Privacy Policy of Arnhem Investment Management Pty. Ltd.
Arnhem Investment Management Pty Ltd (“Arnhem”) (ABN 17 129 606 775)

This document dated 12 March 2014 gives information on how we protect the personal information we hold about you. The aim of the Arnhem privacy policy is to give you comfort that the personal information you provide to us will be kept in the strictest confidence. We acknowledge that circumstances may change and our policy will be reassessed accordingly.

Australian Privacy Principles.
The Australian Privacy Principles (APPs), formerly known as National Privacy Principles (NPPs), which are set out in the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Privacy Amendment Act), include provisions that regulate the way private sector organisations collect, use, disclose, keep secure and provide access to personal information. Arnhem is bound to protect your personal information in accordance with the Australian Privacy Principles, to the extent required by the Privacy Amendment Act.

Collection of personal information

What is ‘personal information?

Under the Privacy Amendment Act, personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Why we collect information?
Personal information is collected so that we may:

We may use personal information for purposes such as:

The information we collect
The information we collect from you will depend on what services we provide to you. In most instances information about you will be collected from you either in an application form, during an interview or from telephone contact.

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. For example, if you subscribe to notifications, if you e-mail your contact details to us, if you use a login and password to access a particular service or if you provide your email address to access commentary.
When visiting our web site, our web server may collect information for statistical purposes. This includes the device and browser type, internet (IP) address that you are browsing from, and may include details of the organisation to whom this IP address is registered to. No attempt is made to identify individual users from this information.
The Arnhem 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. Arnhem does not collect information about you from the third parties. You will need to contact them to ascertain their privacy standards.

The 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. Arnhem does not, and will not, disclose personal information to overseas recipients.

In all circumstances where personal information may become known to our third party suppliers, there are confidentiality arrangements in place. Contractors, agents and outsourced service providers are not able to use or disclose personal information for any purpose other than our own. Arnhem takes its obligations to protect customer information very seriously and we make every effort to deal only with parties who share and demonstrate the same attitude.

What if you provide incomplete or inaccurate information?
We may not be able to provide you with the products or services you are seeking.

Personal information quality
Our goal is to ensure that the personal information we collect, use or disclose is accurate, complete and up‑to-date. Please contact our Privacy Officer by calling +61 2 9016 3633 or e-mailing, if any of your personal details change.
Please also contact us if you believe that the information we have about you is not accurate, complete or up-to-date.
Personal information security
We are committed to keeping secure the personal information you provide to us. We take all reasonable precautions to protect the personal information we hold about you from misuse and loss and from unauthorised access, modification or disclosure.
We have a range of practices and policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.
Our security measures include, but are not limited to:

Where information we hold is identified as no longer needed for any purpose we take reasonable steps to effectively and securely destroy it. Further, any unsolicited information received will be destroyed within a reasonable timeframe or we will ensure that the information is de-identified.
Online Services
If you use the Internet to communicate with us, you should be aware that there are inherent risks in transmitting information over the Internet. Arnhem does not have control over information while in transit over the Internet and we cannot guarantee its security.

A ‘cookie’ is a packet of information that allows the server (the computer that houses the web site) to identify and interact more effectively with your computer.
When you use our web site, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use our web site. Cookies do not identify individual users, although they do identify a user’s browser type and your Internet Service Provider (ISP).
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. If you reject all cookies, you may not be able to use our web site.

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.

Changes to our privacy and information handling practices
Arnhem may make changes to our privacy and information handling practices from time to time for any reason. We will publish those changes on our web site and, if there are important changes or a lot of minor changes, we will update this document.

Access to personal information
You can request us to provide you with access to the personal information we hold about you. In most cases, your personal information is accessible to you via:

We have processes and procedures in place for the correction of any errors brought to our attention and a data breach response plan designed to handle any breaches.

Responding to an access request
We will respond to your access request as soon as possible. There is no charge for access to your personal information.

Contact us about our privacy and information handling practices
If you have any questions or would like further information about our privacy and information handling practices, please contact us by:

If you have any concerns or complaints about our privacy and information handling practices, please contact us as above. We will acknowledge your concern promptly, investigate the concern, and reply to you, advising of any decision and informing you of any remedies available, including possible appeal through dispute resolution bodies.