Privacy

1. Scope

At Magellan Financial Group Limited (“Magellan”) your privacy is important to us.

This Privacy Policy relates to Magellan Financial Group Limited and its Australian related bodies corporate; Magellan Asset Management Limited and Airlie Funds Management Pty Ltd (together “Magellan”, “we”, “our” and “us”).

This Privacy Policy explains how we collect, hold, use, disclose and protect your personal information.

2. Collection of personal information

When you invest in a financial product that is offered by Magellan, personal information about you (such as your name, address, date of birth, bank account information and tax file number) is collected primarily through our standard forms (such as our application form).

When you visit our website, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent, user journeys and demographics. Information is collected on an anonymous basis and is used by us to analyse the efficacy of our marketing campaigns and to improve our website design and functionality.

We may collect your name, investor number, address, phone number, email address and postcode when you complete forms or sign up to publications on our website. This information is used by us to provide you with online access to your investments or to provide you with marketing material.

3. Use of personal information

We use your personal information to establish and administer your investment, comply with relevant laws and regulations such as the Anti-Money Laundering and Counter-Terrorism Financing Act and to communicate with you about your investment.

Personal information may be used for secondary purposes such as the provision of promotional and marketing material. You can contact us at any time if you do not wish to receive such materials or information.

Where we collect your personal information for a specific purpose (not contemplated in this Privacy Policy), you will be provided with a collection notice which explains the primary purpose (and any related secondary purposes) for which your personal information is being collected.

We do not actively seek to collect sensitive information (for example health information or information about any criminal record), unless it is necessary for business purposes. If we do have to collect sensitive information, we will only collect, use and disclose it in accordance with privacy laws

4. Disclosure of personal information

We may disclose your personal information to:

  • our external service providers that provide investment administration, registry, custody and/or other services;
  • any joint holder of an investment; 
  • parties authorised by you such as a licensed financial adviser, dealer group or service provider; and
  • governmental or regulatory bodies and agencies (such as ASIC, ATO, AUSTRAC or a law enforcement agency). 

Magellan uses third party investment administrators and registries to support the administration of our financial products. We have contractual arrangements with these service providers to ensure they comply with privacy laws when dealing with your personal information.

Your personal information may be provided to external service providers in offshore locations such as the Philippines and Luxembourg.

5. Accessing and correcting personal information

If you require access to, or wish to update your personal information, please contact our Privacy Officer:

Privacy Officer 
Magellan Asset Management Limited
Level 36, 19 Martin Place, Sydney, New South Wales, 2000
Tel: + 61 2 9235 4888
Email: privacy@magellangroup.com.au

If you believe that the personal information we hold is inaccurate, incomplete or out-of-date, you should contact us to correct this information.

We will endeavour to promptly update any personal information that is inaccurate, incomplete or out-of-date. If we do not agree that the personal information is inaccurate, incomplete or out-of-date, we will notify you in writing of our reasons to refuse any corrections. We will also notify you of what you can do if you are not satisfied with our response.

6. Protection of personal information

We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, interference, modification or disclosure.

We have physical, electronic and procedural safeguards to protect your information which is held by us. For example, your personal information is stored in secured office premises, electronic databases requiring logins and passwords for access and/or at one of our secured warehouses. Access to information stored electronically is restricted to staff whose job purpose requires access. We also require all staff to maintain the confidentiality of customer information.

We use secure methods to destroy or de-identify any personal information as soon as the law permits, provided the information is no longer required.

7. Eligible data breach

Our service providers are required to notify us of any unauthorised access, disclosure or loss of personal information.

In such a circumstance, Magellan performs an assessment to determine if there has been an ‘eligible data breach’ whereby the access or disclosure of the personal information is likely to result in serious harm to the individuals to whom the information relates. If Magellan determines there has been an ‘eligible data breach’ then the individuals affected will be notified as soon as practicable of the details of the breach and the recommended steps to take in response to it. If required, Magellan will also inform the Office of the Australian Information Commissioner at the same time. 

8. Contacting us

If you have any questions about this Privacy Policy or wish to make a complaint about how we have handled your personal information, please contact our Privacy Officer:

Privacy Officer 
Magellan Asset Management Limited
Level 36, 19 Martin Place, Sydney, New South Wales, 2000
Tel: + 61 2 9235 4888
Email: privacy@magellangroup.com.au

We will endeavour to answer any questions, correct any error on our part or resolve any complaint you may have about our information handling practices. If we do not resolve a complaint to your satisfaction, you may refer the matter to the Office of the Australian Information Commissioner (see www.oaic.gov.au).

Dispute Resolution Process

At Magellan Asset Management Limited (“Magellan”) your feedback is important to us.

What to do if you have a complaint:

Magellan is committed to providing investors with the best possible service. If at any time you are dissatisfied with a service provided by Magellan, please contact us so we can work towards a resolution. 

How to make a complaint:

Magellan accepts all complaints made orally or in writing, formally or informally.

  1. Please contact our Complaints Officer using any of the following methods:
    Phone: +61 2 9235 4888
    Email: complaints@magellangroup.com.au
    Mail: Magellan Asset Management Limited, MLC Centre, Level 36, 19 Martin Place Sydney, NSW 2000
     
  2. Please provide full contact details to enable us to respond to you quickly.
     
  3. Please provide as much detail as possible regarding the nature of your complaint and any supporting documentation.

We will:

  • Provide you with a written receipt of the complaint immediately, or as soon as practicable.
  • Provide you with a final written response setting out Magellan’s proposed remedy as soon as possible, but in any event within 45 days of receiving the complaint.
     
  • Note: The requirement to provide a final response will not apply where the complaint is resolved to your satisfaction by the end of the fifth business day after the complaint is received and you have not requested a response in writing.

Keeping you informed:

We will keep you informed at regular intervals about the progress of our investigations and response.

Still not satisfied?

Magellan is a member of the Financial Ombudsman Service (“FOS”). If you believe that your matter has not been dealt with satisfactorily, you can contact FOS:

Phone: 1800 367 287
Mail: GPO Box 3, Melbourne VIC 3001. 

You can also visit their website for further information http://www.fos.org.au/ or email them at info@fos.org.au.