In this Privacy Policy and Disclosure Statement the expressions
"MIR",
"we", "us" and "our" are references to
MIR Investment Management Pty. Ltd. ABN
47 104 642 613 and those Australian registered bodies corporate related
to it.
We are subject to the National Privacy Principles in the
Privacy Act 1988 (Cth).
This Privacy Policy and Disclosure Statement explains
in general terms how we protect the privacy of your personal information
under the National Privacy Principles ("NPPs") in the Privacy
Act 1988 (Cth). It also sets out the matters that we are required to
disclose to individuals under NPPs 1.3 and 1.5. The principles set out
in this document apply to any personal information you provide to us
via our web site or under any agreement or arrangement and to information
which we might collect about you from other sources.
This Privacy Policy and Disclosure Statement does not
apply to acts and practices of a MIR entity which relate directly to
the employee records of the MIR entity's current and former employees.
How we collect personal information
We generally collect your personal information directly
from you. For example, we may collect personal information about you
when you deal with us over the telephone, send us correspondence (whether
by letter, fax or email) or contact us through this web site, subscribe
electronically to our [web site / publications] or when you have contact
with us in person.
Generally, the type of personal information we collect
about you includes your name, mailing address, telephone number and
e-mail address. It may also include the organisation for which you work,
your position in the organisation and the dealings we have had with
you during your employment with that organisation. In certain circumstances,
we may also collect sensitive information about you such as information
about membership of a professional or trade association or membership
of a trade union.
There may be occasions when we need to source personal
information about you from a third party. For example, we may collect
personal information from a company for whom you work, other organisations
with whom you have any dealings, a recruitment agency, a credit-reporting
agency, an information service provider or from a publicly maintained
record.
We may also collect web site visitors' contact information
(like their e-mail addresses). We utilise "cookies" which
enable us to monitor traffic patterns and to serve you more efficiently
if you revisit the site. A cookie does not identify you personally but
it does identify your computer. You can set your browser to notify you
when you receive a cookie and this will provide you with an opportunity
to either accept or reject it in each instance.
Our Disclosure Statement
MIR collects personal information for the following purposes:
- to provide you or your organisation with information
about our product offerings;
- to service our relationship with you, including providing
you with information from time to time about your investments;
- to consider making offers of employment or for employment
purposes;
- to receive services from you or the organisation which
employs you; and
- to advise you of new investment developments and to
undertake other marketing activities.
If you do not provide the information requested, we may
not be able either to provide you with an appropriate level of service
or to fulfil another applicable purpose of collection.
In some circumstances, we collect personal information
about you from a third party source. If we collect personal information
about you in this way, we will take reasonable steps to contact you
and ensure that you are aware of the purposes for which we are collecting
your personal information and the organisations to which we might disclose
your personal information.
We may disclose your personal information to related bodies
corporate, your consultant, custodian , asset consultant, broker, or
financial adviser on your behalf or to external professional service
providers such as auditors, accountants or lawyers.
How we use or disclose your personal information
We will use and disclose personal information for the
primary purpose for which it was collected. We may also use and disclose
personal information for purposes related or ancillary to the main reasons
we collect it, such as provision of information concerning investment
developments and other services offered by us. We do not disclose personal
information we collect to third parties for the purpose of allowing
them to direct market their products and services. We engage third party
contractors to perform services for us which involves the contractor
handling personal information we hold. In these situations, we prohibit
the third party contractor from using personal information about you
except for the specific purpose for which we supply it.
Other people's information which you provide to
us
If you provide personal information to us about someone
else (such as one of your directors or employees or someone with whom
you have dealings) you must ensure that you are entitled to disclose
that information to us and that, without us taking any further steps
required by privacy laws, we may collect, use and disclose such information
for the purposes described above. For example, you should take reasonable
steps to ensure the individual concerned is aware of the various matters
detailed in this Privacy Policy and Disclosure Statement as those matters
relate to that individual, including our identity, how to contact us,
our purposes of collection, our information disclosure practices, the
individual's right to obtain access to the information and the consequences
for the individual if the information is not provided.
Our duty of confidentiality and obligations of non-disclosure
MIR may be subject to obligations of non-disclosure in
respect of personal information which it holds arising from the fiduciary
duties it owes its clients as well as general duties of confidentiality
owed to its clients.
Gaining access to information we hold about you
We will, on request, provide you with access to the personal
information we hold about you unless there is an exception that applies
under the Privacy Act such as where we have a legal duty of confidentiality.
Your request to obtain access will be dealt with in a
reasonable time. MIR may recover from you its reasonable cost of providing
you with access.
If we refuse to provide you with access to the information,
we will provide you with reasons for the refusal and inform you of any
exceptions relied upon under the Privacy Act.
Keeping your personal information up-to-date
We take reasonable steps to ensure that your personal
information is accurate, complete, and up-to-date whenever we collect
or use it.
If any of the personal information we hold about you is
inaccurate, incomplete or out-of-date, please contact us immediately
and we will take reasonable steps to correct this information or, if
necessary, we will discuss alternative action with you.
Security of your personal information
We protect any personal information that we hold from
misuse and loss. We also protect it from unauthorised access, modification
and disclosure.
Your personal information may be stored either in hard
copy documents or as electronic data in MIR's software or systems.
We maintain physical security over our paper and electronic
data stores and premises, such as locks and security systems. We also
maintain computer and network security; for example, we use firewalls
(security measures for the Internet) and other security systems such
as user identifiers and passwords to control access to our computer
system.
Transfer of information to foreign countries
We may transfer your personal information to foreign countries
as part of the management of our business, for example, for the purpose
of aggregating our information databases internationally.
How to contact us
If you wish to gain access to your personal information
or make a complaint about a breach of your privacy or if you have any
query on how your personal information is collected or used or any other
query relating to this Privacy Policy and Disclosure Statement, please
contact our Privacy Officer:
Telephone: (02) 8222 0800
Mail:
The Privacy Officer, MIR Investment Management Pty. Ltd.
Level 40, 50 Bridge Street
Sydney NSW 2000
Email: privacy.officer@mir.com.au
We will respond to your query or complaint as soon as
possible.
Our contact details
MIR's offices in Australia are located at:
Level 40, 50 Bridge Street
Sydney NSW 2000
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