Anthony Moreton Group - APP Privacy Policy

Anthony Moreton Group and its related bodies corporate (referred to collectively as 'Anthony Moreton Group' in this Privacy Policy) are committed to respecting the privacy of its members and clients by ensuring that it manages any personal information it collects or holds in accordance with the Australian Privacy Principles ('APPs').

This APP Privacy Policy applies from 12 March 2014.

Kinds of personal information Anthony Moreton Group collects and holds

Anthony Moreton Group will only collect personal information which is reasonably necessary for it to provide its products and services. Such information may include an individual's personal and contact details and tax file number. Without this information, Anthony Moreton Group would not be able to provide financial services to its members and clients.

Can an individual remain anonymous when dealing with Anthony Moreton Group

Given the nature of Anthony Moreton Groups products and services, other than providing general publicly available information, it is not practical for Anthony Moreton Group to deal with individuals who wish to remain anonymous or would prefer to identify themselves only by way of pseudonym.


How Anthony Moreton Group collects and holds personal information

When collecting, using or disclosing personal information, Anthony Moreton Group will take such steps as are reasonable in the circumstances to ensure that the information is accurate, up-to-date and complete.

Anthony Moreton Group will only collect personal information in a lawful and fair manner. Wherever possible, personal information will be collected directly from the individual, unless it is unreasonable or impracticable to do so. Sensitive information will only be collected where the individual consents to the collection of that information.

If Anthony Moreton Group receives unsolicited personal information it will, within a reasonable period of time, assess whether it would otherwise have been entitled to collect the information in accordance with this APP Privacy Policy. If the personal information could have been collected by Anthony Moreton Group, it will ensure that this APP Privacy Policy is complied with in respect of that information and it will notify the individual:

  • that the unsolicited personal information has been collected;
  • of the circumstances of that collection; and 
  • provide access to a copy of this APP Privacy Policy.

If the personal information could not have been collected by Anthony Moreton Group, it will destroy the information or ensure that the information is de-identified. 

At or before the time or, if that is not practicable, as soon as practicable after Anthony Moreton Group collects personal information about an individual, Anthony Moreton Group will ensure the individual is aware: 

  • of Anthony Moreton Groups identity and its contact details;
  • that the collection of personal information is permitted by Anthony Moreton Group under the Corporations Act 2001 and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and/or a particular court/tribunal order;
  • of the purpose for which Anthony Moreton Group collects the personal information;
  • of the main consequences (if any) for the individual if all or some of the personal information is not collected;
  • of any other entity (or type of entity) to which Anthony Moreton Group generally discloses the personal information it collects;
  • that Anthony Moreton Group APP Privacy Policy contains information about how the individual may:
    • access and seek correction of the personal information about the individual that Anthony Moreton Group holds; and 
    • complain about a breach of the APPs and how Anthony Moreton Group will deal with such a complaint; and 
  • of whether Anthony Moreton Group is likely to disclose the personal information to overseas recipients.


Unless permitted by law, Anthony Moreton Group will not adopt a government related identifier (e.g. a tax file number) of an individual as its own identifier and it will only disclose such identifiers for the purposes of verifying the identity of the individual, or as permitted by law or as is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

Anthony Moreton Group will ensure that in relation to any personal information it holds that it will take such steps as are reasonable in the circumstances to protect the information from:

  • misuse, interference and loss; and
  • unauthorised access, modification or disclosure. 

If Anthony Moreton Group holds information which it no longer needs (for any purpose for which the information may be used or disclosed) or it is no longer required to keep, it will take such steps as are reasonable in the circumstance to destroy the information or to ensure that the information is de-identified.


The purpose for which Anthony Moreton Group collects, holds, uses and discloses personal information

Anthony Moreton Group collects, holds, uses and discloses personal information for the purposes of providing its products and services which includes issuing units in its managed funds, administering its managed funds and communicating with members and clients.

Where Anthony Moreton Group collects an individual's personal information for a particular purpose (i.e. the primary purpose), it will not use that information for another purpose (i.e. a secondary purpose) unless the individual has consented to the use or disclosure of that information 
or: 

  • it would be reasonably expected that the information would be disclosed for a secondary purpose which is related to the primary purpose (and in relation to sensitive information for a secondary purpose which is directly related to the primary purpose); or
  • the use or disclosure of the information is legally required, specifically authorised by the APPs or reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

Anthony Moreton Group will record in writing circumstances where it uses or discloses personal information for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

Personal information collected by one entity within the Anthony Moreton Group of companies may be used by another entity within the group provided that the personal information is held, used and disclosed for the same primary purpose.

