Lighthouse Privacy Policy

This is the Privacy Policy for Lighthouse Funds Management Pty Ltd ACN 611 913 547, holder of Australian financial services licence number 489340 (“Lighthouse”, “we”, “us” or “our”). Lighthouse is in the business of promoting wholesale managed funds.

In this Privacy Policy, “you” or “your” refers to you as a current or prospective investor, individual user of our website or other services, or any other individual who we may collect personal information from.

This Privacy Policy applies to Lighthouse separately and distinctly. If you are dealing with Mavid Group with whom we are affiliated, we recommend you review the terms of their privacy policy before providing them with any of your personal information.

About this Privacy Policy

We respect your privacy and we are committed to managing your personal information responsibly and in accordance with our legal obligations under the Privacy Act 1988 (Privacy Act). The Privacy Act regulates the way we collect, hold, use and disclose personal information.

The Privacy Act defines personal information as ‘Information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.’ Personal information does not include information that has been made anonymous and cannot reasonably identify a specific person.

This Privacy Policy contains information on our collection and management of personal information.

We collect, hold, use and disclose personal information of individuals in the course of performing our functions and activities and in providing products and services. The type of information we collect and purpose for which will depend on your relationship with Lighthouse and the circumstances in which the information is provided. Circumstances may include whether you are a prospective or actual employee of Lighthouse, a recipient of financial services, or otherwise.

If you provide us with your personal information, then you agree to your information being managed by us in accordance with this Privacy Policy.

Anonymity

You are not required to provide us with your personal information when dealing with us. When dealing with us, you have the option of not identifying yourself or using a pseudonym. However, if you do not identify yourself to us, then we may not be able to provide you with our products or services. If you do not identify yourself or provide us with your contact details, we may not be able to respond to any inquiries or complaints you may have.  

Changes to our Privacy Policy

We may update and revise this Privacy Policy from time to time.

The current version of our Privacy Policy will be accessible on our website free of charge at: www.lighthousefm.com.au or you can contact our Privacy Officer at the contact details below.

What kinds of personal information do we collect and store?

The personal information we may collect and hold will depend on the relationship you have with us, and may include the following—

1. Your full name, date of birth, occupation, contact and other details (including your residential address, e-mail address, and fax and telephone number)
2. Details of any entity through which you have dealings with us
3. Information and/or documentation (such as drivers licence or passport) to verify your identity for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and/or other legislation and regulations regarding identification verification, and tax reporting and withholding.
4. Your bank account details for the purpose of administering investor accounts
5. Your tax file number (as permitted under tax laws and the Privacy Act) for the purpose of tax reporting and withholding
6. Information and/or documentation evidencing that you qualify as a “wholesale client” within the meaning provided in Chapter 7 of the Corporations Act 2001

7. Information that allows us to evaluate whether to provide products or services to you, and to manage our relationship with you in providing such products or services.
8. Information you may provide when applying for employment at Lighthouse, including for example, a resume or other onboarding documents.
9. Any other personal information you provide when you make an inquiry, request information or otherwise correspond with us.

How do we collect your personal information?

Unless it is unreasonable or impractical for us to do so, we will collect your personal information from you directly, including—

1. From application or inquiry forms, such as an application form completed by you to acquire a product or service from us
2. From using our website www.lighthousefm.com.au, any internal website or intranet pages, and any of our social medial pages (together, our “Website”)
3. From our marketing and promotional communications in which we howsoever receive personal information from you (this may include competitions or other activities in which we request or collect personal information)
4. From communications between you and our officers, employees and representatives which may be conducted in person, over the phone, by email, via our Website or otherwise
5. However, we may also collect information about you from third parties, such as—
6. your financial or other professional advisor, broker or agent
7. your attorney or authorised representative such as your executor or administrator
8. your recruitment agent, previous employers and other persons who may act as referees or otherwise be able to provide information to assist us in decision whether to offer you employment
9. outsourced service providers or contractors
10. interactions with credit reporting bodies and identity verification services
11. other third parties you have authorised to provide your personal information

How do we hold your personal information?

All personal information we collect will be held securely and in accordance with this Privacy Policy.

Generally personal information is stored electronically with hard copy records retained and stored securely. We will protect your personal information and prevent unauthorised access through the use of secure passwords, user logins, or other security procedures, including firewalls and anti-virus technology.

However, we cannot provide any assurance regarding the security of information transmitted to us online, as the internet is inherently insecure. Nor can we guarantee the supply of information to us from you will not be intercepted. Information you transmit to us online is at your own risk.

Part IIIC of the Privacy Act established the Notifiable Data Breaches Scheme (NDB Scheme) in Australia. The NDB Scheme sets out obligations for notifying affected individuals and the Australian Information Commissioner (Commissioner) about a data breach which is likely to result in serious harm. Where serious harm to affected individuals is likely, we will notify those individuals and the Commissioner in accordance with our legal obligations. You may contact our Privacy Officer using the details set out below should you require additional information.

