This policy sets out the way Catapult Partners will use, manage and protect your personal information.
The importance of your personal information
We recognise that your privacy is important and that you have the right to control your personal information. The following policy sets out how we will handle your personal information and safeguard your privacy. We will comply with all laws, including the Australian Privacy Principles (APPs), introduced to protect your privacy.
Catapult Partners collects personal information from clients, employees, contractors, shareholders and other individuals. We collect this information when it is necessary for our business purposes.
This type of information may include your name, email and mailing addresses and contact numbers. In some circumstances, we are authorised by anti-money laundering laws or tax laws to collect other information about you, such as your security holder reference number (SRN) or tax file number (TFN). We may also collect information about your criminal record where this is necessary to comply with anti-money laundering laws.
We collect most of this information directly from you where possible. This information may be provided by you in forms you fill out, in face-to-face meetings, in e-mail messages you send us, via our website, or during telephone conversations. In some cases we may collect your personal information from a third party, such as a broker or a bank. If you contact us, we may keep a record of that contact.
We are required to collect personal information from you by certain laws, including The Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), The Corporations Act 2001 (Cth) and The Income Tax Assessment Act 1936 (Cth).
When you visit our site, our server may attach a small data file known as a “cookie” to your hard drive. This enables us to analyse usage patterns on our site in order to tailor it to our users’ needs. Cookies only identify your computer to our servers when you visit our website. Most web browsers are set to accept cookies. If you do not wish to accept cookies, you can refuse the transfer of cookies to your computer’s hard drive by adjusting your internet browser. Cookies do not personally identify users, only a user’s browser. They operate as a unique identifier, which helps us to know what our users find interesting and useful on our website. We do not link this information back to other information that you have provided to us. We do not store information inside cookies.
Use and disclosure of personal information
Any personal information that we collect about you will be used by us and disclosed to companies within Catapult Partners. The purpose is to provide you with the information, products or services that you have requested and also to tell you about other products and services that we think might be of interest to you. We may also use this information to respond to any comments or queries you may have.
We may disclose personal information about you to organisations that provide services to us and, in the case of our managed funds clients, to any person who acts on your behalf in relation to your investment. We limit this disclosure to the information they need to perform the service.
Depending on the service or products we provide to you, we may need to disclose your personal information to other organisations, which may include:
Catapult Partners’ external service providers (including custodian and registry providers);
regulatory bodies, government agencies and law enforcement entities;
your agents (e.g. financial and legal advisers); and
your executor, and administrator, trustee, guardian or attorney.
Disclosure to overseas recipients
Catapult Partners does not directly disclose personal information to overseas recipients. In relation to our managed funds business, our service providers may send personal information to affiliates overseas. These recipients may be in other countries where laws in relation to processing and holding of personal information are not consistent with the APPs or The Privacy Act 1988 (Cth). While we may take steps to ensure that these overseas recipients do not breach the APPs in relation to your personal information, the overseas recipient may do so. By providing us with your personal information you accept that we may make disclosures to overseas recipients on this basis.
Security, accuracy and storage of your personal information
We will endeavour to take all reasonable steps to keep secure any personal information which we hold about you and to keep this information accurate and up-to-date. Your information may be stored in hard-copy or electronically. Any information we hold electronically is stored on secure servers that are protected in controlled facilities. We require our employees and data processors to respect the confidentiality of any personal information held by us.
No data transmission over the internet can be guaranteed to be 100% secure, so we cannot give an absolute assurance that the information you provide to us via the internet will be secure at all times.
In most instances you have the right to access the personal information which we hold.
It is important that we use only your correct information, as such we would ask that if you find our information to be out-of-date or inaccurate could you please advise us so that corrections can be made. Any requests to access or correct personal information should be made via email (firstname.lastname@example.org) or phone (+61 7 3220 1312).
Other websites linked to our site
From time to time our website may provide links to third party websites. These link sites are not under our control and we are not responsible for the conduct of companies linked to such websites. Before disclosing your personal information to any other website, you should examine the terms and conditions for using these websites and the privacy policies applicable.
What to do if you have a complaint or question
Suite 1.2, The Chambers
308 Queen Street
Brisbane QLD 4000
Or by phone on +61 7 3220 1312.
Where possible, your concerns will be resolved within 30 business days. If you are not satisfied with our response, you may contact the office of the Australian Information Commissioner. There is a privacy hotline available for this purpose: 1300 363 992.