This Statement of Privacy applies to the Freehold Investment Management Limited ('Freehold', 'us', 'our') website and governs data collection and usage. By using this website, you consent to the data practices described in this statement.

This policy sets out why we need to collect personal information, how we collect it, what we do with it, how it is stored and who we might share it with. The policy also describes how you can access or correct information we hold about you, how you can ask further questions or make a complaint. We will update this privacy policy when our information handling practices change. Updates will be published on our website and through our email lists.

Collection of your Personal Information

For most products and services, it is necessary for us to collect 'personal information' such as your name, identity details, contact details, transaction information and other personal details where needed (such as your tax file number and financial information).

There is also information about your computer hardware and software that is automatically collected by Freehold. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by Freehold for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Freehold website.

Sensitive Information

Generally, we do not collect sensitive information about you unless required by law or where you consent for us to do so (only where it is relevant to your product). Sensitive information includes information relating to race, political or religious beliefs, sexual orientation, criminal history and association memberships. We may collect information about your affiliation with certain organisations, such as professional associations.

Why we collect personal information

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

  • provide you with our products or services;
  • consider applications and approaches you make to us;
  • conduct marketing;
  • maintain your contact details; and
  • fulfil our legal obligations, such as those relating to taxation and anti-money laundering and counter-terrorism financing;

or as otherwise authorised by you.

Without such information, we may not be able to process your application or provide you with an appropriate level of service.

How we collect your information<
We collect personal information about you directly from you – this can be in person, in documents you give us, from telephone calls, emails or from transactions you undertake with us.

We may also collect your personal information from third parties including public sources, your adviser(s), agents, referrers, brokers, our related companies and service providers (including credit reporting bodies and information service providers).

How we store your information
We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include storage on the cloud. Where this occurs, we take steps to protect personal information against misuse or loss.

We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints.

Use of your Personal Information

We use personal information about you for the purpose for which it was provided to us, including to:

  • process applications for investments in our managed funds;
  • administer and manage our products and services (including monitoring, auditing, and evaluating those products and services); and
  • communicate with you and deal with or investigate any complaints or enquiries.

We may also use your personal information for 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, if you do not want to receive such communications, you can tell us by using any of the methods listed below.

While we may sometimes share personal information with companies we do business with (e.g. in product development, joint venture arrangements or distribution arrangements), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.

When your information is disclosed
We may disclose personal information outside Freehold:

  • as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator;
  • to our service providers, who provide services in connection with our products and services (including auditing, accounting, legal, mailing, marketing, insurance, identity verification, trustee, website and technology services);
  • to your nominated financial adviser with your permission; and
  • as contained in the terms and conditions of our product or service.

It is unlikely that any of the parties to whom we disclose personal information operate outside of Australia. However, where this occurs, we will take steps to protect personal information against misuse or loss.

Keeping information accurate and up to date
We take 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.

Use of Cookies

The Freehold website use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Freehold pages, or register with Freehold site or services, a cookie helps Freehold to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Freehold website, the information you previously provided can be retrieved, so you can easily use the Freehold features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Freehold services or websites you visit.

Security of your Personal Information

We use security procedures and technology to protect the information we hold. Access to and use of personal information within Freehold seeks to prevent misuse or unlawful disclosure of the information – this includes internal policies, training and monitoring of staff.

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 delete the information or permanently de-identify it in accordance with relevant laws.

Changes to this Statement

Freehold will occasionally update this Privacy Statement to reflect company and customer feedback.

How you can access or correct your information
You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

Contact us
If you have any questions or complaints regarding privacy or information handling, please write to or contact us by telephone on +612 9228 1400. Please mark communications to the attention of the Managing Director. We will respond to let you know who will be handling your matter and when you can expect a further response.

If your concerns are not resolved to your satisfaction, you may be able to lodge your complaint with the Financial Ombudsman Service (details below) which is an external dispute resolution service of which we are a member.

Financial Ombudsman Service Limited
Telephone: 1800 367 287
Facsimile: 03 9613 6399