Substancia Pty Ltd and Substancia Capital Limited (‘Substancia’) respect and uphold investors rights to privacy protection under the Australian Privacy Principles contained in The Privacy Amendment (Enhancing Privacy Protection) Act 2012. This Policy describes how we manage any personal information we have about you.
Information or material entrusted to Substancia by clients and investors, maintained or held in relation to clients and investors, or concerning the business, transactions or affairs of Substancia itself (other than what is in the public domain) will be secured appropriately and kept confidential at all times. Only authorised personnel will have access to such information.
What personal information does Substancia hold about its clients and investors?
Substancia may hold the following personal information about you:
- name, residential and mailing addresses;
- telephone number(s) and email addresses;
- date of birth and other identification information such as driver’s licence or passport details;
- tax file numbers;
- transaction details associated with your investments and transactions;
- the name and contact details of your investment advisor; and
- financial institution account details.
What does Substancia do with my personal information?
We use personal information about you:
- to make distributions payments to you;
- to record your ownership details on the unit register for your investment;
- to assist with any calls you make to us;
- to communicate offers and opportunities to you; and
- for our administrative, marketing, planning, product development and research requirements.
At any time you may opt out of receiving any communications from us, other than as required for the operation of our business (for example, for the payment of distributions).
Information about others that you provide to us
If at any time you provide the personal information of another person to us then you must first ensure that that person (or their parent or guardian if they are under 18) has read and understood this statement and separately consented to that personal information being used and disclosed by us for the above purposes.
To whom does Substancia disclose information about you?
There are certain people and organisations to whom we disclose your personal information. We may disclose information about you to any of the organisations that we use in the ordinary administration of our business, including:
- providers of administrative and management services, technology services, and any other related business services, including entities we may outsource these activities to;
- your financial advisor;
- your bank or other financial institution for such matters as making distribution payments or processing receipts;
- entities we use for printing and/or mailing your statements and reports, newsletters and other correspondence to you; and
- auditors, consultants, legal and accounting firms, industry bodies and associations and persons undertaking compliance reviews.
Substancia takes its obligations to protect your personal information seriously. We believe that it is unlikely that we will disclose any personal information to overseas recipients. Where this may occur, we may obtain your prior consent.
Using Government Identifiers
Although in certain circumstances we are required to collect government identifiers such as your licence, passport or tax file numbers, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.
Collection of information on our website
Access to your information
You may request details of the information we hold about you at any time by contacting the Privacy Officer, please note that access to information is subject to some exemptions allowed by law.
- Privacy Officer
- Substancia Pty Ltd
- Level 1, 274 Coventry St
- South Melbourne VIC 3205
- Phone: 03 9645 0840
- Fax: 03 9649 7253
Please contact our office if you wish to complain about any breach or potential breach of your privacy rights. From receipt of your complaint, the Privacy Officer has 30 days to respond. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner.