Wilson Asset Management

Privacy Policy

    Wilson Asset Management

    Wilson Asset Management Privacy Policy


    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.

    This Privacy Policy details how we protect your privacy and how we comply with the requirements of the Privacy Act 1998 (Cth) (the Act) and the 13 Australian Privacy Principles set out in the Act.

    The Act contains exemptions and permitted general situations in relation to certain acts undertaken, including in relation to employee records, legal claims and litigation and related bodies corporate. Where appropriate, we make use of relevant exemptions in the Act.

    This Privacy Policy sets out how we collect, use and disclose personal information.

    2. Who does this policy apply to?

    This Privacy Policy applies to the following Wilson Asset Management and their wholly owned subsidiaries, where applicable, (collectively referred to as ‘we’, ‘our’) entities who comply with the Australian Privacy Principles:

    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 Unit Trust

    • Wilson Asset Management Equity Fund ABN 93 770 126 001; and
    • Wilson Asset Management Leaders Fund ABN 49 678 596 807.

    Investment Management Companies

    • Wilson Asset Management (International) Pty Limited ABN 89 081 047 118; and
    • MAM Pty Limited ABN 98 100 276 542.

    3. Overview

    This Privacy Policy outlines:

    • 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 (whether true or not) about an individual that is reasonably identifiable. For example, this may include your name, age, gender, address or contact details.

    In the course of conducting our business we may collect personal information from investors, financial planners, media, research houses, stockbrokers, potential investors, our share registry (Boardroom Pty Limited) and other organisations including independent sources.

    We also collect personal information from employees, potential employees, contractors and work experience people. Where you apply for a role with us, we may collect personal information from recruitment consultants, your previous employers, universities, program providers and others who may be able to assist us in our decision as to whether to offer you employment.

    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; and/or
    • Other information including your marketing and communication preferences and attendance at our events.

    Information such as your bank account details and tax file number (TFN) are collected by the share registry (Boardroom Pty Limited) and are not disclosed by the share registry to us. Please refer to their privacy policy for further details on how they manage the privacy of this information: https://boardroomlimited.com.au/corp/privacy-policy/.

    Wilson Asset Management Equity Fund ABN 93 770 126 001 may collect identity information (including government identifiers, such as your TFN, passport details or drivers licences details) as well as sensitive information from wholesale investors in order to comply with the Anti-Money Laundering and Counter‑Terrorism Financing laws (AML/CTF).

    In respect of employees, contractors, potential employees and work experience people we also collect personal resumes, third party references, bank details, superannuation details, TFNs, emergency contact details and identity verification information and information about your right to work in Australia. 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:

    • invest in one of the entities set out in Section 2 of this Privacy Policy;
    • request information about one of the entities set out in Section 2 of this Privacy Policy;
    • telephone, email or write to us;
    • have a face to face meeting;
    • use our website (further information in Section 7);
    • attend our presentations to investors, potential investors and financial planners and complete our post-event surveys;
    • 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.

    We may collect personal information from other organisations and people (e.g. third party stock brokers, and from Boardroom Pty Limited who provide share registry, investor communication and voting services for the Listed Investment Companies specified in Section 2 of this Privacy Policy), independent sources and others identified in Section 4 of this Privacy Policy.

    7. Gathering and combining personal information and usage of our website

    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 may combine investor information made available from a variety of sources. This enables us to analyse the data in order to gain useful insights which can be used for the purposes mentioned in Section 9 of this Privacy Policy.

    We also 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; or
    • 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 (such as AML/CTF laws), 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;
    • provide you with work experience opportunities, discuss any potential roles with you, consider your application and test and assess your suitability for roles; and/or
    • in the case of employees, paying your wages and employee entitlements.

    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

    We only collect sensitive information reasonably necessary for one or more of the uses specified in Section 9 of this Privacy Policy if we have the consent of the individuals to whom the sensitive information relates, or are otherwise permitted to do so under the Act.

    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 SalesForce 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 reasonable steps in the circumstances 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 Act 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; and/or
    • undertaking due diligence with respect to third party service providers who may have access to personal information, including cloud service providers.

    We take reasonable steps in the circumstances to destroy, delete or de-identify personal information we hold that is no longer needed, or required to be retained under law.

    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 may on occasion exchange your personal information with an entity specified in Section 2 of this Privacy Policy, so that each entity may adopt an integrated approach to investors. The entities may use the personal information for the purposes specified in Section 9.

    We may 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. These 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 that help identify illegal activities and prevent fraud.

    15. Disclosure of your personal information to overseas recipients

    We do not directly disclose personal information to overseas recipients. However, in the course of regular business, some of our third party service providers, who hold personal information, personal information about an individual is provided to third party service providers, including our share registry providers, IT provider and CRM provider, may store personal information outside of Australia.

    Our share registry, Boardroom Pty Limited, stores personal information in secure electronic databases and offsite storage facilities (for paper documents) located in Australia. Boardroom’s privacy policy can be found here: https://boardroomlimited.com.au/corp/privacy-policy/.

    Our IT provider, onPlatinum ICT, stores personal information on primary and secondary data servers located within Australia. onPlatinum ICT’s privacy policy can be found here: https://onplatinum.com.au/privacy-policy.]

    Our CRM provider, Salesforce, primarily uses a cloud based server to collect, transfer and store personal information, with both primary and secondary servers located in Australia. Salesforce’s privacy policy can be found here: https://www.salesforce.com/au/company/privacy/.

    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 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. Please see Section 17 for further detail on requests we receive to amend your personal information.

    17. How to gain access to your personal information we hold

    You may request access to the personal information we hold about you, or request that we change and/or update the personal information we hold, by contacting us. Our contact details are set out in Section 19 of this Privacy Policy.

    Upon receiving such a request, we:

    • may take steps to verify your identity; and
    • will give you access to the personal information we hold 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

    If you wish to make a complaint about a breach of the Australian Privacy Principles by us, you may do so by providing your written complaint by email, letter, facsimile or by personal delivery to any one of our contact details as noted in Section 19 of this Privacy Policy. You may also make a complaint verbally.

    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.

    If you are not satisfied with the outcome of your complaint, you may lodge a complaint with 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 5288 Sydney NSW 2001.

    19. How to Contact Us

    You can contact us about this Privacy Policy or about your personal information by:

    • Emailing info@wilsonassetmanagement.com.au;
    • 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

    This Privacy Policy may be updated from time to time. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.


    Last updated: 15 December 2023

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