Privacy Commitment

Talaria Asset Management Pty Limited (Talaria) respects the privacy rights of our clients and other organisations with whom we deal (you). Talaria is committed to complying with all applicable privacy laws including the Privacy Act 1988 (Cth) and Australian Privacy Principles(APPs).

1. What personal information do we collect?

We only collect personal information necessary to manage our relationship with you, administer the products and services you request, notify you about our products and services and to comply with applicable laws. Information collected is only used and disclosed in a manner consistent with applicable laws and this Privacy Policy.

The personal information we may collect, hold and/or use about you will depend on the type of product and service you request. Examples of personal information we may collect include, but are not limited to:

• personal identification and contact details
• banking, payment and contribution details
• tax file number
• records of service contacts
• employment details and history.

We will only collect, maintain and use personal information about you if it is necessary for us to adequately provide you the products and services you have requested, provide you with information about other products and services offered by related body corporates or to meet our obligations under applicable Laws (e.g. the Anti-Money Laundering and Counter Terrorist Financing Act (2006) (AML Act).

We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access and disclosure. Additional privacy measures are employed to protect any sensitive information. You have the right, where it is lawful and practicable, of remaining anonymous when entering into transactions with Talaria. However, should you wish to remain anonymous, we may not be able to provide you with our products and services.

Where you provide us with unsolicited personal information which we do not require to deliver products and services to you, such information will be subject to our normal security arrangements for client information. Where reasonable to do so, we will not hold unsolicited personal or sensitive information we do not require, however often we are unable to delete such information, particularly where it forms part of correspondence or other interactions that we do need to retain. Deletion in such circumstances is generally not reasonable or practicable.

Personal information records are held for a period considered appropriate to provide you with the product and/or service you require and consistent with applicable laws and the Privacy Act.

Should you cease to be a client of Talaria, any personal information which we hold about you will be maintained for the relevant periods required by law.

2. Information collected by third parties

We utilise external fund administrators, unit registries, Responsible Entities and other third parties to assist in the provision of services. This may require you to disclose to the third party personal information. Where you disclose personal information, for example by completing a third party application, the privacy statement of the third party applies and this privacy policy does not apply. However, Talaria will endeavour to ensure that the third party meets its privacy obligations.

3. How do we collect and hold your personal information?

In most cases, we collect your personal information directly from you, face to face meetings, application forms or correspondence (written and verbal). However, if this is not practical, we may collect information about you from another person or entity– for example, receiving information from a person to whom you have granted a delegated authority or power of attorney or from trustees and Responsible Entities.

Only where it is necessary to do so, we may collect personal information about you that is sensitive. (e.g membership of a professional or trade association). Unless we are required or permitted by law to collect that information, we will obtain your consent. However, if the information relates directly to your ability to meet financial obligations that you owe to us, you are treated as having consented to its collection.

We or a third party may require the collection of personal information for the purposes of providing investment services to you. We or any third party service provider will disclose at the time of collecting the personal information that you are taken to have given consent to providing your personal information if you proceed with an investment.  A link to the relevant party’s privacy policy will also be included.

4. How do we use your information?

We use your information to primarily manage, deliver and administer the products and services you request. Personal information may also be used so that we can offer products and services to you including special offers (with your consent, and subject to your right to unsubscribe or opt-out) to extend our relationship with you and to develop products and services better suited to your needs. We may also use and analyse your information to meet our obligations under applicable laws, for example the Know Your Customer requirements of the AML Act.

We respect the rights of our client to choose the material they want to receive and how they wish to receive it, including by electronic means. You can therefore choose to receive only the materials you want by calling (03) 8676 0667.