Anthony Moreton Group does not normally disclose personal information about its members and clients to outside parties, except those contracted to provide services to Anthony Moreton Group. These may include:

  • any distributor of an Anthony Moreton Group managed fund;
  • Anthony Moreton Groups professional advisers and contracted service providers e.g. auditors, lawyers, platform operators, fund managers, investment providers, custodian, insurer and consultants.


With consent, Anthony Moreton Group will disclose personal information to a member's or client's accountant, financial consultant or other person or organisation they nominate. Personal information may also be disclosed to the Australian Taxation Office or other government authorities or agencies as required by law.

If Anthony Moreton Group uses or discloses personal information for direct marketing purposes, it will include a simple and free means of 'opting-out' of receiving future direct marketing material and it will ensure that it respects such requests, within a reasonable period of time and notifies any other organisation it is using to facilitate the direct marketing. If Anthony Moreton Group has not collected the personal information directly from the individual, the 'opt-out' statement will be prominent. Anthony Moreton Group will only use sensitive information for direct marketing purposes where the individual has provided consent for it to be used for that purpose.

If Anthony Moreton Group uses personal information provided by a source other than the individual for direct marketing purposes, the individual may request Anthony Moreton Group to provide details of the source of the information. Anthony Moreton Group will provide this information free of charge and within a reasonable period of time.

If Anthony Moreton Group uses the personal informationfor direct marketing purposes, it will ensure that it complies with the requirements of the Do Not Call Register Act 2006, the Spam Act 2003 and the Corporations Act 2001.


How an individual may access and seek correction of personal information held by Anthony Moreton Group

Generally, Anthony Moreton Group will provide an individual with access to their personal informationin a manner they request and within a reasonable period of time after the request is made. An individual can request Anthony Moreton Group to correct any personal information it holds about that individual.

To apply for access or to request a correction to personal information, contact the Privacy Officer by:

Writing to: Privacy Officer, Anthony Moreton Group, GPO Box 2779, Brisbane Qld 4001
Visiting: Level 20, 324 Queen Street, Brisbane Qld 4000
Calling: 07 3100 1300
Emailing:
privacy@anmor.com.au

There are no charges for an individual requesting access to personal information. However, Anthony Moreton Group may charge a fee to provide access, provided that such fee is not excessive.

As set out in the APPs, some exceptions apply. If Anthony Moreton Group relies on one of the exceptions or is unable to provide the personal information in the manner requested by the individual, it will take such steps (if any) as are reasonable in the circumstances to give access in a way that meets the needs of both Anthony Moreton Group and the individual and it will provide a written notice setting out:

  • the reasons for the refusal except to the extent that, having regard to the grounds forthe refusal, it would be unreasonable to do so; and
  • the mechanisms available to complain about the refusal; and
  • any other relevant matter.


Having regard to the purpose for which the personal information is held, if Anthony Moreton Group is satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading or a request is received from an individual, Anthony Moreton Group will take such steps as are necessary to correct that information. This will be done free of charge within a reasonable period after the request has been made. If Anthony Moreton Group has provided that information to a third party, the individual may request Anthony Moreton Group to notify that third party of that correction.

If Anthony Moreton Group refuses to correct an individual's personal information it will provide a written notice to the individual setting out:

  • the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and
  • the mechanisms available to complain about the refusal; and
  • any other relevant matter.


If Anthony Moreton Group refuses to correct an individual's personal information and the individual requests Anthony Moreton Group to associate a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading with that information, Anthony Moreton Group must take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information. This will be done free of charge within a reasonable period after the request has been made.


How an individual can complain about a breach of the APP's and how the complaint will be dealt with

An individual may complain to Anthony Moreton Group about a breach of the APPs by Anthony Moreton Group by contacting the Complaints Officerby:

Writing to: Complaints Officer, Anthony Moreton Group, GPO Box 2779, Brisbane Qld 4001
Visiting: Level 20, 324 Queen Street, Brisbane Qld 4000
Calling: 07 3100 1300
Emailing:
info@anmor.com.au

The complaint will be handled in accordance with Anthony Moreton Groups Complaints Policy which can be requested and a copy sent free of charge.

How an individual can complain about a breach of the APP's and how the complaint will be dealt with

No, Anthony Moreton Group is not likely to disclose personal information about an individual to an overseas recipient.

If at some future time, Anthony Moreton Group chooses to disclose personal information about an individual to an overseas recipient, it will either obtain the individual's informed consent prior to doing so, will be required to do so by Australian law or prior to doing so will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the APPs (other than APP 1) in relation to the information.


Anthony Moreton Group Funds Management Limited  ACN:  105 568 803               Privacy Policy   |   Disclaimer