Privacy Policy.

This Privacy Policy contains important information about how Cor Capital Pty Ltd ACN 155 801 817 (“Cor Capital”, “we”, “us” or “our”) manages your personal information. In cases where this Privacy Policy refers to “we” or “us”, those terms include Cor Capital Pty Ltd and the administrator and custodian of the Cor Capital Fund, the Myer Family Company Ltd, who will comply with the provisions of the Privacy Act 1988 and the Australian Privacy Principles in relation to the collection, holding, use, disclosure and security of your personal information.

The Myer Family Company Ltd’s Privacy Policy can be found on its website: www.mfco.com.au and contains information about how your personal information may be accessed and corrected and how you may complain about a breach.

The document has been developed using a “layered” format which means you can therefore read as much or as little as you like and can find what you need quicker by clicking on the references (if reading it electronically) or going to the relevant section heading (if reading in hardcopy).

About this Policy

This Policy describes the implementation of Cor Capital’sobligations under the Privacy Act 1988 and meets the requirements of Australian Privacy Principle 1 (APP 1).

Our approach to Privacy

Cor Capital is bound by the Australian Privacy Principles (APPs) and aims to comply at all times with the privacy laws. We aim to respect our customers’ right to privacy and value the confidence our customers place in us to safeguard their personal information.

Cor Capital is an “APP entity” under the Privacy Act 1988 (Privacy Act)because it collects personal information, including tax file numbers, and is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the anti-money laundering laws). As a reporting entity under the anti-money laundering laws, we have obligations to collect personal information from customers. The collection, use, storage and disclosure of that personal information is subject to the requirements of the Privacy Act 1988.

Collection

Cor Capital collects, holds and uses personal information from its customers for the purposes of complying with our regulatory obligations and for providing financial services and products to customers and successfully performing its other business functions as outlined below.

We collect personal information that includes details such as your:

  • Name (including aliases);
  • Contact details (including postal and email addresses and phone numbers);
  • Date of birth;
  • Tax file number;
  • Employment details;
  • Driver’s licence number or passport number;
  • Bank account details;
  • Occupation; and
  • Financial information such as information about the financial products and services you acquire from or through us.

We only collect personal information by fair and lawful means, and usually collect it directly from you. Your name and initial contact details may be collected from referrals such as from our existing investors. In this case, we would contact you to seek approval to add your details to our newsletter database and seek to meet with you to explain how our Cor Capital Fund works.

We gather personal information from written documents (such as our application forms), or verbally when we speak to our customers, and we collect certified copies of specified identification documents to meet our obligations for identifying our customers under the anti-money laundering laws.

If unsolicited information is received, we will assess whether the information could have been collected in accordance with this Policy – for instance as a referral from an existing investor – and if it could not have been collected we will destroy or de-identify it.

Wherever practical, we provide our Privacy Collection Notice to new customers and take care to seek consent from them before we record their personal information.

It is not possible for a customer to retain anonymity when obtaining the financial services provided by us because of the anti-money laundering laws. If a customer does not provide all the information we require we will not be able to establish and administer an account for them to provide the financial service or issue or arrange for the issue of a financial product to them. In some cases, we may be required by obligations under the anti-money laundering laws to collect additional personal information on an application or at a later time.

Accessing Cor Capital’s website

We take care to protect any personal data we collect, process, use or store during visits to the Cor Capital website. When you visit our website, either we or our internet service provider will record information in relation to your visit for statistical purposes. The information collected will be your computer’s IP address, the website from which you visit us, type of browser software used, the web pages you actually visit, the date and time you accessed the webpage, and the duration of your visit. We use that data only for the purposes of technical administration and research and development of the Cor Capital website. For instance, we may keep a record of which parts of our website you visited and whether you visited our website from a banner advertisement on another website.

We use tracking technology on our website, such as cookies or tags, to gather the information outlined above in order to make it easier to use the website by storing information about your preferences. Cookies are very small text files that a website can transfer to the hard drive of a computer which accesses it for keeping a record of that computer. This enables you to take full advantage of our services when you access our website and enables us to manage and improve the usability of the website and market our services most effectively. The cookies we use will identify your computer but will not identify you.