What purposes will we collect, hold, use and disclose your personal information?

The purposes for which we will collect, hold, use and disclose personal information from you will depend on your relationship with Lighthouse. Generally, the primary purpose for which we collect, hold, use and disclose personal information is to—

1. carry on our business as Fund Manager, provide our products and services, and prepare administrative and/or operational reports relating to such
2. provide you with information about products or services offered by us or a Fund we promote or operate
3. assess your application, and establish and administer your investment
4. comply with our obligations under the AML/CTF Act and other legislation and regulations regarding identification verification, and tax reporting and withholding
5. verify your identity before we act on your instructions and/or process transactions including to provide information about your investment
6. maintain our relationship with you, including to respond to your enquiries, feedback or complaints and provide you with information as requested
7. assist with research and development, marketing (including direct marketing), quality control or other administrative purposes of ours and/or our contracted service providers
8. assist in determining whether to offer you employment or engage you under a contract, and to manage such a relationship
9. evaluate whether to enter into agreements with you, maintain contact details and relevant records, respond to communications from you, investigate any incidents or complaints, process transactions
10. manage risks including loss prevention, claims management and litigation
11. improve the quality of our services and for training purposes
12. comply with any law, regulation, and enforceable standards.

Disclosure of personal information

Personal information may be disclosed to:

1. outsourced service providers and organisations involved in the provision of, management or administration of our products or services (such as custodians, registries, administrators, printing mail houses and information technology providers)
2. auditors, consultants and other professional advisors such as accountants, lawyers
3. your authorised agents including financial intermediaries
4. third parties you have authorised to receive your personal information (or are otherwise required to provide such to in connection with legal proceedings)
5. government agencies and regulatory bodies such as the Australian Taxation Office, Australian Securities and Investments Commission, Australian Transaction Reports and Analysis Centre
6. other parties we are required by law to disclose information to

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or that you have consented to us making the disclosure.

Where Lighthouse contracts with an outsourced service provided, we will take reasonable steps to protect the privacy of any information disclosed to them, including by requiring them to comply with the Privacy Act.

Are we likely to disclose your personal information to overseas recipients?

We will not disclose your personal information to overseas recipients unless required to do so by law or specifically instructed to do so by you.

Use of our Website

The use of our website is governed by the Terms of use available at: www.lighthousefm.com.au.

Direct marketing

We may also send you direct marketing communications and information about any other products or services offered by us or our related parties that we expect may be of interest to you. These communications may be sent in various forms, including mail, fax and email. At any time you may opt-out of receiving marketing communications from us by contacting the Privacy Officer using the details set out below.

We will not sell your personal information nor will we provide it to third parties except as described in this Privacy Policy.

How you can access and correct your personal information held by us 

We take all reasonable steps to ensure the personal information we retain is current, accurate, complete and securely maintained.

You may request access to any of your personal information held by us. Your right to access is subject to some exceptions allowed by law. We will notify you of the basis for any denial of access to your personal information.

Please let us know if any of your details change and we will update our records accordingly. If you notice that your personal information is inaccurate or incomplete, please notify us and we will take reasonable steps to correct our records. If we do not agree that there are grounds to amend our records, we will include a note with the personal information which states that you disagree with it.

Please contact our Privacy Officer using the below details to request access to or correct any of your personal information held by us.

How can you complain about a breach of privacy?

If you have a complaint about a breach of this Privacy Policy including the manner in which we have collected, held, used or disclosed your personal information, then you may make a complaint to us using the contact details set out below. You will need to provide us with sufficient details regarding your complaint and any supporting evidence.

Our Privacy Officer will investigate your complaint and determine the steps we will take to resolve your complaint. We may ask you to provide more information.

We will notify you in writing of our determination, generally within 30 days. If you are not satisfied with our determination or you do not receive a response within 30 days, then you can contact us to discuss your concerns and you can refer the complaint to the Office of the Australian Information Commissioner www.oaic.gov.au.

Request a copy of this Privacy Policy and further information

A copy of our current Privacy Policy is available from us free of charge from our website, www.lighthousefm.com.au. You can also request a copy of the Privacy Policy to be sent to you. If you would like a copy of this Privacy Policy in a particular form (for example, on audio disc), then please contact us and we will accommodate any reasonable request.

If you have any further questions relating to this Privacy Policy, would like to request a copy of our Privacy Policy, or if you have any concerns about the way in which we have handled your personal information, then please contact our Privacy Officer as follows:

Kathleen Moran

Email: kathleenmoran@mavidgroup.com.au

Phone: 02 4015 2666

Post: PO Box 93 Lorn NSW 2320