Purpose

The Renaissance Property Securities Pty Ltd (RPS) Privacy Policy details how we protect your privacy and how we comply with the requirements of the Privacy Act 1998 (Cth) and the 13 Australian Privacy Principles.

This policy document outlines how RPS will meet these privacy requirements, while recognising the need for RPS employees and external service providers (ESP’s) to manage personal information in an effective and efficient manner.

This policy also describes:

• the kinds of personal information collected and held by us;
• how this information is collected and held;
• the purposes for which your personal information is held, used and disclosed;
• how you may access your personal information and seek the correction of such information;
• whether we are likely to disclose your personal information to any overseas recipients; and
• 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.

What kinds of personal information do we collect?

RPS only collects personal information that is necessary to assist us in providing our services to our clients. In the course of providing these services we may need to collect:

• Personal Information including names, addresses, other contact details, dates of birth; and financial information.
• Sensitive Information including government identifiers (such as your TFN), your nationality, country of birth.

You do not have to provide us with your personal information but if you do not provide this, we may not be able to provide our services to you or our clients on your behalf.

How do we collect and hold your personal information?

RPS may collect your personal information in different ways, including email, telephone, letters, application and redemption forms, and face to face meetings.

We may also collect information from third parties, such as fund administrators, custodians, consultants, trustees and/or anyone you have authorised to deal with us on your behalf.

We store personal information in a variety of formats including on databases, in hard copy files, on personal devices including laptop computers, in computer storage facilities both in-house and at our external services providers.

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:

• ensuring all staff are aware that they are not to reveal or share personal passwords;
• implementing physical security measures at our premises to prevent break-ins;
• implementing procedures designed to protect personal information storage on our computer networks; and
• implementing human resources policies and procedures, such as email and internet usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information.

For what purposes do we collect, hold, use and disclose personal information?

RPS only collects, holds and uses personal information for the purposes for which it was provided (which will normally be obvious at the time of collection), related purposes or as permitted or required by law. Such purposes may include:

• establishing, maintaining and administering your account;
• conducting verifications, monitoring and reporting required under the AML/CTF Laws;
• recording tax information such as TFN, ABN, country of residence in order to report to the ATO (and other relevant bodies as required by law) and withhold tax correctly from payments;
• communicating with you or your custodian/consultant regarding the status of your unit/share holdings, value, distributions or responding to your and/or your custodian/consultant’s enquiries/information requests;
• processing authorised payments to and from you;
• providing you and/or your custodian/consultant with the services requested; and
• any other uses identified at the time of collecting your personal information.

These purposes may require us to disclose your personal information to our external services providers such as our investment administrator or custodian.

How to gain access to your personal information we hold

You may access the personal information we hold about you, or request that we change the personal information, by contacting the person referred to in the section entitled “To Contact Us” below.

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. 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.

Disclosure of your personal information to overseas recipients

RPS may also subcontract to companies located in countries outside of Australia. Our contracts with these parties will generally include an obligation for them to comply with the Australian Privacy Principles and this Privacy Policy. However you acknowledge that, by agreeing to the disclosure of your personal information to these entities outside of Australia, we will no longer be required to take reasonable steps to ensure the overseas recipient’s compliance with the Australian privacy law in relation to your personal information and we will not be liable to you for any breach of the Australian privacy law by these overseas recipients. On this basis, you consent to such disclosure.

What do you need to do if you have a complaint?

If you wish to make a complaint about a breach of this Privacy Policy or the privacy principles of the Privacy Act 1988 you can contact us by using the contact details below. You will need to provide us with sufficient details regarding your complaint together with any supporting evidence.

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 a full and complete response.

Your complaint may also be taken to the Office of the Australian Information Commissioner via www.oaic.gov.au.

To Contact Us

You can contact us about this Privacy Policy using the following contact details:

Attn: The Privacy Officer
Renaissance Property Securities Pty Ltd
GPO Box 4946
Sydney NSW 2001

Telephone: +61 2 8223 5020
Email: privacy@renaissanceasset.com.au