Privacy Policy

Alleron Investment Management Pty Ltd Privacy Policy

This Privacy Policy sets out how and why Alleron Investment Management Pty Ltd ABN 71 109 874 160 (“Alleron”) collect, store, use and disclose your personal information. This policy also covers any financial services Alleron provides to you, such as by providing investment management services via a collective investment vehicle where Alleron is a Trustee or has been appointed an investment manager or other service provider. By using any of our services or otherwise providing Alleron with your personal information (or authorising it to be provided to Alleron by someone else), you agree to your personal information being handled as set out in this Privacy Policy.


Alleron abides by the Australian Privacy Principles (“APPs”), which provides a scheme in relation to the collection, disclosure, use and storage of personal information. Alleron’s objective is to handle information responsibly and provide you with some control over the way information about you is handled. The Privacy Act 1988 provides exemptions in relation to employee records relating to current or former employment relationships between Alleron and an individual.


Revisions to this Privacy Policy

Alleron may update this Privacy Policy from time to time. Your continued use of our 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.


What personal information does Alleron collect?

Alleron only collects personal information that is necessary to assist Alleron in providing services to clients. Alleron generally collects personal information such as name, phone numbers, address, email address, banking details, date of birth, country of residence, investment details, taxation details (including Tax File Numbers) and other accounting, audit and financial services related information. If you provide Alleron with personal information that Alleron has not requested (unsolicited personal information) Alleron will, unless otherwise required or permitted by law, delete or destroy it was soon as possible after receiving it.


In certain circumstances Alleron may be required or permitted by law or Court or Tribunal order to collect certain personal information about you. For example, Alleron may need to collect your name, residential address, country of residence, date of birth, business name (if any), directorship appointments (if any) 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 and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (“AML/CTF Laws”)

• Income Tax Assessment Act 1997 / Tax administration Act 1953

• Superannuation Industry (Supervision) Act 1993


You do not have to provide Alleron with your personal information but if you do not provide Alleron with the personal information that Alleron has requested, Alleron may not be able to provide services or assistance to you or clients on your behalf.


How does Alleron collect personal information?

Alleron may collect your personal information in various ways, including via telephone, email or hardcopy forms. In most situations Alleron collects your personal information directly from you. However, Alleron may also collect information from third parties, such as trustees and Responsible Entities, asset consultants, companies/trusts in which you are a unit holder, shareholder or officeholder and/or anyone you have authorised to deal with Alleron on your behalf.


Depending on the type of services requested, Alleron may also seek to collect information about someone else from you (for example, details of members of your company/fund or your employees/contractors). However, you must not provide Alleron 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 handed in accordance with this Privacy Policy and where they can find it. On all occasions personal information is collected, held, used and disclosed by Alleron in accordance with this Privacy Policy.


Why does Alleron collect and use personal information?

Alleron only collects, holds and uses personal information for the purposes for which it was provided, related purposes or as permitted or required by law. Such purposes may include:

• establishing, maintaining and administering your account or investment;

• conducting verifications, monitoring and reporting required under the AML/CTF Laws;

• recording tax information such as a Tax File Number (“TFN”), ABN, country of residence in order to report to the Australian Taxation Office (“ATO”) and other relevant bodies as required by law and withhold tax correctly from payments;

• communicating with you regarding the status of your unit/share holdings, value, distributions or responding to your enquiries and/or information requests;

• processing authorised payments to and from you;

• providing you with the services requested, either by Alleron or through a third party service provider;

• quality assurance and training purposes; and

• any other uses identified at the time of collecting your personal information.


Who does Alleron disclose personal information to?

Any personal information provided to Alleron may be disclosed, if appropriate, to other entities in order to facilitate the purpose for which the information was collected. Such entities generally include:

• the ATO for the purpose of legislative compliance and reporting;

• the Australian Securities and Investments Commission (“ASIC”) and/or the Australian Securities Exchange (“ASX”) for the purpose of legislative compliance and reporting;

• third party service providers for the purpose of enabling them to provide a service such as unit registry, audit and tax and/or manage a product;

• your personal financial advisor/planner/asset consultant and their service providers (if you have provided consent for such disclosure) for the purpose of managing your affairs;

• government bodies, regulators, law enforcement agencies and any other parties where authorised by law;

• other entities if you have given your express consent; and

• any other entities identified at the tie of collecting your personal information or to which Alleron is legally required to disclose your personal information.


You also acknowledge that, if Alleron is required to provide your personal information to a service provider nominated by you and they are located outside of Australia, Alleron will no longer be required to take reasonable steps to ensure the overseas recipient’s compliance with Australian privacy laws in relation to your personal information. Additionally, Alleron will not be liable to you for any breach of the Australian privacy laws by these overseas recipients. On this basis, you consent to such disclosure.


How does Alleron protect personal information?

Alleron takes reasonable steps to protect any personal information that Alleron holds from misuse, interference and loss and from unauthorised access, alteration and disclosure. However, you acknowledge that data protection measures are never completely secure and, despite the measures Alleron has put in place, Alleron 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 Alleron as soon as possible if you become aware of any security breaches.


Accessing your personal information held by Alleron

You may access your personal information Alleron holds, subject to legal restrictions or exemptions. Where such restrictions or exemptions exist, Alleron will advise you of those reasons at the time of your request. If you wish to access the personal information Alleron holds about you or request correction of it, you should contact the Privacy Officer using the contact details below.


While Alleron does not charge you a request for accessing your personal information you should be aware that Alleron may charge a reasonable fee, which you will be notified of once you make a request) for time and cost if an extended amount of time is required to collate and prepare material for you.


How can you correct and update your information?

Alleron takes reasonable steps to ensure that the personal information Alleron holds about you is accurate, complete and up-to-date. However, Alleron also relies on you to advise us of any changes to your personal information. If there are any changes to your personal information or if you believe the personal information Alleron holds about you is not accurate, complete or up to date, please contact us using the contact details below as soon as possible.


What to do if you have a complaint?

If you want to make a complaint about a breach of this Privacy Policy or the privacy principles of the Privacy Act 1988 you can contact Alleron using the contact details below. You will need to provide Alleron with sufficient details regarding your complaint together with any supporting evidence. Alleron will refer your complaint to the Privacy Officer who will investigate the issue and determine the steps (if any) that Alleron will undertake to resolve your complaint. Alleron will contact you if additional information is required and will notify you in writing of the outcome of the investigation.


If you are not satisfied with Alleron’s determination, you can contact Alleron to discuss your concerns or complain to the Australian Privacy Commissioner via


Officer of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
GPO Box 5218


Contact us

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


Privacy Officer
Alleron Investment Management Pty Ltd
Suite 14, Level 14
14 Martin Place

Phone: +61 2 8252 7559