Privacy Policy

Your Privacy

VGI is committed to respecting your privacy and protecting the security of your personal information and complies with the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles under that Act. We take the protection of your personal information very seriously.

 

By providing personal information to us, you consent to us collecting, holding, using and disclosing of your personal information in accordance with and for the purposes specified in this Privacy Policy and any arrangements that apply between us.

 

You are not required to provide personal information to us. However, if you do not provide us with all the information we request, the services we provide to you may be affected.

 

Policy Application

This Privacy Policy applies to the following entities (collectively, “VGI”; “we”; “our”; or “us”):

 

Investment Management Companies

  • VGI Partners Limited and its related bodies corporate
  • VGI Partners Asian Investments Management Pty Limited

 

Listed Investment Companies

  • VGI Partners Limited
  • VGI Partners Global Investments Limited
  • VGI Partners Asian Investments Limited

 

Unlisted Wholesale Funds

  • VGI Partners Master Fund
  • VGI Partners Offshore Master/Feeder Funds
  • Individually Managed Accounts

 

Foundation

  • VGI Partners Foundation Pty. Limited ATF VGI Partners Foundation

 

Overview

This Privacy Policy outlines:

  • the types of personal information we may collect;
  • how we collect and handle personal information;
  • purpose of collection, use and disclosure of personal information;
  • storage and security of personal information;
  • reporting data breaches;
  • how you can gain access to your personal information and seek correction if required; and
  • how you may complain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or concern will be handled.

 

Personal Information we may collect

In this Privacy Policy, personal information means any information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified (anonymous data).

 

The types of personal information that VGI may collect includes information that is reasonably necessary for VGI to conduct its business, communicate with you, consider any investment applications and/or approaches that you make to us or provide you with appropriate services and may include:

  • Personal Information: your full name, residential address, date of birth, contact details, copies of identification documentation, and banking details.
  • Sensitive information: Regulatory and other laws may also mandate us to collect additional information from you, for example membership of a political association, membership of a professional or trade association, or criminal record.

 

In respect of listed investment companies, information such as your bank account details and tax file number (TFN) are collected by the share registry (Boardroom Pty Limited).  Please refer to their privacy details on how they manage the privacy of this information: https://www.boardroomlimited.com.au/corp/privacy-policy

 

In respect of unlisted wholesale funds and individually managed accounts, application forms and information such as your bank account and TFN will be collected by or provided to VGI and/or the Administrator, Citco.  Please refer to their privacy details on how Citco manage their privacy of information:  https://www.citco.com/footer/privacy/

 

In respect of employees, independent contracts and directors as part of our recruitment process we may also collect personal resumes, third party references, bank details, superannuation details, TFNs, emergency contacts, and conduct pre-employee screening, criminal checks and bankruptcy checks.

 

How we collect Personal Information

We may collect personal information about you via:

  • any messages or comments you submit to VGI via its website, through the ‘Contact Us’ page, and via email including the  privacy@vgipartners.comemail address;
  • application forms, identification documentation or other documents that you may complete or provide to VGI;
  • face to face meetings, interviews and telephone conversations;
  • attending our investor presentations or conferences;
  • publicly available information;
  • information that we receive from third parties, including share registry(s), administrators, custodians, brokers or from your legal, tax or financial advisers (where you have authorised them to provide this information to VGI); or
  • an employment application with VGI.

 

Links and Cookies

The VGI website (www.vgipartners.com) may contain links to other websites. Such websites are responsible for their own privacy practices and you should review the respective privacy policies or statements of those websites.

 

VGI may use third parties to analyse traffic at its website and may use ‘cookies’ (a packet of information placed on a user’s computer by a website for record keeping purposes) to do this, however, the information collected to conduct such analysis is anonymous.

 

Unsolicited Personal Information

We may be provided with personal information without having sought it through our normal means of collection.  This is known as “unsolicited information” and is often collected by:

  • misdirected postal mail – Letters, Notes, Documents;
  • misdirected electronic mail – Emails, electronic messages;
  • employment applications sent to us that are not in response to an advertised vacancy; or
  • additional information provided to us which was not requested.

 

Unsolicited information obtained by us will only be held, used and or disclosed if it is considered as personal information that could have been collected by normal means or the collection would be reasonably expected by you. If that unsolicited information could not have been collected by normal means or the collection would not reasonably be expected by you, then we will destroy, permanently delete or de-identify the personal information as appropriate.

 

Purpose of collection, use and disclosure of Personal Information

VGI collects your personal information primarily for the purpose of processing applications (including identifying you and confirming your eligibility to invest in the product or to utilise the service), managing and administering your investments and/or to providing services to you, and providing you with investment related communications.

 

VGI will only use or disclose your personal information:

  • for the purpose for which you provided it or for a related purpose that would be reasonably expected by you;
  • where you have consented to the use or disclosure; or
  • to the extent that VGI is required or permitted to do so by law, including to comply with anti-money laundering and counter-terrorism financing, taxation or any other regulatory reporting requirements.

 

We may disclose your personal information to VGI’s related bodies corporate, to regulators to the extent required or permitted by law, and to other companies and individuals who assist us in providing services or who perform functions on our behalf such as administrators and custodians. These related bodies corporate and service providers may be located or operate overseas and therefore your information may be held outside Australia. VGI has contractual arrangements in place with its service providers which are designed to ensure that your personal information is kept confidential and secure.  VGI will take all reasonable steps to not disclose an individual’s personal information to overseas recipients unless we have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime.

 

VGI may also use your personal information to keep you informed of our services, events and investment opportunities. We may contact you by mail, telephone, email or SMS to keep you informed. We will always give you the opportunity to “opt out” of receiving any information and may subject to the nature of the information provided seek specific consent. Please contact us via privacy@vgipartners.com if you do not wish to be contacted for these purposes.

 

VGI does not sell personal information to other companies or individuals and will not disclose your personal information to any third-party marketing company.

 

Storage, Security and Integrity of Personal Information

VGI regards the security of your personal information as paramount and takes reasonable steps to protect the security of personal information that it holds. VGI also takes reasonable steps to protect such information from misuse, loss and unauthorised access, modification or unlawful disclosure.

 

When the personal information VGI collects is no longer required for the purpose it was collected or as other required by applicable laws, VGI will take reasonable steps to destroy it. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.

 

Your personal information is stored in secure buildings and systems in written and/or electronic form.  Personal information is protected from misuse and loss and from unauthorised access by such measures as (including but not limited to):

  • use of physical security, network security, password protection, restricted access depending on staff role and responsibilities;
  • ensuring staff comply with internal policies and procedures; and
  • confidentiality agreements in place to bind staff and third-party providers (e.g. share registry, administrators, custodians).

 

Our website may contain links to other websites. We do not control and are not responsible for these websites or any of their content, and when you visit these websites, they will be governed by their own terms of use (including privacy policies). Please check their privacy policies.

Although VGI endeavours to provide a secure environment, and restricts VGI personnel access to personal information, the Internet by nature is not a secure environment. Information transmitted to VGI over the Internet cannot be guaranteed to be completely secure or error free, and as such VGI is not responsible for them. If you send an e-mail to VGI over the Internet, you are accepting the associated risks.

 

Reporting Notifiable Data Breaches

We will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, and if there is an eligible data breach notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).

 

Accessing and Correcting Personal Information

If you wish to contact us to request access to the personal information VGI holds about you or if you have any questions regarding this privacy policy, you may contact us via privacy@vgipartners.com. We will provide you with access to, any personal information we hold about you (subject to certain legal exceptions). If a legal exception applies and we decide not to provide you with access to any personal information we hold about you, we will advise you of the reasons for our decision.

 

VGI endeavours to ensure that the personal information it holds is accurate, up to date and complete. To assist us, please make sure that the information you provide to use is accurate, up-to-date, and complete. You may contact us via privacy@vgipartners.com and request a correction if you feel the information we hold about you is inaccurate, incomplete, out of date or misleading. If we are satisfied that any personal information we hold about you is inaccurate, out of date or incomplete (having regard to the purpose for which it is held) we will take such steps (if any) as are reasonable in the circumstances to correct that personal information. This may include notifying third parties to whom we have disclosed that personal information. If we do not agree that personal information we hold about you is inaccurate, incomplete, out of date, misleading or not relevant you may ask that we attach a statement to this effect to our record.

 

How to Contact Us

You can contact us about this Privacy Policy or about your Personal Information by:

  • emailing privacy@vgipartners.com
  • calling +61 2 9237 8980; or
  • writing to our Privacy Officer at 39 Phillip Street, Sydney NSW 2000.

 

If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym.  However, if you choose not to identify yourself, we may not be able to give you the information or assistance you might otherwise receive.

 

Privacy Concerns or Complaints

If you have any concerns or complaints about your privacy, please contact us in writing via privacy@vgipartners.com as soon as possible. VGI will use its best endeavours to resolve your concern or complaint within a reasonable time (usually within five business days or if we are unable to do so within this time frame, we will contact you and let you know why) and we may seek further information from you in order to provide you with a full and complete response.

 

If we are unable to satisfactorily resolve your concern or complaint, you can contact the Office of the Australian Information Commissioner (OAIC) by using their contact details at www.oaic.gov.au. The OAIC has the power to investigate and make a determination.

 

Updates to this Policy

This Privacy Policy may be updated at any time, and without notice. Any changes to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on our website. Please check our website (www.vgipartners.com) to view our current Privacy Policy.

Last updated: 26 February 2020