Tony Barbone discusses the difference between investing in a pooled mortgage fund and direct loans.
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.
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 to Primary 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.
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.
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.
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:
1. Government regulators or entities such as the Australian Securities and Investment Commission or the Australian Tax Office;
2. The Financial Ombudsman Service;
3. As required by a court order;
4. 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).
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.
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.