This Privacy Policy applies to the activities of Pengana Capital Limited ("Pengana") and associated Pengana entities. It explains how Pengana handles personal information and complies with the requirements of the Privacy Act 1988. If you have any questions relating to this policy please contact Katrina Glendinning on +61 (0) 2 8524 9900 or info@pengana.com.
1. Collecting Information About You
Pengana collects personal information from investors, advisers, employees, contractors, shareholders and other individuals. We collect this information when it is necessary for business purposes, such as for responding to enquiries, in managing individual investment portfolios and maintaining information relating to shareholders.
The main types of information Pengana collects are details such as the name, address and other contact information. We collect most of this information directly from individuals, such as when individuals request information relating to Pengana and its services. The personal information we collect may be provided on forms filled out by individuals, face to face meetings, e-mail messages, telephone conversations, and information provided by a third party. If you contact us, we may keep a record of that contact.
2. Using and Disclosing Your Personal Information
Our purpose in collecting information about you is to provide you with information or services that you request and to operate our business efficiently. Pengana does not routinely use or disclose personal information without your consent, unless:
 | required by law; |
| we believe it necessary to provide you with a service which you have requested, such as information relating to our investments and their performance; |
| in order to give effect to a contract between Pengana and an individual; |
| to protect the rights, property or personal safety of another Pengana client, any member of the public or Pengana, or |
| the assets and operations of the business are transferred to another party. |
When you provide your personal information to us, Pengana will give you the choice as to whether or not you wish to receive further information relating to Pengana's services. If you indicate that you do not wish to receive these, we will not contact you further for these purposes. Please allow 28 days for your request to be processed.
3. Employee Information
Employee records are not generally subject to the Privacy Act, and therefore this Privacy Policy does not apply to the handling of information about employees by Pengana. For information about our practices relating to employee information please contact us directly.
4. Service Providers
Like many businesses, Pengana uses a range of service providers to help us maximise the quality and efficiency of our services and our business operations. This means that individuals and organisations outside of Pengana, such as registry providers, will have access to personal information obtained by Pengana and may use it on behalf of Pengana. We require our service providers to adhere to strict privacy guidelines and not to use personal information for any unauthorised purposes.
5. We Will Not Send You Unsolicited Information
We may contact you at the e-mail or other address that you provide to us in order to supply you with updated information about our financial products and services. If you are receiving promotional information about Pengana and do not wish to receive this information any longer, you may remove your name from our list on request. Please allow 28 days for this request to be processed.
6. Our Website Privacy Practices
We sometimes use cookie technology on our website to provide information and services to web site visitors. Cookies are pieces of information that a website transfers to your computer's hard disk for record keeping purposes and are a necessary part of facilitating online transactions. Most web browsers are set to accept cookies. Cookies are useful to estimate our number of members and determine overall traffic patterns through our website.
If you do not wish to receive any cookies you may set your browser to refuse cookies. This may mean you will not be able to take full advantage of the services on the website.
7. You Can Access the Information We Keep About You
If at any time you want to know exactly what personal information we hold about you, you are welcome to request access to your record.
8. Changing and Deleting the Information We Have About You
If at any time you wish to change personal information that is inaccurate or out of date, please contact us and we will amend this record. If you wish to have your personal information deleted, please let us know in the same manner as referred to above and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.
9. Storage and Security of Your Personal Information
Pengana will endeavour to take all reasonable steps to keep secure any information that we hold concerning you, and to keep this information accurate and up to date. Your information is stored on secure servers that are protected in controlled facilities. We require our employees and data processors to respect the confidentiality of any personal information held by Pengana.
10. Questions and Future Changes
If Pengana becomes aware of any ongoing concerns or problems regarding our privacy practices, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our Privacy Policy, or you have a problem or complaint, please contact us.
Our commitment to being a leading provider of managed investment services means that our business will continue to evolve as we respond to customer needs. Because of this, from time to time, our policies will be reviewed and may be revised. Pengana reserves the right to change its Privacy Policy in the future.