Privacy policy

Scope of this policy

This policy is authorised by Rajomon Asset Management Pty Ltd (ABN 72 654 721 043), which operates Lonvera, and applies to the company and its Australian related entities.

The information we collect

Whenever it is reasonable and practicable to do so, we only collect information about individuals directly from individuals.

The type of information collected by us will depend upon your relationship with Lonvera and may include:

• name and title
• address
• contact details
• detail on entities through which you invest
• date of birth
• bank account details
• employment details
• citizenship
• shareholding details
• Australian Tax File Number.

In most cases, and wherever possible, Lonvera will try to collect personal information only from you. Information will be collected through various company forms and from you directly, either in writing or verbally.

Personal information is information or an opinion about you from which you can be reasonably identified. Lonvera collects personal information so that we can provide you with our products and services and comply with our legal obligations such as those under superannuation laws, taxation laws and the Anti-Money Laundering and Counter-Terrorism Financing Act. If Lonvera does not collect your personal information, we may not be able to provide you with a product or service.

We do not generally collect sensitive information about individuals unless required by applicable laws or rules. Sensitive information includes information relating to:

• race
• political or religious beliefs
• sexual preferences
• criminal convictions
• membership of professional or trade associations or unions

We also collect personal information from people who submit applications or register interest for employment with Lonvera.

In addition, we may collect personal information about individuals who are not customers of Lonvera (e.g. business contact details of a company representative with whom we deal).

Depending on how you choose to interact with us, we may collect your personal information when you contact us or our service providers by telephone, by email, through our website, complete an application or registration form, or when you meet one of our representatives face to face.

Lonvera may also collect information about you from third parties. For example, Lonvera may collect personal information from:

• your authorised representatives and advisers
• our service providers
• your employer, or
• our corporate clients, where we are providing services to them.

How your information is held

Your personal information is held in our registry systems for our investors and shareholders.

Generally personal information is stored electronically with hard copy records retained and archived with an archival service provider.

All internal systems are subject to the security measures detailed in this policy. All external service providers are contractually required to hold personal information in accordance with the Act.

How information is used

Lonvera collects personal information about you primarily:

• to provide you with the products and services you request
• to provide you with the information you request
• to verify your identity before transactions are processed, your instructions are carried out, or providing you with information about your investment
• to administer your financial product
• to provide you with information about other products or services offered by Lonvera or its related entities
• to respond to your enquiries or complaints
• to satisfy any legal requirements.

Laws and rules regarding the use of personal information may vary by jurisdiction. Lonvera complies with applicable laws and rules in the related jurisdiction.

We may also collect, use and exchange your information in other ways where permitted by law.

Anti-money laundering and counter-terrorism financing

The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) is aimed at addressing money laundering in Australia and the threat to national security caused by terrorism. This legislation requires us to collect identification information from investors into our investment products and to verify your identity from original or certified copies of specified documents. Details of what identification information and documentation you are required to provide are set out in transactional based forms. We may also contact you to follow up and clarify certain information.

Under this legislation we are also required to monitor transactions to identify any suspicious activity within any of our investment products.

As required under the AML/CTF Act, we may, in our absolute discretion, without notice to you, disclose or otherwise report details of any transaction or activity, or proposed transaction or activity (including any personal information) to the relevant reporting body.

Disclosure of personal information

Lonvera does not sell, rent or trade personal information to, or with, third parties.

In some circumstances your information may be disclosed to Lonvera’s related entities or service providers that perform a range of services on our behalf, such as:

• outsourced service providers including administration, custodial and registry service providers, printers and mailing houses, and information technology systems
• solicitors, accountants, real estate agents or other advisors to provide professional advice in relation to one of our services
• investment managers or other financial institutions to facilitate an investment
• software providers, actuaries, professional advisers and research organisations
• business partners, including insurance underwriters
• government agencies including APRA, ASIC, AUSTRAC, Centrelink or the ATO
• financial intermediaries such as financial planners
• related companies.

Where Lonvera contracts with an outsourced service provider or business partner we take reasonable steps to protect the privacy of any information disclosed to them. This includes inserting confidentiality provisions and a requirement to comply with the Act in our contractual arrangements.

Some of the third parties to whom we disclose your personal information may be located outside Australia. For example, we may disclose your personal information to external national or overseas facilities in the course of conducting information and data processing, back up and scanning or for the purposes of obtaining other services from third parties.

Opting out of product or service offers

From time to time Lonvera may wish to use your information to tell you about other products, services or special events or offers that we think may be of interest to you. Please let us know if you do not want to receive these offers by contacting us using the contact details noted below.

Quality of information

Lonvera aims to ensure that the personal information we retain about you is accurate, complete and up to date. Please provide us with complete and accurate information and keep us informed of any changes in your details such as a change of address.

If you do not provide all or part of the personal information that we request we may not be able to contact you or to administer your investment properly.

If you believe that the information we hold about you is inaccurate please contact us directly using the contact details provided below, so that we can update our records.

Security of information

Lonvera will at all times take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. Your personal information is treated as confidential.

Employees and contractors of Lonvera are bound by confidentiality obligations.

We may store your files in hard copy or electronically in our ordinary IT systems. These may include Australian-based cloud servers or the servers of third parties within Australia.

We implement a range of physical and electronic security measures to protect the personal information that we hold including password controls, firewalls and virus protection.

All premises housing our systems and other copies of your information are monitored and protected by security alarms and access card or key lock entry.

Service providers who hold personal information are contractually required to hold information in accordance with the Act and Lonvera obtains periodic confirmation of adequate information security management.

Your rights of access and correction

You are entitled to obtain access to your personal information subject to some exceptions allowed by law. You may also request that Lonvera correct or update information that we hold on you. We encourage our customers to ensure that their personal information is accurate and up to date, particularly mailing address and contact details. We include regular reminders in correspondence with our customers.

If you wish to make a request for access to your personal information please contact us using the contact details below.

Complaints

If you have a complaint related to how Lonvera has managed your personal information, please contact our Privacy Officer, whose details are set out under Contact details. Lonvera will consider your complaint and respond in the manner detailed in our Dispute Resolution Guide (if you are a retail investor) or in the manner set out in your offer document (if you are a wholesale investor) or otherwise within 30 days. If your complaint is still not satisfactorily resolved, you may consider lodging a Privacy Complaint Form with the Office of the Australian Information Commissioner. For more information, please visit the Australian Information Commissioner’s website.

Changes to this policy

From time to time it may be necessary for us to review and revise our privacy policy. We reserve the right to change our privacy policy at any time.

The Board will review and approve any changes to the Privacy Policy.

Contact details

If you have any questions about this privacy policy, if you wish to complain about how we handled personal information about you, or if you wish to access or correct your personal information, please contact Lonvera’s Privacy Officer by using the following address details: