OUR COMMITMENT TO PRIVACY
Phoenix recognises an individual’s right to privacy and understands the protection and confidentiality of your personal information is important to you. Phoenix is bound by the Privacy Act 1988 (Cth).
PERSONAL INFORMATION WE COLLECT
Any information that identifies you is deemed to be personal information. We primarily collect this information through our standard forms (for example, application forms attached to product disclosure statements issued by us), information you provide through our website, and when you phone or contact our staff.
The type of personal information Phoenix collects from you includes – your name, contact details (such as your address and telephone number), date of birth, individual investment details, bank account information and tax file number. The Corporations Act 2001 (Cth) requires us to collect your name, address and date of birth. The Government’s anti-money laundering laws may also mandate us to collect additional personal information from you.
Phone calls to our Investor Services staff may be recorded or monitored for quality control, training, regulatory or other compliance reasons.
If you do not provide personal information to us, we may not be able to provide you with the services or information you require. In most cases, we will collect your personal information directly from you. In some cases, we may also collect your personal information from a third party such as a financial planner.
When browsing our website Phoenix’s webservers automatically collect standard information as part of the HTTP web protocol – your IP address, browser type, operating system, access times, referring sites, pages viewed and other anonymous information. Generally, personal information is collected on our websites when you login, complete a form or perform a transaction.
HOW WE USE PERSONAL INFORMATION
Phoenix uses your personal information to administer your investment, comply with relevant laws and regulations and communicate with you on an ongoing basis about your investment and the market. We may also send you educational and marketing material about our other products and services we offer – you may contact us at any time to ask us not to send this information.
Phoenix may use information that you provide through our website or over the phone for analysis to improve our products and services.
Staff may also use personal information to verify your identity over the phone.
We may also use your personal information to prevent fraud, crime or other activity that may cause harm in relation to our products or services and to help us run our business.
In some circumstances Phoenix may disclose your personal information to persons/entities outside of Phoenix, including:
· to agents, contractors and external service providers who help us provide our services to you (such as our registry provider, custodian, mailing houses, printing companies, information technology service providers and external consultants) and to auditors and professional advisors;
· to governmental or regulatory bodies or agencies (such as ASIC or a law enforcement agency) and to stock exchanges, in connection with their information requests or to meet our legal and/or regulatory obligations in any relevant jurisdiction, or for the purposes of processing tax reclaims for our funds. Some of these recipients may be located outside of Australia; and/or as required or authorised by law, regulation or by a court order.
Phoenix may disclose your personal information to agents, contractors and external service providers in the following locations: India, China, United States of America.
Phoenix takes steps to ensure that our agents and third parties keep your personal information confidential and use it only for the purposes for which they, and Phoenix, are authorised. You may also authorise us to disclose information we hold about you to your financial adviser*, administrator* or other person nominated by you.
Exemptions Note - Phoenix intends to rely on some of the exemptions permitted under the Privacy Act. For instance, the exemption for disclosing personal information to our related bodies corporate. Similarly, the employer exemption relating to employee records (we have, however, adopted a number of measures designed to protect the privacy of our employees).
*If you nominate an individual contact within an Advisory firm or Administrative firm, Phoenix deems (in order to protect the privacy of our investors) that you give authority to the firm and not the individual contact.
PERSONAL INFORMATION SECURITY
Phoenix regards the security of your personal information as a priority and has a number of physical and electronic protection measures in place.
You should be aware that the internet is not a secure environment. Whilst Phoenix takes reasonable steps, we cannot guarantee the security of the information you provide to us via our website or that we make accessible to you via the secure investor site. No personal data is stored on our public website. Personal data is stored on our secure investor site.
ACCESS TO YOUR PERSONAL INFORMATION
In many circumstances you can request access to personal information we hold about you. Sometimes it is not possible for us to give you access in which case we will explain why
Phoenix will take reasonable steps to correct personal information held about an individual where Phoenix is satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading or, you request that Phoenix corrects the information.
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