1. The privacy of your personal information is important to us
The privacy of your personal information is important to us, and we understand that how we collect, use and protect your personal information is important to you.
2. Who does this policy apply to?
Listed Investment Companies
- WAM Capital Limited ABN 34 086 587 395;
- WAM Leaders Limited ABN 33 611 053 751;
- WAM Global Limited ABN 76 624 572 925;
- WAM Microcap Limited ABN 34 617 838 418;
- WAM Alternative Assets Limited ABN 47 168 941 704;
- WAM Strategic Value Limited ABN 24 649 096 220;
- WAM Research Limited ABN 15 100 504 541; and
- WAM Active Limited ABN 49 126 420 719.
Unlisted Wholesale Unit Trust
- Wilson Asset Management Equity Fund ABN 93 770 126 001
Investment Management Companies
- Wilson Asset Management (International) Pty Limited ABN 89 081 047 118; and
- MAM Pty Limited ABN 98 100 276 542.
- who we collect personal information from;
- the types of personal information collected and held by us;
- how this personal information is collected and held by us;
- the purposes for which your personal information is collected, held, used and disclosed;
- how you can gain access to your personal information and seek its correction if required;
- how you may complain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or inquiry will be handled; and
- that we may disclose your personal information to overseas recipients.
4. Who do we collect personal information from?
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode or contact details.
In the course of conducting our business we may collect personal information from investors, financial planners, media, research houses, stockbrokers and potential investors. We also collect personal information from employees, potential employees, contractors and work experience people.
5. What types of personal information do we collect?
In the course of conducting our business, the information we collect may include:
- Personal Information including names, addresses, email addresses and other contact details; dates of birth; financial information, age and employment status.
- Sensitive Information including details of your professional memberships.
Information such as your bank account details and tax file number (TFN) are collected by the share registry (Boardroom Pty Limited or Automic Pty Limited) and are not disclosed by the share registry to us. Please refer to their privacy policies for further details on how they manage the privacy of this information: https://boardroomlimited.com.au/corp/privacy-policy/, or
Wilson Asset Management Equity Fund ABN 93 770 126 001 may collect sensitive information from wholesale investors in order to comply with the Anti-Money Laundering and Counter‑Terrorism Financing laws (AML/CTF). This sensitive information may include government identifiers such as your TFN.
In respect of employees, contractors, potential employees and work experience people we also collect personal resumes, third party references, bank details, superannuation details, TFNs and emergency contact details. We also conduct criminal checks and bankruptcy searches on individuals who commence employment. These searches are held on our employee files.
In respect of directors of Listed Investment Companies we also collect addresses, bank details, superannuation details and TFNs. This personal information is collected in the course of our ordinary operations as well as in conducting criminal checks and bankruptcy searches.
6. How do we collect and hold your personal information?
How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.
We may collect information about you when you:
- telephone, email or write to us;
- have a face to face meeting;
- attend our presentations to investors, potential investors and financial planners;
- attend conferences where we are presenting;
- subscribe to receive investment information from us;
- apply for work experience with us;
- apply for employment with us; or
- accept an offer of employment.
7. Gathering and combining personal information
Improvements in technology enable organisations to collect and use personal information to get a more integrated view of investors, and to allow them to provide better products and services to investors. We use data collection methods to collect information based on how individuals use our website, such as the number of visitors and the number of pages viewed. This information is collected to analyse and improve the quality of our website and the investor experience. We do not use this information to personally identify individuals.
8. Unsolicited Information
We may be provided with personal information without having sought it through our normal means of collection, as set out above. This is known as “unsolicited information” and is often collected by:
- Misdirected postal mail – Letters, Notes, Documents
- Misdirected electronic mail – Emails, electronic messages
- Employment applications sent to us that are not in response to an advertised vacancy
- Additional information provided to us which was not requested
Unsolicited information obtained by us will only be held, used and or disclosed if it is considered as personal information that could have been collected by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the personal information as appropriate.
9. Why do we collect, use and disclose personal information?
We use personal information that is reasonably necessary for conducting our business (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our uses of personal information include but are not limited to:
- establishing your identity;
- managing your investment and our relationship with you;
- providing you with updates in relation to your investment and other investments;
- engaging with investors (including calls to investors, emails and ad hoc surveys);
- assessing your application for a financial product;
- conducting and improving our business, and improving the investor experience;
- complying with our legal obligations, and assisting government and law enforcement agencies and/or regulators;
- identifying other products and services that we think may be of interest to you;
- communicating with you about the products and services that we offer; and/or
- in the case of employees, paying your wages and employee entitlements.
