DUET GROUP PRIVACY POLICY

Last Updated: 12 March 2014


DUET Finance Limited (ACN 108 014 062, AFSL 269287), DUET Investment Holdings Limited (ACN 120 456 572), DUET Company Limited (ACN 163 100 062) and their related entities and subsidiaries (DUET, we, our or us) respect the privacy of our clients and other individuals we deal with in the course of our business. DUET is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act), as well as other privacy laws applicable to us. Where appropriate, we will handle personal information relying on the employee records exemption and the related bodies corporate exemption in the Privacy Act.

The information we collect and hold

DUET may collect, use and disclose the personal information of its clients and other individuals for the purposes of its business operations. In each case, the precise nature of the our collection, use and disclosure of personal information depends on the nature of your interaction with us (for example, the services or products you request and receive from us). We may collect personal information about you in a number of circumstances, including:

  • if you contact us;
  • if we provide you with products or services;
  • if you are, or if you are employed by, one of our service providers, suppliers, contractors or related companies; or
  • if you apply for a job or contract with us (for example, we may collect your contact details, information about your working history and relevant records checks).
We generally hold personal information relating to:

  • the products and services we provide or have provided to you;
  • your financial interests and sometimes your financial position; and
  • your contact details.
We do not generally collect sensitive information about you unless required by applicable laws or rules. Sensitive information includes information relating to:

  • race;
  • political or religious beliefs;
  • sexual preferences;
  • criminal convictions;
  • membership of professional or trade associations or unions; and
  • health information.
We collect personal information about you in a number of ways, including:

  • directly from you (for example, when you provide information to us by phone or email); and
  • from third parties, such as our related entities or from service providers such as Computershare Investor Services Pty Ltd.
If you choose not to provide certain personal information to us, we may not be able to provide you with the products, services or information you require.

How that information is used and disclosed

We collect the personal information we need to provide products, services and information to our clients and for our business operations generally. We use and disclose personal information about you for the purpose for which it was disclosed to us or related purposes which would reasonably be expected by you or otherwise with your consent or as permitted by law.

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. You may ask us to stop sending you information about our products and services by contacting us using the details below.

We may disclose personal information to third parties in relation to our business operations including:

  • to service providers who provide services in connection with our products and services such as Computershare Investor Services Pty Ltd;
  • with your permission, to your nominated financial adviser;
  • to our related entities;
  • our professional advisers, including our legal advisors, accountants and auditors;
  • other persons, including government and regulatory agencies, as required or authorised by law; and
  • organisations that acquire (or propose to acquire) all or a part of our assets or business.
In certain circumstances, we may disclose limited types of personal information to the U.S. Securities and Exchange Commission, located in the United States of America,  in connection with our legal obligations as a foreign exempt advisor under US law.

If your personal information is held by our service provider, Computershare Investor Services Pty Ltd, then Computershare's privacy policy will apply to Computershare's collection, use and disclosure of that information. You should refer to Computershare's privacy policy at https://www.computershare.com/au/help/Pages/privacy-policies.aspx for further details about how Computershare may collect, process, use, store and disclose your information and how you can contact Computershare if you have any queries, or wish to make a complaint, about Computershare's handling of your personal information.

Keeping information accurate and up to date

We take all reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time using the contact details further below and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

Keeping information secure

We use security procedures and the latest technology to protect the information we hold. Access to and use of personal information within DUET is appropriately limited to prevent misuse or unlawful disclosure of the information.

If other organisations 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 take reasonable steps to delete the information or permanently de-identify it unless we are otherwise required or authorised by law to retain it.

How you can access your information

You can contact us to request access to your information. In normal circumstances we will give you access to your personal information that we hold. However, there may be some legal or administrative reasons to deny access. If access is denied, we will provide you with the reason why.

Dealing with DUET online

If you visit DUET's website to browse, read or download information, our system will log these movements. These web site logs are not personally identifiable and DUET makes no attempt to link them with the individuals who browse the site.

Cookies

A cookie is a small data file that contains information about your visit to a web site. This information is provided by your computer during your first visit to a web server. The server records this information in a text file and stores this file on your hard drive. When you visit the same web site again, the server looks for the cookie and structures itself based on the information provided.

Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. We use cookies to help us improve our service to visitors to our site and to ensure that our site stays easy to navigate and useful.

DUET cannot guarantee or accept responsibility for the privacy practices or the content of third party web sites to which we provide links.

Google Analytics

Google Analytics (GA) website measurement software is used to assist in tracking traffic patterns to and from DUET's website, anonymously surveying users of the site. The GA system is used to collect such information as the number of unique visitors, how long these visitors spend on the website when they do visit, and common entry and exit points into and from the website.

This non-personal information is collected and aggregated by GA and provided to us to assist in our analysis of our website. You cannot be identified personally from this information and no personal information is stored about you. GA systems comply with the DUET Privacy Policy.

Contacting us and making complaints

If you have any questions regarding our privacy policy or handling of information, please contact us using the details below:

Telephone: 1800 005 049 or (02) 8224 2701

Address: Level 15, 55 Hunter Street, Sydney NSW 2000

If you wish to make a complaint about the way we have handled your personal information (including if you think we have breached the Privacy Act) you may do so by using the contact details set out above.  When you contact us, please provide us with your email address, name, address and telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you consider that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.