Ophir Asset Management (Ophir) is bound by the Australian Privacy Principles set out in the Privacy Act which impose certain requirements on Ophir with respect to handling personal information. Ophir has implemented procedures to ensure that personal information is handled in accordance with the Act. Ophir has issues this policy in compliance with the Act.
Please read the following policy to understand how Ophir deals with the personal information that it may collect about you from time to time. This policy may change from time to time, so please revisit the policy periodically.
In the course of providing our products and services, Ophir may collect personal information from clients, or potential clients. What types of personal information do we collect? In the course of providing products and services we may collect:
How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you. Where possible, Ophir has attempted to standardise the collection of personal information by using specifically designed forms (e.g. our Application Forms).
We may also collect personal information from other people (e.g. a third party administrator) or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly.
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented. Our uses of personal information include but are not limited to:
We may also need to collect personal information in order to comply with our legal obligations, such as the AML/CTF laws, under the Anti-Money Laundering and Counter Terrorism Financing Act 2006.
It may be necessary for Ophir to disclose your personal information to certain third parties in order to assist us with one or more of our functions or activities. This may include organisations providing fund administration or custodial services under an arrangement with us.
We only collect sensitive information reasonably necessary for one or more of these functions or activities if we have the consent of the individuals to whom the sensitive information relates, or if the collection is necessary to lessen or prevent a serious threat to life, health or safety or another permitted general situation.
We store personal information in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers.
The security of your personal information is of paramount importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure. These steps include:
Personal information we hold that is no longer needed, or required to be retained by any other laws, is destroyed in secure manner, deleted or de-identified as appropriate.
Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies.
We only use personal information for the purposes for which it was given to us, or for purposes which are directly related to one or more of our functions or activities. We may disclose your personal information to government agencies, and other recipients from time to time, only if one or more of the following apply:
We may disclose personal information about an individual to overseas organisations that help us provide our services, in certain circumstances, such as when storing information with a “cloud service provider” which stores data outside of Australia. We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:
We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up to-date. These steps include ensuring that the personal information is accurate, complete and up-to-date at the time of collection and when using or disclosing the personal information.
On an ongoing basis we maintain and update personal information when we are advised by individuals or when we become aware through other means that their personal information has changed. Please contact us if any of the details you have provided change.
You should also contact us if you believe that the information we have about you is not accurate, complete or up-to-date.
You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us. If we do not agree to provide you with access or to amend your personal information as requested you will be notified accordingly.
Where appropriate we will provide you with the reason/s for our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.
If you wish to make a complaint about a breach by us of the Australian Privacy Principles, you may do so by providing your written complaint by email or letter to any one of our contact details as noted below. You may also make a complaint verbally.
We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we may seek further information from you in order to provide a full and complete response.
If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.
The monthly ‘Ophir Letter to Investors’ provides readers with a comprehensive overview of the performance of each Ophir Fund, our current investment insights and broader portfolio commentary.