Privacy Statement

1. INTRODUCTION & BACKGROUND

This Privacy Statement relates to Smithfield Property Group Pty Ltd ACN 128 753 202 (Smithfield) and its subsidiaries (Smithfield Group).

 Smithfield is a boutique property and funds management company.  Smithfield has originated investments in residential apartment developments, land subdivision and commercial real estate. Smithfield believes that values-aligned investment can be sustainable and profitable for all stakeholders. Smithfield originates and transacts on investments which generate financial performance with sustained environmental and social impact.

 Smithfield Capital Pty Ltd ACN 165 077 994 holds Australian financial services (AFS) licence number 473958 and is regulated by the following government bodies over and above the regulation imposed on other typical Australian companies:

• Australian Securities and Investments Commission (ASIC) - in relation to the AFS licence and generally as a registered Australian company.
• Australian Prudential Regulation Authority (APRA) – as an entity authorised to acquire deal in general insurance products.
• Australian Transaction Reports and Analysis Centre (AUSTRAC) - in relation to the Anti-Money Laundering and Counter Terrorism Financing Act (Cth) (AML/CTF Act).

 As an AFS licensee, Smithfield Capital must met high standards of transparency, governance and accountability.  We embrace these standards across the entire Smithfield Group.

2. OUR COMMITMENT TO PRIVACY

In this policy, "us", "we" or "our" means Smithfield and its related bodies corporate within the Smithfield Group.

We recognise an individual’s right to privacy and understand that the protection and confidentiality of your personal information is important to you. 

We have practices in place to comply with the 13 Australian Privacy Principles set out in The Privacy Act 1998 (Cth) (Privacy Act). These principles govern how organisations handle personal information.

This Privacy Statement outlines the types of personal information we collect, how that information is collected, used, stored, and protected and to whom we may disclose personal information.

3. THE TYPES OF PERSONAL INFORMATION THAT WE COLLECT

Personal information is information or an opinion about an identified, or reasonably identifiable individual. 

The types of personal information that we may collect from you can include your name, contact details (such as your address and telephone number), date of birth, individual investment details, bank account information and tax file number. 

 The Corporations Act 2001 (Cth) requires us to collect your name, address and date of birth. Pursuant to the AML/CTF Act we are also required to collect additional personal information from you to verify your identity.

4. PERSONAL INFORMATION SECURITY

We regard the security of your personal information as a priority and have a number of physical and electronic protection measures in place. Please be aware that the Internet is not a secure environment hence no personal data is stored on our public website. 

5. FOR WHAT PURPOSES DO WE COLLECT, HOLD, USE and DISCLOSE YOUR PERSONAL INFORMATION?

 We collect, use, hold and disclose your personal information for the purpose of providing you with our products and services. Collection of your personal information allows us to identify you and assess applications for your investment in our trusts.  This includes:

• checking whether you are eligible for the product or service;
• verifying your identity;
• helping to manage the product or service;
• managing relationships with our clients;
• providing our clients with information about our products, services, the markets and developments that may interest them; and
• facilitating our internal business operations, including to fulfil our legal requirements.

Your personal information will also be used for related purposes which include, the administering and ongoing management of your investment, communication with you and compliance with Australian taxation laws, the Corporations legislation, the AML/CTF Act and other laws and regulations.

Throughout the life of the investment product or service, we may collect and hold additional personal information about you. This may include transaction information or making a record of queries or complaints you make. We may also collect personal information about individuals who are not clients of the Smithfield Group (e.g. business contact details of a company representative with whom we deal).

We take steps to ensure that our agents and third parties (e.g.: consultants, advisors and partners) keep your personal information confidential and use it only for the purposes for which they, and the Smithfield Group are authorised.

You may also authorise us to disclose information to other persons nominated by you. These persons may include accountants, financial planners and investment managers. Your express consent is required in these circumstances. We reserve the right to contact you directly pursuant to our statutory obligations under the AML/CTF Act.

6. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect most personal information directly from you. For example, we will collect your personal information when you apply to invest in one of our trusts or talk to us in person or on the phone.

Sometimes we collect personal information about you from other people or organisations. This may happen without your direct involvement, but as referred to above, your express consent will be required. For example, we may collect personal information about you from:

• your representatives (including your legal or financial adviser, administrator, trustee, or attorney); and
• other organisations, who jointly with us, provide products to you.

7. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose personal information for the purposes for which it was collected to:

our staff within the Smithfield Group;

• our professional advisors including financial advisors, legal advisors, auditors and consultants;
• our agents, contractors and external service providers;
• Authorised Representatives on our AFS licence who sell products on our behalf;
• other organisations, who jointly with us, provide products or services to you;
• your representatives (including your legal or financial adviser, accountant, trustee, or attorney); and
• fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct.
• We may also disclose your personal information to out-sourced back-office providers. The privacy standards of these providers must be at least in accordance with ours.
• No personal information that we receive is disclosed by us to recipients based outside of the Australian territory.

8. ACCESSING OR CORRECTING YOUR PERSONAL INFORMATION

You may contact us to request access to the personal information we hold about you at any time. You may also ask us to correct information about you that you may believe is inaccurate, incomplete or out of date.

We will need to verify your identity before giving you access to, or correcting your information.

In certain circumstances, we may not be able to correct or provide you with access to your information. In these circumstances, we will write to you to explain and provide the reasons as to why access cannot be granted.

We take all reasonable precautions to ensure that the personal information that we collect, use and disclose is accurate, complete and current. However, we recommend that you advise us if there are any errors in your personal information and that you update us on any changes to your personal information such as changes of name, address or bank account details.

9. RESOLVING YOUR PRIVACY CONCERNS & COMPLAINTS

If you have a query or a complaint regarding your personal information, please contact us (contact details provided below).

We will acknowledge your complaint within 10 business days of receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint. We aim to resolve complaints as quickly as possible.

If a complaint remains unresolved, you may apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. The Commissioner may be contacted on the privacy hotline: 1300 363 992.