Use and disclosure

We only use personal information for the purpose for which it was provided to us, that is for the purposes of providing financial services and products to you, or for related purposes that would not reasonably require specific permission from our customers.

Our business functions 

    1. (a)Provision of financial services 

As a Licensee, Cor Capital provides financial products and services authorised under our AFSL, including issuing interests in and operating our regulated managed fund, the Cor Capital Fund. The Myer Family Company Ltd collects information for the purposes of providing administration services for the Cor Capital Fund.

We are required by law to obtain a Tax File Number (TFN) from customers. The handling of TFNs is regulated under the Privacy Act and Cor Capital is committed to maintaining the security of its customers’ TFNs in accordance with the Tax File Number Guidelines.

    1. (b)Handling complaints

We may need to collect additional personal information from our customers in the process of handling a complaint from them. If that is necessary, we will collect that information from them over the phone or from correspondence and we will let the customer know at the time that we are collecting the personal information for the purposes of resolving their complaint.

    1. (c)Sending out our newsletter 

We will use the personal information we collect from our customers to provide them with updated information about our range of products and services in our newsletter. Customers may choose not to receive the newsletter at any time by notifying us of this choice.

Disclosure of personal information – generally

Cor Capital does not sell, rent or trade personal information to or with any other organisations. We may disclose a customer’s personal information to:

    • the Myer Family Company Ltd, which provides custody and administration services to us, and other persons to enable us to administer the financial products or financial services we provide to customers, including lawyers or auditors, entities providing finance, insurance, maintenance, registration and other services;
    • third parties the customer authorises to act on their behalf; and
    • government agencies such as the ATO, ASIC and AUSTRAC under corporations, taxation, social security, or anti-money laundering laws.

The Myer Family Company Ltd may provide your Personal Information to the following recipients:

    1. (a)The Myer Family Investments Pty Ltd and any of its subsidiaries;
    2. (b)any sub-contractors, agents, service providers, including their officers and employees;
    3. (c)any person or entity as may be necessary for administering your investment;
    4. (d)any third party fund manager;
    5. (e)professional advisers, including accountants, auditors and lawyers;
    6. (f)government and regulatory agencies.

In particular we have “Know Your Customer” obligations under the anti-money laundering laws. If certain thresholds are met during a transaction with a customer, Cor Capital is obliged to disclose that information to AUSTRAC.

When we disclose a customer’s information to third parties, we will take all reasonable steps to ensure that those third parties comply with the Privacy Act.

Disclosure to overseas recipients

When collecting a customer’s personal information, we will generally notify the customer of any other overseas recipients to whom we may likely disclose their personal information. Before disclosing the customer’s personal information to an overseas recipient, we will take all reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to that information. If we cannot ensure this, we will not disclose your personal information without your consent.

The Myer Family Company Ltd has entered into agreements with one or more IT service providers operating outside of Australia. As a consequence, personal information may be subject to cross-border disclosure between Australia, Canada and the USA. You acknowledge that by consenting to us disclosing your personal information to overseas recipients, the APPs will not apply to the disclosure. This means we will not be obliged under the Privacy Act to take reasonable steps that an overseas recipient does not breach the APPs and we may not be liable under the Privacy Act if the recipient does not act consistently with the APPs.

Storage and security

Cor Capital takes reasonable steps to keep the personal information that it holds about you secure. Our records and the personal information of customers are stored by the administrator electronically on its computer systems which are maintained by it and secured by password protections and in paper files secured by physical access restrictions.

We have taken all reasonable measures to protect the information in our records. Access to personal information within Cor Capital is strictly limited to prevent any loss, unauthorised access, use, modification or disclosure. We annually review our security and risk management measures around security of information.

If a customer receives more than one financial product or financial service from us, we will link the personal information about the customer between those products and services.

We will de-identify or dispose of a customer’s personal information in a secure manner when it is no longer required, not contained in a Commonwealth record and is not legally required to be retained. However, personal information which is the subject of a complaint, inquiry or legal process will not be destroyed until the resolution of that process.