We may also need to collect personal and sensitive information in order to comply with our legal obligations, such as the Anti-Money Laundering and Counter-Terrorism Financing laws, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
10. Direct Marketing
We may use your personal information to send you direct marketing communications and information about our financial products, our general activities and advocacy. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Act and the Spam Act 2003 (Cth). You may opt-out of receiving marketing materials from us by contacting us using the details set out in Section 19 below or by using the opt-out facilities provided (e.g. an unsubscribe link).
We will not disclose your personal information to any third party marketing company.
11. Sensitive Information
12. Storage and security of your personal information
We store personal information in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers.
We store personal information on our Customer Relationship Management (CRM) system and on our third party IT provider’s cloud server. See Section 15 for more information on how and where this information is stored.
The security of your personal information is of paramount importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure.
These steps include:
- restricting access to personal information on our databases to a ‘need to know’ basis with different levels of security being allocated to staff based on their roles, responsibilities and security profile.
- ensuring all staff are aware that they are not to reveal or share personal passwords.
- training and reminding our staff of their obligations with regard to your personal information, and the requirements of the Privacy Act 1998 (Cth) and the Australian Privacy Principles.
- ensuring where sensitive information is stored in hard copy files that these files are stored in lockable filing cabinets in lockable rooms. Access to these records is restricted to staff on a need to know basis.
- implementing physical security measures at our premises to prevent break-ins.
- implementing security systems, policies and procedures designed to protect personal information storage on our computer networks.
- implementing human resources policies and procedures, such as email and internet usage and confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information.
- undertaking due diligence with respect to third party service providers who may have access to personal information, including cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.
Personal information we hold that is no longer needed, or required to be retained by any other laws, is destroyed in a secure manner, deleted or de-identified as appropriate.
Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies.
13. Responding to data breaches
We will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action and notifying affected individuals.
14. When we disclose your personal information
We only use personal information for the purposes for which it was given to us, or for purposes which are directly related to our business.
It may be necessary for us to disclose your personal information to certain third parties in order to assist us with one or more of our functions or activities, or where permitted or required by law. Third parties may include:
- organisations providing share registry services under an arrangement with us;
- those to who we outsource certain functions, for example information technology support and payroll services;
- auditors and insurers;
- government and law enforcement agencies and regulators; and
- entities established to help identify illegal activities and prevent fraud.
We may disclose your personal information from time to time, only if one or more of the following apply:
- you have consented;
- you would reasonably expect us to use or disclose your personal information in this way;
- we are authorised or required to do so by law;
- where a permitted general situation applies (as defined in Section 16A of the Act); or
- disclosure is reasonably necessary for a law enforcement related activity.
15. Disclosure of your personal information to overseas recipients
We do not directly disclose personal information to overseas recipients. In the course of regular business, personal information about an individual is provided to third party service providers, including our share registry providers, IT provider and CRM provider.
We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:
- we have the individual’s consent (which may be implied);
- we have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime; or
- we are taking appropriate action in relation to suspected unlawful activity or serious misconduct.
16. How we ensure the quality of your personal information
We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date. These steps include ensuring that the personal information is accurate, complete and up-to-date at the time of collection, and when using or disclosing the personal information.
On an ongoing basis we maintain and update personal information when we are advised by you or when we become aware through other means that your personal information has changed.
Please contact us if any of the details you have provided to us change. You should also contact us if you believe that the personal information we have about you is not accurate, complete or up-to-date.
17. How to gain access to your personal information we hold
Upon request, we will give you access to the personal information held about you, unless specific exceptions apply under the Act (e.g. if the request is frivolous or vexatious, or providing access would be unlawful).
We will respond to a request for access to personal information within a reasonable period after the request is made and give access to the personal information in the manner requested by you, if it is reasonable and practicable to do so.
If we do not agree to provide you with access, or to amend your personal information as requested, you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision, and the mechanisms available to complain about the refusal. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.
18. Privacy Complaints
We will respond to your complaint within a reasonable time (usually no longer than 30 days), and we may seek further information from you in order to provide you with a full and complete response.
Your complaint may also be taken to the Office of the Australian Information Commissioner. You may contact the Australian Information Commissioner by calling them on 1300 363 992, contacting them online at www.oaic.gov.au, or by writing to the Office of the Australian Information Commissioner at GPO Box 5218 Sydney NSW 2001.
A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.
19. How to Contact Us
- Emailing firstname.lastname@example.org;
- Calling (02) 9247 6755;
- Faxing (02) 9247 6855: or
- Writing to our Privacy Officer at Level 26, Governor Phillip Tower, 1 Farrer Place, Sydney NSW 2000.
If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.
20. Changes to our privacy and information handling practices
Last updated: 8 October 2021