at any time.

We may also use personal information for related purposes that would be reasonably expected by you.

 

Who does April disclose personal information to?

We may disclose personal information to other parties to assist us to implement and administer investments and in order to facilitate the purpose for which the information was collected (or a related purpose). Such entities include:

  • our related bodies corporate in the ordinary course of administering our business and providing our products and services to you;
  • the ATO for the purpose of legislative compliance and reporting;
  • third party service providers for the purpose of enabling them to provide a service, including unit and share registry, payroll, accounting, superannuation administration, audit and tax, secure storage and archiving services, or manage a product (such as trustees, responsible entities and fund managers);
  • your personal financial adviser / planner or legal adviser and their service providers (provided you have given consent for such disclosure) for the purpose of managing your affairs;
  • entities on behalf of which we provide our services to you (including your fund manager, responsible entity, trustee, company for which you work or in which you have shares and the Australian Medical Association);
  • government bodies, regulators, law enforcement agencies and any other parties where authorised or required by law or to comply with our legal obligations;
  • insurance providers;
  • other entities if you have given your express consent; and
  • any other entities identified at the time of collecting your personal information or to which we are legally required to disclose your personal information.

We will not otherwise disclose any personal information unless we seek your consent or where such disclosure is legally authorised or required.

We do not disclose your personal information to other parties located outside of Australia.

 

GDPR

If you are in the European Union ("EU") (including the European Economic Area), the collection and processing of your personal information will be subject to the General Data Protection Regulation (2016/679) ("GDPR"). In providing our services to you, we may collect and process personal information as outlined in this Privacy Policy. Otherwise, including for individual users of our services, we will be a data controller for the purposes of the GDPR and this Privacy Policy includes information that must be provided to you when we collect your personal information.

 

How does April protect personal information?

Whether your personal information is gathered through face-to-face meetings or by interacting with us via telephone, mail, internet or other methods, we take steps to store your information securely. We hold your personal information in a combination of secure computer storage facilities, paper-based files and other formats.

We take a number of steps to protect any personal information that we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure. This includes but is not limited to the following security measures:

  • security procedures for access to our business premises;
  • security procedures within our offices;
  • IT security procedures including password protection, firewalls, intrusion detection and site monitoring;
  • mandatory confidentiality guidelines for all staff within the business (as outlined in all employment contracts); and
  • conducting regular internal reviews to assess whether we have adequately complied with or implemented these measures.

Personal information is held on secure servers or in storage located in controlled, access restricted environments. April’s employees are required to maintain the confidentiality of any personal information held by us.

Personal information may also, in certain circumstances, be held on behalf of April in hard copy or electronic forms by April’s service providers (such as offsite document storage providers, electronic data storage providers or registry service providers).

April enters into agreements with such service providers which impose confidentiality and privacy obligations on the service provider. However, data protection measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your personal information. You must take care to protect your personal information (for example, by protecting any usernames and passwords). You should notify us as soon as possible if you become aware of any security breaches.

 

Links to third party websites

Our Website may contains links to the websites of other entities. If you click on such links, you will be transferred to the website of these entities. April has no control over, and is not responsible for, the privacy practices of these entities. You should read the privacy policy of these entities to find out how they handle your personal information when you visit their websites. This Privacy Policy applies solely to information collected and held by April.

 

Cookies

We may use 'cookies' or other similar tracking technologies on our Website that assist us with tracking how our Website are used and the preferences of our Website visitors. Cookies are small files which store information on your computer, mobile phone or other internet device. They enable the entity that places the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. Cookies can be disabled through your internet browser, however some websites may not fully function the way they are supposed to if cookies are disabled.

While we do not use browsing information to identify you personally, if we use cookies we may record information in relation to how you use our Websites, including which pages you viewed, when you viewed them, whether you reached them via a search engine, and your computer's assigned internet protocol address.

 

Accessing and correcting your personal information

You have a right to request access to the personal information we hold about you. Where you make such a request, subject to certain legal exceptions we will provide you with to access personal information we hold about you. Where such an exception applies and we decide not to provide you with access to any personal information we hold about you,  we will advise you of the reasons for our decision as soon as practical after you make the request.

If we are satisfied that any personal information we hold about you is inaccurate, incomplete, out of date, misleading or irrelevant (having regard to the purpose for which it is held) we will take such steps (if any) as are reasonable in the circumstances to correct that personal information. This may include notifying third parties to whom we have disclosed that personal information. If we do not agree that personal information we hold about you is inaccurate, incomplete, out of date, misleading or not relevant you may ask that we attach a statement to this effect to our record.

If you wish to access the personal information we hold about you or request correction of it, you should contact the team responsible for your file (for example our unit registry department) or our Compliance Manager using the contact details below.

 

How do we maintain the integrity of your personal information?

We take such steps (if any) as are reasonable in the circumstances to ensure that the personal information we hold about you is accurate, complete and up-to-date, and that the personal information we use and disclose is accurate, complete, up-to-date and relevant (having regard to the purpose of the use or disclosure). However, we also rely on you to advise us of any changes to your personal information. You have a right to request the correction of any personal information we hold about you. Please contact us using the contact details below as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete or up-to-date so that we can update our records accordingly.

When we don’t need your personal information anymore we will delete, destroy or de-identify it. If you provide us with personal information that we have not requested (unsolicited personal information) we will, unless otherwise required or permitted by law, delete or destroy it as soon as possible after receiving it.

 

What do you need to do if you have a complaint?

If you wish to make a complaint about a breach of this Privacy Policy or Privacy Laws you can contact us using the contact details below. You will need to put your complaint in writing and provide us with sufficient details regarding your complaint together with any supporting evidence.

We will refer your complaint to our Compliance Officer who will investigate the issue and determine the steps (if any) that we will undertake to resolve your complaint and respond within a reasonable period of time.

We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns or complain to the Office of the Australian Information Commissioner ("OAIC") at enquiries@oaic.gov.au or by phone on 1300 363 992.

 

Access and complaints if you are in the EU

You also have in certain circumstances the right to request that the personal information that is collected from you is erased, its further processing is restricted, or to object to its further processing and the right to data portability. You can also ask that personal information provided by you to us is transmitted to another party. You may also withdraw your consent where it has been provided as a condition of our processing your information or object to the further processing of your personal information in certain circumstances.

If we refuse any request you make in relation to these rights, we will write to you to explain why and how you can make a complaint about our decision. To make a request in respect of these rights or to make a complaint, please contact us via the contact details below. You also have the right to lodge a complaint with a relevant data protection supervisory authority (for example in the place you reside or where you believe we breached your rights).

 

About this Privacy Policy

We will update this Privacy Policy when our information handling practices change, and any amendments will apply to the information we hold at the time of the update. This Privacy Policy incorporates the relevant Privacy Laws.

April regularly reviews its practices and procedures regarding how it collects, holds, uses, discloses and otherwise manages personal information. As a result, April may update this Privacy Policy from time to time, so please review it periodically for changes on our Website.

Your continued use of our services (including any online services), requesting our assistance or the provision of further personal information to us (directly or via an authorised person) after this Privacy Policy has been revised, constitutes your acceptance of the revised Privacy Policy.

 

Contact us

If you have a query relating to this Privacy Policy or wish to make a complaint, please contact us using the following contact details:

Address: Suite 606, 50 Holt Street, Surry Hills, NSW, 2010

Email: info@aprilgroup.com.au

Phone: (02) 9096 3618

 

 

Last updated: July 2020

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