Privacy & Security

What is this policy about?

Allard Partners Limited and Allard Partners Australia Pty Limited (collectively referred to as “Allard Partners”) recognise the importance of ensuring that its clients have confidence in the way Allard Partners handles personal information.

This document sets out the policy of Allard Partners for handling personal information and has been prepared to:

1. provide Allard Partners representatives with information about what they can do with personal information collected from clients; and
2. provide clients with information about what Allard Partners can do with their personal information.

Allard Partners is bound by, and committed to the terms of the Privacy Act 1988 and the National Privacy Principles forming part of that Act. A summary of the National Privacy Principles is available by contacting our office.
Our related company

Allard Partners has a related company, Allard Partners Management Limited, which is registered in the Cayman Islands. The Privacy Act permits Allard Partners to share the personal information which it holds with its related company, unless you request otherwise. If our related company is entitled to use that personal information, it may only do so for the purposes for which the personal information was collected by Allard Partners.

What is personal information?

Personal information is any information about an individual that identifies the individual or by which their identity can reasonably be ascertained.

What kinds of personal information do we collect and hold about you?

Allard Partners only collects personal information that is necessary for one or more of its functions or activities.

Allard Partners is subject to certain legislative and regulatory requirements which necessitate it obtaining and holding detailed information which personally identifies clients and may contain information or an opinion about our clients (“Personal Information”).

The types of Personal Information which are collected from our clients and suppliers (including employees of our clients or suppliers) include name, address and other contact details, as well as information about products and services which those individuals request from Allard Partners from time to time. The Personal Information collected may also include information pertaining to a client’s financial circumstances including income and net assets (to confirm that person is a wholesale client).

Allard Partners will not collect any Personal Information about a client except where the client has knowingly provided that information to us or authorised a third party to provide that information to us. Generally collection of Personal Information will be effected in either a face-to-face interview, over the telephone, by way of an application form or other client establishment documentation. From time to time additional and/or updated Personal Information may be collected through one or more of those methods.

Allard Partners will only collect, maintain and use Personal Information about clients if it is necessary to adequately provide the clients with the services requested including: making Financial Products recommendations;

arranging Financial Products transactions on your behalf;
investing in Financial Products on behalf of the Fund; or
providing custodial services (which are incidental to the operation of the Fund)

and all things necessary or incidental to the above.

How is Personal Information collected?

Most information we hold about clients is collected from the client's application form. Information may also be collected over the phone or via the internet during the course of the client's relationship with Allard Partners. Sometimes, information about an individual is collected from other people or organisations. For example, information about a director of a corporate customer may be obtained from a public record relating to the company.

Regardless of how it is collected, all Personal Information is handled in accordance with this Privacy Policy.

What does Allard Partners use your Personal Information for?

Allard Partners uses the Personal Information it holds in order to provide its clients with the services they request. Allard Partners will not use or disclose Personal Information collected by us for any purpose other than:

(a) the purposes for which it was provided or secondary related purposes in circumstances where a client would reasonably expect such use or disclosure; or
(b) where the client has consented to such disclosure; or
(c) where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.
Allard Partners Australia Pty Limited is required under the Corporations Act to make certain information available for inspection by the Australian Securities and Investments Commission on request to ensure ongoing compliance with licensing and regulatory requirements. This may involve the disclosure of clients’ Personal Information.
Allard Partners’ services include funds management services and related investment advice. Providing a client with services includes undertaking activities such as administering the client's accounts or investments, providing client support, responding to inquiries and requests for product information and meeting regulatory requirements.

If Allard Partners is unable to collect Personal Information from or about an individual, it may not be able to do business with that individual or the organisation with which the individual is connected.

Allard Partners may disclose clients Personal Information to external contractors for the following purposes:

(a) execution, clearing and settlement of financial product transactions;
(b) registration and/or changes to investor details;
(c) accounting for financial products transactions;
(d) causing statutory audits to be conducted as required by law;
(e) maintenance and service of our information technology systems; or
(f) in the course of reviews by external consultants.
We may also use Personal Information for our own internal purposes and we may use that information for marketing purposes, to inform you about new products and services from time to time. If you do not wish to receive marketing material from Allard Partners, please let us know by contacting info@allardpartners.com and we will cease sending it to you.

Allard Partners may also collect Personal Information from its suppliers in order to complete business transactions and purchase products and services.
If we want to use your information for purposes other than those set out above, we will request your consent.

Does Allard Partners disclose the Personal Information it holds?

Sometimes Allard Partners obtains services from other organisations and where necessary (and where the law permits), Personal Information may be provided to those organisations. The kinds of services obtained externally by Allard Partners include information technology support, financial advice, custodial and administrative services, legal advice, compliance advice and the use of settlement and clearing systems.

External service providers are only authorised to use Personal Information for the purpose for which Allard Partners supplied it. Those organisations are not authorised to use that Personal Information for their own purposes.

Where a client nominates someone to act on their behalf, Allard Partners may provide information to that person, for example, the client's accountant or financial adviser.

Sometimes, the law requires Allard Partners to disclose Personal Information. For example, information may be disclosed to a court in response to a subpoena or to a Government agency such as the Australian Taxation Office on receipt of a direction issued under taxation laws.

Security and accuracy of Personal Information

Allard Partners will take reasonable steps to ensure that all Personal Information we collect or use is:

• Accurate, complete and up-to-date;
• stored in a secure environment; and
• accessed only by authorised personnel for permitted purposes.

If your details change, we ask that you advise us of the change as soon as possible in order that we may maintain accurate records.

Website

Allard Partners has implemented procedures and installed equipment to safeguard the security and confidentiality of Personal Information collected via our website. We continually review these arrangements to ensure that we are doing all that is reasonably and technically feasible at the time to protect your information, although because of the nature of the internet, we cannot guarantee that it is totally protected from hackers or misuse.

This Privacy Policy does not apply if you access another website through a link from ours. In this case the privacy policy of the owner of the other website (if any) will apply. We cannot and do not make any warranty or representation as to the practices of any linked websites in the handling of your Personal Information.

Access to Personal Information

You are entitled to access most Personal Information Allard Partners holds about you (subject to the exceptions listed below). If you would like access to your Personal Information, please contact us at:

Allard Partners Limited
Suite 3106, 31/F Alexandra House
18 Chater Road, Central
Hong Kong

Tel: +852 2526 9168
Fax: +852 2869 9087

OR
Allard Partners Australia Pty Limited
Suite 1203, Level 12, Royal Exchange Building
56 Pitt Street
Sydney, NSW 2000
Australia

Tel: +61 (2) 9247 7888
Fax: +61 (2) 9251 2566

OR

Email: info@allardpartners.com
Website: www.allardpartners.com

Allard Partners will not provide you with access to your Personal Information if:

(a) providing access would pose a serious threat to the life or health of a person;
(b) providing access would have an unreasonable impact on the privacy of others;
(c) the request for access is frivolous or vexatious;
(d) the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
(e) providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
(f) providing access would be unlawful;
(g) denying access is required or authorised by or under law; or
(h) providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

In the event Allard Partners refuses you access to your Personal Information, we will provide reasons for making this decision.

Resolving concerns

If you believe that the privacy of your Personal Information has been compromised, you are entitled to complain. Complaints can be made by contacting the person you were dealing with or by contacting us on the above numbers or at the above addresses. We will respond to complaints as soon as possible.

It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.

Additional information

If you would like more information about Allard Partners’ approach to privacy, you are encouraged to contact us on the above numbers or at the above addresses.