Privacy Policy

About this Policy

Sturt Capital Partners Pty Limited (ACN 138 346 755) and its related bodies corporate, including Sturt Capital Pty Limited (ACN 142 685 827) (AFSL 362429), (“Sturt Capital”, “we’, “us” and “our”) are committed to providing quality services to you and this policy outlines how the collection, storage, use and disclosure of your personal information is carried out by Sturt Capital. Sturt Capital is bound by the Privacy Act 1988 (Cth) (“Act”) and the Australian Privacy Principles (“APPs”) established under the Act. Information about the Act and the APPs is available by contacting our office. Our contact details are provided at the end of this document.

About Us

Sturt Capital Pty Ltd (ACN 142 685 827) holds Australian Financial Services Licence No. 362429 and is licensed to provide specific financial services including corporate advisory, dealing and funds management.

Information Collection

As a financial services organisation, we are subject to legislative and regulatory requirements governing how we obtain and hold the personal information of our clients. Information we hold about you may include things such as your contact details, date of birth, bank account details and tax file numbers plus information to identify you so that we can comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”). The information we collect may extend to members of your family or beneficiaries of trusts if they are officers, shareholders or beneficiaries of a client of Sturt Capital. Unless we are required to comply with the law, we will not collect any personal information about you unless you have knowingly provided that information to us or authorised a third party to provide that information to us (for example, to your financial advisor or custodian).

Information Use and Disclosure

We will not use or disclose personal information collected by us for any purpose other than:

1. the purposes for which it was provided or obtained or a related secondary purpose where you would reasonably expect us to use or disclose the information; or
2. where you have consented to such disclosure; or
3. where required or authorised under law or court order (for example, to regulatory bodies such as ASIC, ATO or AUSTRAC).

Information may also be accessed by our agents, third party service providers and advisors including our auditors and lawyers where this is necessary for the provision of products to you and for the operation of Sturt Capital’s business. Those parties are subject to obligations of confidentiality and authorised to only use the information to perform the functions required by Sturt Capital. If you choose to invest in a fund or scheme managed by us, your information may be used to:

1. Advise the Australian Tax Office (ATO) of your tax file number. If you choose not to provide us with your tax file number, tax may be deducted from any distributions payable to you at the highest marginal tax rate.
2. Enter your details on the register of the members of the fund or scheme, which is available for inspection in accordance with the Corporations Act.
3. Communicate with you about your investment.
4. Make deposits of distributions to your nominated bank account.
5. Provide details to financial advisors, mortgage providers and your bank in accordance with your express authority.
6. Conduct mandatory checks under AML/CTF Act and undertake the required reporting to AUSTRAC.

We may use the personal information collected from you for the purpose of providing you with updates or general information (such as research and market updates) that may be of interest to you. You may request not to receive such information. Sturt Capital does not report your personal information to credit agencies.

Document Storage and Security

Your personal information is generally held in computer storage facilities (located in-house or with our service providers) or in files located at our offices. We take reasonable steps to ensure that your personal information is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential. All computer-based information is protected through the use of access passwords and data is backed up each evening and stored securely. We also have firewalls and anti-virus technology to prevent unauthorised access. All physical files are held in secure premises and access is restricted to approved staff. If you cease to be a Sturt Capital client, your personal information will continue to be maintained securely in order to comply with legislative and professional requirements, currently for a minimum period of seven years.

Gaining Access to your Personal Information

You may request access to your personal information at any time but we will require you to provide evidence of your identity in order to provide such access. We will provide you with access to information by either providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information we hold. The APPs place certain restrictions on accessing your personal information. Restrictions include where unlawful activity is suspected or enforcement action is being conducted, where provision of access would pose a serious threat to public health or safety or is unlawful or likely to prejudice a criminal investigation. In addition, we will not provide you access to personal information which would reveal any confidential formulae or the detail of any proprietary process, but may instead provide you with the result of such process and/or an explanation of that result. If we decline your request for access, we will provide you with an explanation for that refusal and you will have an opportunity to lodge a privacy complaint (see below). We will take reasonable steps so that, at all times, the personal information we hold about you is accurate and up to date and will correct the information if you request us to do so.

How a Privacy Complaint may be Made

We are committed to providing you with a fair and responsible system for handling privacy complaints. If at any time you have any complaints in relation to privacy, please contact our Privacy Officer at one of the contact points referred to below. We will try to resolve any concerns you may have to your satisfaction within ten days, however if you are unhappy with our response, you are entitled to contact the Australian Privacy Commissioner who may investigate your complaint further.

The Sturt Website and the Internet

Your use of the Sturt Capital website may be monitored, tracked and recorded. Our web server may automatically record your IP address, the website from which you visit us, the type of browser software used and the web pages you actually visit including date and duration. Anyone using the website expressly consents to such monitoring, tracking or recording. A cookie is a small text file placed on your computer hard drive by a web page server. Cookies may be accessed later by our web server. If you do not wish to accept cookies from Sturt Capital you may configure your browser not to accept cookies. The Internet is generally not regarded as a secure environment and information sent via the Internet can be accessed by unauthorised third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the Internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than exists in your country of residence. We accept no responsibility or liability for the security of your information whilst in transit over the Internet to or from Sturt Capital.

OUR CONTACT DETAILS

The Privacy Officer
Suite 7.02, 60 Carrington St
Sydney NSW 2000
Telephone: 02 9025 9533
Email: admin@sturtcapital.com.au

Additional information about privacy in Australia may be obtained by visiting the web site of the Australian Privacy Commissioner at www.privacy.gov.au.