Celeste Funds Management Limited treats the privacy of your personal information with the utmost importance. We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles which came into force on 12 March 2014. We collect, and are required to collect under Anti Money Laundering and Counter Terrorism legislation, personal information when you invest in our products and services. At other times, we may also be required by law to collect personal information. Due to the nature of our products and services we are unable to deal with you anonymously or by pseudonym.
What personal information do we collect
We collect, hold and use unit holder’s personal information. This includes name, address, bank account details, tax file number, contact details, application and redemption history, and is collected directly from the unitholder.
Why do we collect and hold personal information and how do we use it
Personal information for each unitholder is held and used to deliver our products and services to you.
In the course of doing business, a unitholder’s information may be disclosed to third parties including the custodian, auditors, lawyers and other contractors and, where expressly authorised by law or by court order, to government agencies such as the Australian Taxation Office (ATO), the Australian Securities and Investments Commission (ASIC) and the Australian Transaction Reports and Analysis Centre (AUSTRAC). In order for us to carry on our business we also are required to meet the requirements of the Foreign Accounts Tax Compliance Act (FATCA), a piece of United States of America legislation. If you are a US citizen or resident, this may require us to provide your personal information to US authorities.
At times, we will also contract external experts to assist in enhancing our products, services and systems. These third parties are bound by confidentiality arrangements when handling your personal information.
If you used a financial adviser who recommended your investment in our products and services (as indicated on your application form), then details of your investments will also be provided to that financial adviser.
We will not sell, rent, trade or otherwise disclose to third parties any personal information about you without your consent, or unless we are required to do so by law or under a court or tribunal order, or a permitted general situation exists within the meaning of the Privacy Act 1988 (Cth), or we reasonably believe disclosure is necessary for an enforcement related activity. We do not use your personal information for marketing purposes, nor do we make it available for others to use for marketing.
All collection, use and disclosure of unitholder information is lawfully authorised, required or permitted. Otherwise, unitholder information is kept confidential and only disclosed to the unitholder or an authorised representative. Unitholders have certain rights including access to and correction of information, and the right to complain about any breaches of the Privacy Act.
Accuracy of personal information
We take every reasonable step to ensure that the personal information we collect, use or disclose is accurate, complete, relevant and up-to-date. If you wish to view the personal information we hold about you please contact the Company Secretary in writing with your request at the following address:
Celeste Funds Management Limited
GPO Box 4266
SYDNEY NSW 2001
or by email at email@example.com. In some very limited circumstances we may not be able to meet your request. Please contact us immediately on 02 9216 1800 or email us on firstname.lastname@example.org if your details change or you become aware that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading. We may ask for certain proofs in regard to your information in some circumstances before we update the information. If we decide that amending the information we hold is not appropriate we will advise you accordingly. If you believe our decision is wrong you can complain about that decision using the process described below.
If you have a complaint about a privacy issue
If you have a query or complaint about a privacy matter relating to the personal information we hold or how we have used it please contact the Company Secretary in writing or email at the above address. We will acknowledge your concern promptly, investigate the concern, and reply to you advising of any decision and informing you of any remedies available, including possible appeal through dispute resolution bodies. We will endeavour to do this within 30 days but this may not be feasible depending on the nature of your complaint.
Security of personal information
We take all reasonable precautions to ensure the security of your personal information. This includes physical and technological procedures to protect this information.
Access is restricted to only those employees, directors and third party contractors who require your personal information to perform their services.
We receive information when you visit our website such as the date and time of your visit, server address and domain name. This information is used for statistical purposes only. No personal information is collected, held or disclosed on our website.