Privacy Policy

1. What kinds of personal information do we collect and hold?

We collect personal information that is reasonably necessary to provide you with a financial service or product, and to meet our legal obligations. This may include your name, contact details and date of birth; identity verification information and details of beneficial owners or controllers collected to meet our anti-money laundering obligations; your tax file number and tax residency information; and financial information such as bank account details, investment holdings and information relevant to your status as a wholesale client.

If we receive unsolicited personal information, we will determine whether we could have collected it as part of our usual functions. If we could not, and we are not required to keep it by law, we will destroy or de-identify it as soon as practicable.

2. Why do we collect, hold, use and disclose personal information?

The main reason we collect, use, hold and disclose personal information is to provide and administer the financial services and products you have requested. This may include checking your eligibility for a service or product, providing the service or product, helping you manage your investments, communicating with you, and meeting our legal, regulatory and taxation obligations.

3. How do we collect personal information?

We collect most personal information directly from you. Sometimes we collect it from third parties, such as your financial adviser, accountant or solicitor, our service providers, and publicly available sources. Telephone calls may be monitored or recorded for training, regulatory or compliance purposes.

4. How do we hold personal information?

Personal information is generally held electronically and securely by us or our service providers (such as our custody, platform and administration providers). We use a range of physical, electronic and cyber security measures to protect it, and we take reasonable steps to destroy or de-identify it when it is no longer needed and we are not required by law to retain it.

5. Who do we disclose your personal information to and why?

We may disclose your personal information to: our related companies and our service providers (such as custody, platform and administration providers); other financial institutions, brokers, custodians and fund managers where needed to give effect to your investments; your nominated adviser or representative, with your authority; and government and regulatory bodies where required or authorised by law, including the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO) and the Australian Transaction Reports and Analysis Centre (AUSTRAC). We only disclose personal information where permitted or required by law, or with your consent. We do not sell your personal information.

6. What is an eligible data breach?

Under the Notifiable Data Breaches (NDB) scheme in the Privacy Act, an eligible data breach occurs where there is unauthorised access to, or unauthorised disclosure or loss of, personal information we hold, and this is likely to result in serious harm to any affected individuals, and we have not been able to prevent that likely harm through remedial action.

If we suspect an eligible data breach may have occurred, we carry out a reasonable assessment and take reasonable steps to complete it within 30 days. If we determine an eligible data breach has occurred, we will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as soon as practicable. The notification will describe the breach, the kinds of information involved, and the steps individuals should take in response.

7. Do we disclose personal information overseas?

We generally use systems and service providers located in Australia. From time to time we may disclose personal information to recipients located overseas — for example, technology, hosting, cloud or operational service providers. We will only do so in compliance with applicable Australian privacy laws, and we take reasonable steps to ensure overseas recipients handle your information consistently with the Australian Privacy Principles.

8. Do we use or disclose personal information for marketing?

We may use your personal information to tell you about other products and services that may interest you. You can ask us to stop sending you marketing communications at any time by contacting us at compliance@gloryhouse.com.

9. Access to and correction of personal information

You can request access to the personal information we hold about you, and ask us to correct information you believe is inaccurate, incomplete or out of date. To make a request, email us at compliance@gloryhouse.com. Access is subject to the exceptions permitted under the Privacy Act; where we cannot give access, we will explain why.

10. Resolving your privacy concerns and complaints

If you have a privacy concern or complaint, please contact us at compliance@gloryhouse.com. We will endeavour to respond within 30 days. If you are not satisfied with our response, you may seek a review by the OAIC:

• Website: www.oaic.gov.au/contact-us
• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au
• Mail: Office of the Australian Information Commissioner, GPO Box 5288, Sydney NSW 2001

11. Contact us

If you have any questions about this notice or our privacy practices, please contact us:

• Email: compliance@gloryhouse.com

This information is provided for general information only. It does not constitute an offer or invitation to enter into any legal agreement for financial products or services.