Active Property Group’s Privacy Policy
Active Property Group Pty Ltd (‘APG’) and its service providers are provided information from investors and borrowers in order to establish and maintain records and to ensure all information is sent to investors, borrowers and regulatory bodies as necessary. The privacy of that information is important to us.
This privacy policy sets out the way we manage personal information received and is in accordance with the Privacy Act 1988 as amended and with the Australian Privacy Policies.
Each of APG’s service providers has its own privacy policy which are consistent with this privacy policy. The privacy policy of each service provider is published on the website of that service provider and, where applicable, should be read in conjunction with this privacy policy.
Kind of Personal Information Collected and Held
In order to provide services to investors and borrowers in the managed investment schemes of which Primary Securities Ltd is the responsible entity/trustee or is the proposed responsible entity/trustee, APG may collect the following information:
1. Full name, date of birth, telephone, residential/business address, email and fax;
2. Identification documentation for the purpose of verifying identity and to ensure compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act and other legislation and regulations regarding identification verification;
3. Tax file number, Australian Business Number and GST registration details for the purposes of tax reporting and withholding;
4. Bank account details for the purpose of making payments and also administering direct debit payments when authorised to do so;
5. Contact information about investors’ financial advisers;
6. Copies of any relevant trust deeds, partnership agreements or other documentation which may be required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act;
7. Powers of attorney;
8. Information relating to probate and estate administration.
How is information Collected and Held
We generally collect personal information from applications, questionnaires and other forms you complete and provide to us, from information you disclose to us on the phone, in correspondence, or in person, or from third parties.
If we are provided with personal information about you from a third party we will take reasonable steps to ensure that you are or have been made aware of the matters set out in this privacy policy.
We will only collect sensitive information about you with your express consent or if exempted by the Australian Privacy Principles, such as if the collection is required or authorised by law.
We may receive unsolicited personal information about you. We destroy all unsolicited personal information, unless the personal information is relevant to the purposes for which we collect your personal information.
APG holds personal information in a combination of secure computer data storage facilities and secure paper based files and takes all reasonable steps to protect the personal information held from misuse, loss and unauthorised access, modification or disclosure. Your personal information may be stored by third party data storage providers and may be combined or linked to other information held about you in a client file. Computer stored information is protected through the use of passwords.
Purpose for Collecting, Holding Using and Disclosing Personal Information
APG collects and holds information from investors and borrowers in order to establish and maintain records and to ensure all information is sent to investors and regulatory bodies as necessary.
APG uses or discloses personal information only for the purpose for which it was collected or related purposes which would reasonably be expected. Our service providers may handle your personal information and we prohibit them from using that information other than for the specific purpose for which it was supplied.
APG may be required by law to disclose personal information particularly to:
- Government regulators or entities such as the Australian Securities and Investment Commission or the Australian Tax Office;
- The Financial Ombudsman Service;
- As required by a court order;
- Pursuant to a request under section under s 173(3) of the Corporations Act 2001 (the right to receive a copy of the register of a scheme for use for a proper purpose).
- To optimize our digital marketing campaigns, track website conversions, and improve advertising relevance through secure, third-party data-matching tools.
Access and amendment
Investors may at any time request access to their personal information held by Primary. Any errors in the information held will be amended on request.
Primary will only refuse access where authorised by law.
Complaints
Any complaints regarding breaches of this privacy policy will be handled in accordance with APG’s Complaints Procedures which can be accessed on the FAQ section of our website.
Disclosure of Information to Overseas Recipients
We may be required to disclose your information to service providers that are based overseas. Where possible the information will only be transferred to another country where we reasonably believe that the other country has privacy laws substantially similar to those of Australia.
We may also share limited, securely obfuscated (hashed) contact details with third-party advertising platforms (such as Google) to measure the effectiveness of our online marketing. These platforms match this data against their existing user records for attribution purposes only, and are prohibited from using your data for any other purpose.
Cookies and Digital Tracking
When you interact with our website, we and our third-party partners (such as Google Analytics and Google Ads) may use cookies, pixels, and web beacons to collect information about your browsing activity.
If you complete a form on our website, we may utilize feature enhancements (such as Google Enhanced Conversions) where your data (e.g., email address) is securely hashed and matched with the third-party platform to measure ad performance. You can manage your cookie preferences through your browser settings or opt out of personalized Google advertising via Google’s Ad Settings.
Availability of Privacy Policy
A copy of this Privacy Policy is available free of charge either by downloading a copy from our website or by contacting APG and requesting that a copy be sent to you by email, facsimile or post.
