Privacy Policy

In order to provide you with our products and services we will only collect necessary personal information. Personal information means information about you from which you can be reasonably identified.

The type of personal information we may collect about you includes, but not limited to:

• Full name;
• Date of birth, place of birth, residency, citizenship;
• Investment details and instructions, account numbers, usernames, passwords, 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, e-mail addresses and fax numbers;
• Tax File Number and bank account and payment method details;
• Documentation such as copies of drivers licence, passport or other such information as is required for the FTIA Group 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.

If you represent a financial adviser or corporate or institutional client (including as an employee or officer), we may collect additional personal information about you that will assist us in the provision of products and services to you and the client you represent.

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.

Generally, we will only collect personal information directly from you or your financial adviser or authorized representative or via our third party Administrator and Registry, unless it is unreasonable or impracticable to do so.

We collect personal information in a number of ways and this may depend on how you interact with us, which includes:

• Completion of application forms.
• Communication/correspondences between you or in person and our representatives.
• By telephone, email or website contact.
• From information about your transactions with us.
• From individuals who submit applications or register interest for employment with us, including form recruitment agencies or referees.
• From our conduct of marketing activities which may include requests for more information for example competitions, events or requesting ‘business cards’
• From third parties including your adviser or authorised representative.
• 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.
• Information that is collected by or transferred to other entities in the Franklin Templeton group of companies, including outside Australia. See the section below on “Personal information disclosed offshore".

We will only use your personal information for the purpose of providing you with our investment products and services. We will only collect personal information that is reasonably necessary for the FTIA Group to fulfil its functions and activities relevant in providing you with its investment products and services.

In managing your investment with us, we may use your personal information to:

• assess your application and provide our products and services to you.
• 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.
• 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, and
• assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of the FTIA Group and its contractors and service providers

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.

If we do not obtain all the information we need from you, the following may happen:

• we may not be able to provide you with and subsequently administer some or all our products or services, and/or
• we may not be able to provide you with information about our products and services.

To provide you with the services you require, and for the purposes set out above, we may disclose your personal information to another person or third party organizations. We take reasonable steps to ensure that these third party organizations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

We may disclose your personal information to the following third parties:

• Administrators who provide fund accounting, unit registry, custodial and other services;
• Service providers, such as your financial adviser. If a financial adviser’s stamp appears on your application form or if you otherwise inform us of having a financial adviser, we may supply your financial adviser with information about your accounts unless you instruct us otherwise in writing;
• Auditors, legal advisers, accountants, consultants or other professional advisers;
• A representative or agent 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;
• Archive providers, our related bodies corporate, contractors, or other third parties for the purposes specified above;
• Regulatory bodies, government agencies, law enforcement bodies and tax authorities;
• Market research providers for the purpose of assessing our services and products;
• Other organizations that you have authorised to receive your information, such as data aggregators;
• Other third parties where required, or allowed under law, or in connection with legal proceedings.

We will not sell or otherwise provide your personal information to other organizations, nor provide organizations outside the FTIA Group with your personal information unrelated to the management,  administration or regulation of your investment or the distribution of marketing materials.

We may also disclose your personal information to entities located overseas only for one or more of the purposes set out above.

We may send you direct marketing communications and information about our products and services that we expect may be of interest to you. These communications may be sent in various forms, including mail, SMS and email. You consent to us sending you those direct marketing communications by any of those methods. 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
E-mail: [email protected]

Or by using the unsubscribe function in all electronic communications we send to you.

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 recognize 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 are used to enable websites to function or to provide information to the owners of a website or other third parties which receive data obtained from that website.

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 that we can place cookies on your device. The cookies we use don’t include any information about your personal identity or your accounts. Simply accepting cookies from our website does not compromise the security of your account. We don't display any of your account information on our website. In certain instances, we may collect your personal information from a third party such as our registry services provider, a financial planner or adviser, your employer, companies that provide identification verification services or from some other person where it is reasonably necessary for us to do so and you have agreed to such collection. We may also disclose details about the 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 invest considerable resources to keep your personal information secure from misuse, loss, interference, unauthorised access, modification or disclosure. Access to and the use of personal information is regulated to prevent misuse or unlawful disclosure of the information. We use security procedures such as encryption, firewalls, intrusion detection and anti-virus technology to prevent unauthorised access. We also use valid log-in identification and password based security to achieve electronic information security. We retain information for as long as may be necessary to respond to issues that may arise later, and longer where required by law. When personal information is no longer required by us, it is destroyed or de-identified.

As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

FTIA Group is aware of its obligations under the Privacy Act where a breach of personal information data occurs and the breach is likely to result in serious harm to any individual impacted by the data breach. In such a circumstance, FTIA Group has procedures in place to conduct an assessment of the breach to determine if an Eligible Data Breach has occurred. If this is the case, FTIA Group will implement a process to manage the data breach, including notifying individuals impacted by the breach and if required, notifying the Office of the Australian Information Commissioner.

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. Before we give you access to information about you we may ask you to verify your identity. In normal circumstances we will give you full access to your information, however, at times there may be a legal reason why we must deny access, such as where granting access would interfere with the privacy of others or it would result in a breach of confidentiality. If access is denied, we will give you the reasons for any refusal in writing and the mechanisms available to complain about the refusal.

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 Victoria  3000.
 

OR

Email: [email protected]

OR

Phone: 1800 673 776
Email: [email protected]
Mail: PO Box 24011, Melbourne VIC 3001

Please address all written requests: ‘Attention: Privacy Officer’.

We will endeavour to ensure your personal information is kept accurate, complete, up to date and relevant. Please let us know if and when any of your details change.

If you believe that the personal information we store about you is incorrect, incomplete, inaccurate, misleading, or out of date, you may ask us to amend it.  We will deal with your request within a reasonable time. If we do not agree that there are grounds for amendment, we will give you the reasons for any refusal in writing and the mechanisms available to complain about the refusal, and we will add a note to the personal information stating that you disagree with the information. Any changes can be done by contacting the Privacy Officer using the contact information above.

If you have any concerns about how we have handled your personal information, please contact the Privacy Officer on the details above.

If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the 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, you may access an external dispute resolution service (if applicable) or apply to the Office of the Australian Information Commissioner (OAIC) to have the issue heard and determined.

When we write to you about our decision, we will explain how you may access an external dispute resolution scheme or make a complaint to the OAIC.

To facilitate the provision of our product and services to you, we may disclose your personal information to a member of the FTIA Group located overseas in the United States, Canada, Mexico, Brazil, the United Kingdom, Germany, Switzerland, Spain, Portugal, Italy, Ireland, 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.

We will review this policy from time to time and updates will be posted on the website and readers should review periodically.