5. Who do we disclose information to?

Talaria will only disclose personal information to third parties for the purposes of managing, delivering and administering the product and service you require and in accordance with this Policy and applicable laws. For example, we may disclose relevant personal information to:

• agents and brokers(intermediaries) to enable them to efficiently answer enquiries and process transactions
• for legal reasons, disclosure may need to be made to law enforcement agencies, government agencies, courts or external advisers, for example to meet our obligations under the AML Act
• a person acting on your behalf including a financial adviser, trustee, attorney or person to whom you have granted a delegated authority
• service providers engaged to carry out functions on our behalf (e.g. other financial institutions as required, solicitors, software or IT service vendors and auditors/investigators)
• some of these service providers may be located overseas, including in the United States of America, United Kingdom, Hong Kong, Singapore, Japan, Germany and France. Your personal information will only be disclosed to one of our service providers, or stored overseas in accordance with this Policy and applicable laws
• if you have acquired a product through a related body corporate, your personal information may be shared with that related body corporate on a confidential basis
• your financial adviser/consultant who in turn may disclose information to superannuation funds, trustees, insurance providers and product issuers for the purpose of giving effect to your financial plan/strategy and recommendations made by them
• if a financial adviser/consultant has referred you to our products and services then your details (including ongoing investment and transaction details) maybe provided to that financial adviser/consultant, the dealer group, the broker or the organisation for whom they work
• for legal reasons, disclosure may need to be made to law enforcement agencies, regulators, Government agencies, courts or external advisers(e.g. to meet our obligations under the AML Act).

6. Information Security

We have systems and processes in place designed to hold your information securely. Only authorised personnel are granted access your information. We also have in place processes designed to identify you when you deal with us by phone, online or face to face. These processes are designed to ensure we only disclose your information to you, or someone properly authorised by you. You need to keep access details like user names and passwords confidential and not share them or leave them somewhere that is easy for others to access or find.

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7. Website

If you access your account information online through either our website or that of an external service provider (eg. administrator or product issuer) (using a registered user identification), we may collect personal information electronically. For example, we may collect information about your visits by using ‘cookies’. A cookie is a packet of information which is sent by our website to your computer to track your use of our website and to allow you to efficiently access your account information. Generally, we use cookies for security purposes and to assess the usage and improve the functionality of our website.

We use both session cookies and persistent cookies. A session cookie is temporary and is automatically destroyed once your web browser is closed. All of the e-commerce and client service functions of our website rely on session cookies. These web pages will not work if session cookies are explicitly blocked or disabled within a web browser. A persistent cookie is a small text file stored on the user’s computer for an extended period of time. Your web browser can be set to reject cookies. If you reject persistent cookies you will still be able to access our website, but may not be able to use certain features or the web service may not recognise you.

We take care to ensure that the personal information you give us on our website is protected. Talaria uses a range of security measures to help ensure this security. Our website contains links to other sites, which are not subject to our privacy standards policies and procedures. You will need to review those websites directly to ascertain their particular privacy policies and practices.

8. Access and Correction

You have the right to correct your personal information held by us if you believe it to be inaccurate or out of date. We will then amend your records accordingly. If we disagree with the correction, we will advise you of the reasons for doing so and will make a note on your record of this.

You have the right to access your personal information. This can be arranged by calling (03) 86760667 or writing. Your request should include a detailed description of the information required. To ensure information is only disclosed to those entitled to it you may be asked for identification, or in the case of a telephone call asked to answer a series of questions to verify your identity.

If we are unable to provide you with access to your information, we will inform you of the reasons why.

9. Privacy Enquiries and Complaints

If you have an enquiry or complaint about our information handling practices, please contact us by calling (03) 8676 0667 or alternatively write to:

Privacy Officer

Talaria Asset Management Pty Limited

Level 14

330 Collins Street

Melbourne VIC 3000

You can also contact us if you believe that the privacy of your personal information has been compromised or not adequately protected.

It is our intention to resolve any complaint as quickly as possible and to your satisfaction.If you are not satisfied with the response provided by us, please let us know and our Privacy Officer will investigate further and respond to you. If you are still not satisfied or if we do not respond to your complaint within 30 days, you can contact external bodies that deal with privacy complaints such as the Office of the Australian Information Commissioner. This body may forward your complaint to another external dispute resolution body if it considers the complaint would be better handled by that body.

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Telephone: 1300 363 992

Website: www.oaic.gov.au

This Policy is provided for the purposes of information only. While we have taken care to ensure that it is accurate and current, we provide no guarantee as to its accuracy or currency. We accept no liability for loss or damage suffered as a result of reliance on the information provided in this Policy.

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Last Review Date 21 March 2023

Talaria Asset Management Pty Limited ACN 130 534 342