Access and correction

A customer may request access to their personal information held in our records by contacting our administrator, the Myer Family Company Ltd. The Myer Family Company Ltd will generally provide you with access to that information in a form or manner suitable to your needs. Access will not be unreasonably withheld but may not be able to be provided in some circumstances. These include circumstances where:

    • life, health or safety would be seriously threatened;
    • it would be unlawful to do so;
    • access would prejudice action undertaken or contemplated by a law enforcement agency;
    • it would unreasonably impact upon the privacy of other individuals or compromise The Myer Family Company’s legitimate commercial negotiations.
    • providing access would pose a serious threat to any individual;
    • providing access would jeopardise the privacy of other individuals;
    • where the customer makes an unreasonable request for access for the purpose of creating a nuisance;
    • the information relates to existing or anticipated legal proceedings between us and the customer, and the information would not be accessible by the process of discovery in those proceedings;
    • providing access would unreasonably prejudice our commercial dealings with the customer;
    • providing access would be unlawful;
    • denying access is required or authorised by or under law; or
    • providing access would jeopardise an investigation of possible unlawful activity.

In circumstances where we have refused access to a customer’s personal information in the manner requested by the customer, we will:

    • •take all reasonable steps to give access in some other way that meets the customer’s needs; and
    • •provide a written notice which sets out the reasons for refusal, the mechanism to complain about the refusal and any other matters prescribed by law.

We may seek reimbursement for providing access to the personal information we hold about you where expenses were incurred in retrieving and collating the requested information.

Seeking correction of personal information

While we use our best endeavours to ensure the quality of our records, and to maintain the accuracy, currency and completeness of all personal information collected, we rely on the accuracy of the personal information provided to us and we request and appreciate our customers’ assistance in maintaining the quality of our records by contacting us if any personal information is found to be inaccurate or incomplete.

A customer can request that their personal information be updated by contacting the administrator – the Myer Family Company Ltd.

We will make the changes to the customer’s personal information unless there is a sound reason not to make the changes. We will inform the customer when the changes have been made and ask whether the customer wishes us to inform any third party of the correction.

In circumstances where we have refused to correct a customer’s personal information, we will give the customer written notice setting out reasons for denial to correct personal information.

Privacy concerns or complaints 

A customer can contact the administrator or the Managing Director of Cor Capital, Davin Hood, to request further information about anything discussed in this Privacy Policy.

A customer is entitled to lodge a complaint with us if they have a complaint about how we deal with their personal information or if they believe that we, or one of our contractors, have breached the Australian Privacy Principles. The customer must tell us about their complaint first, so we ask the customer to please telephone the administrator or the Managing Director to discuss their complaint. We may ask the customer to lodge their complaint in writing.

We continually strive to ensure our customers are satisfied and will use our best endeavours to resolve complaints in a timely manner. We will acknowledge receipt of a customer’s complaint within 7 days and provide a response to their complaint within 30 days.

Where a customer’s complaint is not resolved to their satisfaction within a reasonable time, we will refer them to the Office of the Australian Information Commissioner (OAIC). Contact details for the OAIC can be found at www.privacy.gov.au where you can also find more information about privacy in general.

Contacting us

Cor Capital’s Privacy Officer is Davin Hood, Managing Director, who supervises our provision of financial services in compliance with our AFSL licence. He owns the Policy and is responsible for testing its effectiveness, and for reviewing and updating it. The Policy is generally updated, if required, on an annual basis, but the Privacy Officer will also update the Policy if a material issue with the Policy is detected as a consequence of the results of the testing process or of a privacy complaint.

Our Privacy Officer may be contacted as follows:

The Managing Director
Cor Capital Pty Ltd
Suite 19, 644 Chapel Street
South Yarra VIC 3141

Phone +61 3 9823 6292
Fax +61 3 9826 3642
Email contact@corcapital.com.au

Our Administrator may be contacted as follows:

The Administrator
Cor Capital Fund
c/- The Myer Family Company Ltd
Level 18, 8 Exhibition Street
Melbourne VIC 3000

Phone +61 3 9207 3000
Fax +61 3 9207 3001

This Privacy Policy is easily available to our customers free of charge and in hard copy
or electronically by requesting it from our Privacy Officer or via our website.

Updated: August 2014