Privacy Policy

We may collect the following personal information:

• Full name;
• Date of birth, place of birth, residency, citizenship;
• Investment details and instructions, account numbers, usernames, answers to security questions;
• Details about authorised signatories, agents, or representatives (including deceased estates);
• Copies of any relevant trust deeds, partnership agreements, constitutions, or articles of association;
• Contact details, including telephone numbers, addresses, email addresses and fax numbers;
• Tax File Number and bank account and payment method details;
• Documentation such as copies of driver’s licence, passport or other such information as is required for FTAL to comply with its legal obligations including identity verification, tax reporting and withholding and under the Anti-Money Laundering and Counter-Terrorism Financing legislation; and
• Other information that you provide to us in connection with your account.

Generally, we will only collect personal information:

• directly from you;
• from third parties including your financial adviser or authorised representative;
• from our third-party Administrator and Registry providers, unless it is unreasonable or impractical to do so;
• through marketing activities which may include requests for more information for example competitions, events or requesting ‘business cards’;
• if you are a contact of a corporate client or other organisation or an adviser within a dealer group, personal information may be collected from that entity.

We collect personal information in a number of ways and this may depend on how you interact with us. We may collect it through completed application forms where we offer our products and services, by telephone, by email and website contact, in correspondence with you or in person at one of our offices. We may also collect information about your transactions with us.

We, or a third party that we partner with, such as Google Analytics, may also collect information about you when you log in or browse our website via a ‘Cookie’.

A cookie is a file placed on a computer’s hard drive that allows a website to recognise that computer each time someone uses it to visit that site. It contains information about preferences for using the site that have been established by someone using that computer. They may also be used to keep track of the pages looked at during a visit as well as the path taken to those pages. We may use this information to make decisions about ways to improve the services we offer online. We specifically use cookies to tell us, in general terms, how and when pages in our websites are visited, and to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our site. This information is collected to analyse and improve our website, our marketing campaigns and to record statistics on web traffic. We may use “cookies” to help us tailor our website to better suit your needs (e.g. we may use cookies to enable us to save any personal preferences indicated by you) and to provide a more effective route to various components of our website. When you use our website, you agree to the use of cookies on your device. If you are concerned about having a cookie on your device, you can set your browser to refuse cookies and you can delete a cookie from your device. However, this may mean that certain features of the website may not function optimally.

We may also disclose details about your general use of our website to third parties – for example, to demonstrate patterns of use and other business partners. Information we pass on for this purpose will not include any personal data by which you may be identified.

We may also collect personal information from individuals who submit applications or register interest for employment with us. Such information may also be obtained from recruitment agencies or referees.

Personal information may also be collected by or transferred to other entities connected to FTAL, including those outside of Australia. See the section below on “Personal information disclosed offshore”.

In providing financial services to existing and prospective clients, we may collect personal information from individuals for a number of reasons including to provide a range of financial products and services. We will only collect personal information that is reasonably necessary for FTAL to fulfil its functions and activities, including (but not limited to):

• assess your application and provide our products and services to you;
• perform various functions and activities associated with the provision of financial products and services (including administering accounts);
• communicate with you in relation to your investment;
• monitor, audit, evaluate and otherwise administer our products and services;
• provide you with access to protected areas of our websites;
• marketing and promotional purposes and to tailor the content of materials that we send you;
• better understand how you use our products and services, for research and analytical purposes, for security purposes and communicating with you;
• provide continuous service to you and to conduct business processing functions including by providing personal information to our related bodies corporate, contractors, service providers or other third parties;
• assist with the administrative, planning, product or service development, quality control or research purposes of the FTAL Group and its contractors and service providers; and
• collect personal information to ensure we comply with our legal and/or regulatory requirements.

We may also use your personal information to make you aware of other FTAL products and services. You consent to us sending you these direct marketing communications. At any time you may opt out of receiving marketing communications from us by contacting us using the contact details below or by using the opt-out facilities provided in the marketing communications.

Please note that, if we are currently providing you with services or products, we will still need to send you essential information about your account, the relevant services or products and other information required by law. If you do not wish to receive such notifications, you can notify us at any time by contacting Client Services:

Phone: 1800 673 776

Email: [email protected]

Please be aware that there is certain information that we are required by law to provide to you and you cannot opt-out of receiving this information.

We will cooperate with all law enforcement bodies, including providing personal information we have collected from you when required or requested.

Generally, we will not collect sensitive information about you. Examples of sensitive information would include your race, religion, political beliefs, ethnic background or affiliations. If we need to collect sensitive information about you, we would only do so with your knowledge and consent and the information is reasonably necessary for our functions and activities.

FTAL has adopted an AI Governance Policy that articulates Franklin Templeton’s commitment to ethical, transparent, and secure development, procurement, and use of artificial intelligence (“AI”) applications. The policy articulates the need to protect personal data and that FTAL employees are to avoid inputting personal information (such as an individual’s name, tax IDs, account numbers, physical address, or candidate/employee sensitive or high-risk data) unless an AI tool has been specifically approved for such usage.

AI Security and Data Privacy

1. Data Protection - AI systems must adhere to the organisation’s data loss protection policies.
2. Data Privacy and Security: AI applications must comply with data privacy and security regulations.
3. Monitoring Global Information Security reserves the right to access and monitor the use of GenAI applications on any company-issued devices or that appear on company managed networks to ensure compliant use of these systems.

You are not obliged to provide any of the personal information we ask for. However, if we do not obtain all the information we need from you, we may not be able to provide you with information and subsequently administer some or all our products or services.

In order to fulfil our functions and activities, including to service your needs and perform our role, we may need to disclose your personal information with another person or third-party organisation.

Examples of such information disclosure may include:

• Administrators who provide fund accounting, unit registry, custodial and other services;
• Auditors, legal advisers, consultants or other professional advisers;
• Agents acting on your behalf, including financial and legal advisers, an administrator or trustee;
• A representative who is entitled to instruct on, or receive, the proceeds from a deceased investor's account balance (for example a Legal Personal Representative, executor, or administrator) or any person we contact to assist us in that process;
• Printers and mailing houses for the purposes of preparation and distribution of mail;
• Regulatory bodies, government agencies, law enforcement bodies and tax authorities;
• Market research providers for the purpose of assessing our services and products;
• Other organisations that you have authorised to receive your information, such as data aggregators.
• Archive providers, our related bodies corporate, contractors, or other third parties for the purposes specified above;
• Other third parties where required, or allowed under law, or in connection with legal proceedings.

We will neither sell your personal information to other organisations, nor provide organisations outside of FTAL with your personal information unrelated to the management or administration of your investment or the distribution of marketing materials.

Where there has been a breach of your personal information that is likely to result in serious harm to you or you and other individuals, we will notify you and the Office of the Australian Information Commissioner under the Notifiable Data Breaches Scheme. Under the scheme, there is an eligible data breach if your personal information is accessed or disclosed without authorisation, or is lost, and this data breach is likely to result in serious harm.

We rely on the accuracy of personal information provided. You may ask us at any time to correct personal information held by us about you and which you believe is incorrect, incomplete, misleading or out of date. We will deal with your request within a reasonable time (generally within 30 days). You may request access to the personal information we hold about you at any time and such requests should be directed to the Privacy Officer as follows:

Franklin Templeton Australia Limited

Level 47, 120 Collins Street

Melbourne VIC 3000

Phone: 1800 673 776

Email: [email protected]

There may be exceptions allowed by law as to why we will not allow access. If access is denied, we will provide you with reasons why.

If you believe your privacy has been breached, or if you have a complaint in relation to a possible breach of the Australian Privacy Principles by us, you can direct this complaint directly to the Privacy Officer on the details above. We will seek to provide a response as soon as practicable and, in general, no later than 30 days after receipt of the initial complaint.

We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the Investigating Officer and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

If a complaint remains unresolved, or if you are not happy with our response, you may apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. Contact details for the OAIC are as follows:

Office of the Australian Privacy Commissioner Post:

GPO Box 5218

Sydney NSW 2001

Telephone: 1300 363 992

Web: www.oaic.gov.au

You may also refer a complaint to an external dispute resolution service (if applicable), details of which will be provided to you at such time.

We may disclose your personal information to another Franklin Templeton entity located overseas, including in the United States, Canada, Mexico, Brazil, the United Kingdom, Germany, Switzerland, Iberia, Italy, Belgium, Luxembourg, France, Sweden, Spain, Poland, Dubai, India, China, Hong Kong, Japan, Malaysia and Singapore. This list may be updated from time to time on our website. If you consent to the disclosure of such personal information, you need to be aware that the privacy laws in these countries may be different to your country of residence. Unless you inform us otherwise, you consent to any such disclosure.

This Policy is located on our website, franklintempleton.com.au. Should there be a material change, we will update the Policy and if required make an announcement on our website.