The following terms have the following meanings:
“APP Entity” means an agency or organisation.
“Australian Privacy Principles” means section 14, i.e. the Australian Privacy Principles set out in the clauses of Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Bill 2012.
“Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.
“Privacy Act” means the Privacy Act 1988 (Cth) and The Privacy Amendment (Enhancing Privacy Protection) Bill 2012.
“QuietGrowth” means QuietGrowth Pty Ltd (“We”, “us” and/or “our”).
Open and transparent management of personal information
QuietGrowth will ensure that it manages personal information openly and transparently, and will ensure that it complies with the Australian Privacy Principles.
Anonymity and pseudonymity
Given the nature of the services provided by QuietGrowth and our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, it is impracticable for our Clients to remain unidentified or use pseudonyms.
Failure to provide the personal information required by the investor application process may mean that we cannot provide the services requested, or we may be forced to withdraw our services.
USE OR DISCLOSURE OF PERSONAL INFORMATION
Collection of information
QuietGrowth collects personal information by lawful and fair means within the requirements of the legislation.
In most circumstances your personal information will be used to:
- provide you with financial services;
- establish and manage investments and accounts;
- implement investment instructions, process distributions and withdrawal applications;
- report the investment performance of accounts;
- keep the individual up to date on other products or services offered by the Company;
- monitor and improve the services provided by the Company;
- process an application for employment with the Company;
- comply with regulatory or legal requirements.
QuietGrowth may collect personal information about an investor from their application form to establish and support the ongoing administration of their investment in the Funds managed by QuietGrowth. For legal and practical reasons, QuietGrowth may not be able to process an application or administer an investment without specific prescribed information.
When you visit our website, our system may record various information through web tools such as the date, location and time of your visit, the pages accessed, any information downloaded and navigation patterns. To evaluate the effectiveness of how we provide service to you, and for our website advertising, we adopt various means including the use of third parties to collect statistical data.
QuietGrowth Referral Program
QuietGrowth manages a referral program or invite program. This program allows you to lower your QuietGrowth fees by inviting your contacts to become QuietGrowth clients. Your participation in our invite program is voluntary. In doing so, you may choose to provide us with the requested information, such as name and email address, about the contact to whom you refer us. You may also choose to provide us access to your contact list so that we can contact the persons to whom you refer us.
If you give us access to your contacts’ information, we may use this information to facilitate your referral invitations and for any other purpose you may authorise us at the time of us collecting the contacts' information.
We handle all the information about your contacts in the similar manner in which we handle your personal information.
Disclosure or sharing of information
QuietGrowth may disclose your personal information to external parties who provide services to the Company including (but not limited to):
- organisations that assist us with fund registry, archival, research, mail and delivery, auditing, recruitment, payroll, superannuation, insurance, management consulting, financial and legal advisory, banking, security and technology services in their capacity as service providers to QuietGrowth;
- in relation to an investor, the custodian, investment advisers, brokers and asset consultants;
- other third parties where required or authorised by law, which may include emergencies and assisting government agencies.