Privacy Policy This Privacy Policy sets out how Vinta Funds Management Limited (ABN 55 167 227 321) (Vinta) handles your personal information under the Privacy Act 1988 (Cth) (Privacy Act). What kinds of personal information are collected? Vinta collects personal information from potential and existing investors, their authorised representatives and contacts within businesses with whom Vinta deals. The personal information Vinta collects depends on your relationship with us, but could include your name, mailing address, email address, phone number, fax number, date of birth, tax file number, financial information, bank account details, gender, nominated beneficiaries and IP address. Vinta generally does not collect sensitive information (as defined in the Privacy Act) about you, unless required by law. How is personal information collected? Vinta collects your personal information from you directly when you provide your information to us (such as when you complete an application form or request certain information from the Vinta website). Vinta may also collect your information from third parties such as any authorised representatives to your account or from public sources. Vinta's website uses cookies. Cookies are small data files that are placed on your hard drive that collect information, including browsing information, each time you access Vinta's website. Information collected through cookies is used by Vinta to operate the website efficiently and to track the patterns of behaviour of visitors to the website. You can change your browser settings to disable cookies. If you disable cookies, it may effect your online experience. Why is personal information collected, used or disclosed? Vinta collects, holds, uses and discloses your personal information in order to: (a) establish, administer and facilitate your investment in a Vinta fund (including monitoring, auditing and evaluating the fund); (b) communicate with you; (c) process payments from and transfer money to you; (d) promote goods and services to you and facilitate related companies of Vinta promoting goods and services to you; and (e) conduct research to improve its services and comply with its legal obligations. You will have the choice to elect to receive some of the above communications either on the Vinta website at www.vinta.com.au or, if investing in a Vinta fund, via the application form accompanying the relevant fund offer document. Should you elect to receive any of the above communications, you will also have the option to 'opt out' of receiving them at any time in the future by unsubscribing from communications received electronically or by contacting Vinta at info@vinta.com.au. Vinta is also required to collect certain personal information in order to comply with its legal obligations, including under the following legislation: (a) Corporations Act 2001; (b) Income Tax Assessment Acts 1936 and 1997; (c) Taxation Administration Act 1953; and (d) Anti-Money Laundering and Counter-Terrorism Financing Act 2006. Who is your personal information disclosed to? Vinta may disclose your personal information to its unit registry provider, fund manager, custodian and fund accountant. Vinta’s unit registry provider will actively manage the administration of Vinta Funds including maintaining the investor register. It may collect, use, store and disclose personal information for the same purposes as set out in this Privacy Policy. Vinta may disclose your personal information to: (a) Vinta's related companies; (b) agents and contractors that provide services to Vinta or perform functions on our behalf, including custodians, legal advisers, accountants, actuaries, insurers, website managers, and providers of internet, data storage and data access services; (c) anyone else to whom you authorise Vinta to disclose your personal information; and (d) anyone else required or authorised by law. Is your personal information disclosed overseas? Vinta will not disclose your personal information to recipients located overseas. How is your personal information stored? Vinta uses reasonable steps to protect your information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Vinta takes precautions including: (a) restricting access to personal information stored in Vinta's servers; (b) imposing confidentiality requirements on its employees; (c) requiring that its contractors and agents take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure; (d) implementing electronic security systems, such as firewalls; (e) ensuring that servers containing investor account information have security measures such as password protection; and (f) controlling access to Vinta's offices. Accuracy of your personal information Vinta aims to ensure that the personal information we keep about you is accurate, up to date and complete. How can you access and correct personal information? Subject to the exceptions set out in the Privacy Act, you have a right to access and seek correction of personal information that Vinta holds about you. Vinta may recover from you reasonable costs of supplying you with access to your personal information. However, we will not charge you for the making of the request or to correct or update your personal information. If you would like to access or correct your personal information, please contact Vinta's Privacy Officer via the contact details listed below. Your request will be dealt with as soon as reasonably practicable. If Vinta refuses to provide you with the requested access to, or correction for, the information it will generally notify you of the reasons for refusal to the extent required and what the next steps for you are. Privacy Complaints If you believe Vinta has breached the Privacy Act or a registered code that binds us, please contact Vinta's Privacy Officer via the contact details listed below. Vinta may request that you put your complaint in writing. Vinta will endeavour to resolve your complaint in a reasonable time frame (usually within 30 days) and may contact you in order to obtain further details in order to provide you with a full and complete response. If you are not satisfied with the manner in which Vinta has handled your complaint, you can lodge a complaint with the Office of the Australian Information Commissioner at www.oaic.gov.au. Privacy Officer Contact Details To access or correct your personal information, to notify Vinta of a breach of the Privacy Act or a registered code or if you have any privacy related inquiries, please contact Vinta's Privacy Officer at , Telephone No. (02) 9290 6000, GPO Box 5275 Sydney NSW 2000. Links to other websites You may find links to other websites not operated by Vinta on our website. This Privacy Policy does not apply to those websites – always check the privacy policy of other sites you enter. This policy is amended from time to time, and was last updated on 3 September 2015. 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