This privacy statement is made on behalf of Capital Dynamics (Australia) Limited ACN 129846260 AFSL 326283 (“CDAL”). CDAL is committed to protecting your privacy and to compliance with the National Privacy Principles contained in the Privacy Act 1988 (Cth). If you have any questions relating to this privacy statement or your privacy rights please contact us.

This Privacy Statement sets out the policy of CDAL for handling and protecting your personal information. We are committed to ensuring the privacy of your information and recognise that you, as a customer, are concerned about your privacy and about the confidentiality and security of information that CDAL may hold about you.

Collection
The information we collect

The information we collect from you will depend on what services we provide to you and may include the following:

• your name, address and contact details;
• your e-mail address;
• your tax file number;
• Bank account details;
• Identification and verification information; and
• details of specific transactions.

Where we collect information

In most instances information about you will be collected from you in an application form. We may also collect information about you from our web site but this information will only identify who you are if you provide us with your details (eg. if you e-mail your contact details to us). When you visit our web site our web server collects the following types of information for statistical purposes:

• your Internet service provider's address;
• the number of users who visit the web site;
• the date and time of each visit;
• the pages accessed and the documents downloaded;
• the type of browser used.

No attempt is made to identify individual users from this information.

The CDAL web site contains links to the web sites of third parties. If you access those third party web sites they may collect information about you. CDAL does not collect information about you from the third parties. You will need to contact them to ascertain their privacy standards.

Cookies

A cookie is a small text file placed on your computer hard drive by a web page server. Cookies may be accessed later by our web server. Cookies store information about your use of our web site. Cookies also allow us to provide you with more personalised service when using our web site.

CDAL uses cookies to:

• determine whether you have previously used the CDAL web site;
• identify the pages you have accessed; and
• facilitate administration of the site and for security purposes.

Most web browsers are set to accept cookies but you may configure your browser not to accept cookies. If you set your browser to reject cookies you may not be able to make full use of the CDAL web site.

Uses and disclosure of information

We will only use or disclose the information collected about you for the purpose for which it was collected, for related purposes which you would reasonably expect us to use or disclose the information for, or where you have consented to us using or disclosing the information.

We may use your personal information to:

• process your investment application;
• respond to any specific requests you may make of us;
• notify you of any products that may be of interest to you;
• audit and monitor the services we provide to you;
• update your personal files; and
• enable us to meet our obligations under law, for example, the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth.), Financial Transaction Reports Act 1988 (Cth.) and Australian taxation laws.

We may disclose your personal information to:

• our agents, contractors or third party service providers to enable them to provide administrative and other support services to us; and
• where the disclosure is required by law, for example to government agencies and regulatory bodies as part of our statutory obligations, or for law enforcement purposes.

E-mail address

If you provide us with your e-mail address during a visit to our web site it will only be used for the purpose for which you provided it to us. It will not be added to a mailing list without your consent unless the mailing list is related to the purpose for which you provided your e-mail address to us. We may use your e-mail address, for example, to provide you with information about a particular service or respond to a message you have sent to us.

If you subscribe to one of our services and provide your e-mail address to us so that we may communicate with you through e-mail, we may also use your e-mail address to advise you of upgrades and changes to those services.

CDAL agents

CDAL may use third party service providers to maintain some of our data systems and provide auxiliary services. We require any party that has access to personal information to conform to our privacy standards.

Direct marketing

We do not disclose information about you to third parties for marketing purposes.

Security and retention policies

CDAL is committed to ensuring the security of information that we hold about you. We take all reasonable steps to ensure that the information we hold about you is stored securely, whether in a physical or electronic form.

If you use the Internet to communicate with us, you should be aware that there are inherent risks in transmitting information over the Internet. CDAL does not have control over information while in transit over the Internet and we cannot guarantee its security.

Any personal information that we no longer require is destroyed. An exception to this may be where records are retained to comply with legal requirements.

Access and correction

We try to ensure that all information about you that we collect, use or disclose is accurate, complete and up-to-date.

You may at any time request access to personal information that we hold about you. If there is an error with our information or our information is incomplete, you can advise us and we will, if needed, correct or add information.

We will not charge you a fee for your access request but may charge you the reasonable cost of processing your request. If you would like to request access to the information we hold about you, please contact us.

Disputes

If you have a complaint about our treatment of your privacy, please contact us. We will investigate your complaint and endeavour to resolve any issue to your satisfaction.

If we do not adequately answer your concerns, you have the right to make a complaint to the Office of the Federal Privacy Commissioner.