Privacy Policy

This Privacy Policy was prepared on 11 March 2014

1. Information

Our policy has been maintained to ensure that our clients’ personal details are protected from misuse and disclosure whether intentional or otherwise.

Lambda Group and its subsidiaries continually strives to ensure that its policy is consistent with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth.

2. Our Policy

The privacy principles apply to personal information which is:

Information or an opinion about an individual whose identity is apparent or can readily be ascertained from the information or opinion.

The following policy statement on privacy was formulated to inform our Clients about the types of information we hold, the purpose and the circumstances by which we would disclose this information to a third party.

3. The Information We Collect

Whenever it is reasonable and practicable to do so, we only collect information about you directly from you.

We only collect personal information about you which is reasonably necessary to:

• provide you quality services;
• consider applications and approaches you make to us;
• maintain your contact details; and
• fulfill our legal obligations under applicable laws and rules, such as those relating to taxation and Anti-Money Laundering and Counter-Terrorism Financing.

We generally hold personal information relating to:

• the services we provide or have provided to you;
• your financial interests and your financial position; and
• your name, contact details and identification information; and
• your enquiries or complaints.

We do not generally collect sensitive information about you unless required by applicable laws or rules. Sensitive information includes information relating to:

• race;
• political or religious beliefs;
• sexual preferences;
• criminal convictions;
• membership of professional or trade associations or unions; or
• health information.

We collect health information where we offer products with an insurance component to our customers. We do not use or share that information for any purpose other than the underwriting or administration of a client's policy, claim or account, or as otherwise disclosed to the client when the information was collected.

4. How that Information is used

We only use and disclose personal information about you for the purpose for which it was disclosed to us or related purposes which would reasonably be expected without your permission.

For example, we may from time to time use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, we do respect your right to ask us not to do this. We do not sell or provide your personal information to any other organisation to allow them to do this.

We may disclose personal information to service providers who provide services in connection with our services, i.e. fund auditor.

5. Keeping Information accurate and up to date

We take all reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

6. Keeping Information secure

We use security procedures and the latest technology to protect your information from misuse, loss, unauthorised access or disclosure. Access to and use of personal information within Lambda Group is appropriately limited to prevent misuse or unlawful disclosure of the information.

If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.
Where the personal information we collect is no longer required we will ensure that it is properly removed from our records or make it anonymous in a controlled and secure manner to prevent access by unauthorised parties.

7. Government Identifiers

We do not use government identifiers, e.g. Tax File Number, Social Security Number, to identify, sort or match information we hold.

8. How you can access your information

You can contact us to request access to your information. In normal circumstances we will give you full access to your information. However, we may deny access if we believe that such a request is trivial or grievous, or there is some legal or administrative reason to decline your request. If access is denied, we will provide you with the reason why.