Privacy Policy


ALL INFORMATION COLLECTED FROM YOU IS COLLECTED AND STORED IN THE UNITED STATES, AND IS SUBJECT TO UNITED STATES LAW WITH RESPECT TO USE, PROCESSING AND TRANSFER.

General

We respect your privacy and understands that your privacy is important to you. This privacy policy summarizes how we collect, store, use and disclose your personal information.  If you have any questions regarding this privacy policy, you should contact us in any of the ways specified under "Contact us", below.

Revisions to this Privacy Policy

We reserve the right to change this privacy policy at any time by posting an updated version of the policy on the Site. You should visit this page periodically to review the privacy policy for changes.

Safeguarding your personal information

We take precautions to maintain the privacy of your personal information and other information and or data collected by us. These precautions include the adoption of certain physical, technical and/or administrative procedures designed to reduce the risk of loss, misuse unauthorised access, disclosure and alteration.  third parties. Certain laws and regulations require us to inform you of this privacy policy.  NO SECURITY IS PERFECT, AND WE DO NOT GUARANTEE IN ANY WAY THAT A SECURITY BREACH WILL NOT OCCUR, WHETHER THE DATA IS BEING TRANSMITTED OR STORED, NOR THAT YOUR PERSONAL INFORMATION OR ANY OTHER INFORMATION OR DATA IS FULLY PROTECTED FROM UNAUTHORISED DISCLOSURE OR USE.

Collecting your personal information

"Personal information" is information or an opinion, whether true or not and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable. Your provision of such information is entirely voluntary. However, please note that if you decline to provide such information when prompted, you may not be able to take advantage of certain features or certain areas of the Sites.

We will only collect personal information about you if you provide it to us knowingly or otherwise in accordance with this policy, including, but not limited to:

  • Information we receive from you in subscription documents or other related documents or forms, or through a Site; and/or
    • Information about your transactions with us, our funds, affiliates, or others; and/or

We may also obtain information about you from a third party including, but not limited to, from:

  • from a consumer reporting agency
  • our related entities;
  • the responsible entity or administrator of a managed investment scheme for which we provide services (Fund); and
  • regulatory or government authorities, industry bodies or professional associations.

We collect your personal information to allow us to conduct our business functions and to market and sell our products and services, as well as the specific purposes for which we collect your personal information set out in the section entitled “Using your personal information" below.

When you visit our Sites, request information about us or our products, or otherwise contact us (via a Site or otherwise), we may collect personal information about you including (but not limited to) your full name, email address, telephone number, residential address, date of birth, tax file number or other similar information. We are authorised to collect tax file numbers by the Income Tax Assessment Act 1936 (Cth). It is not compulsory for you to provide your tax file number for our products and services, but if you do not, taxation law may require additional deductions to be made from amounts payable to you.  We may also keep a record of visits to our sites using cookies (see the section entitled “Cookies” below) or “log files”.

Links to third party websites

The Sites may contain links to other websites. We are not responsible for the privacy policies of such sites. We recommend that you examine the privacy policy for all third party websites you visit to understand their procedures for collecting, using and disclosing personal information.

Using your personal information

We collect personal information about you to:

  • communicate with you and assist us in the provision of products and services to you;
  • assist you by providing you with information and support, and managing and administering any account you may hold with us or with a fund;
  • conduct anti money laundering related identity and background checks where you or your related organisation are applying for our products or services;
  • administer our website and make enhancements to our website in order to improve the users experience;
  • keep you up to date with events, products and services that may be of interest to you;
  • help us research the needs of our customers and to market our products and services with a better understanding of your needs and the needs of customers generally;
  • conduct research for the purposes of improving existing products or services or creating new products or services;
  • comply with legal and regulatory obligations (e.g. to ASIC, ATO, AUSTRAC or the courts);
  • for other purposes required or authorised by law, including other purposes for which you have provided your consent;
  •  process any job application submitted by you; and
  • allow us to provide advertising material to you regarding us and our related entities.

We also collect personal information about individual financial advisers from industry bodies and financial planning dealer groups for the purposes of identifying advisers who may be interested in our products and services. We may also collect personal information about individuals who are not our customers themselves but are individual employees of a customer with whom we deal.

You consent to us using your personal information in the above ways.  We may also collect and use your personal information for other purposes not listed above.  If we do so, we will make it known to you at the time we collect such information.

We will not use personal information provided by you to us in a manner inconsistent with the Privacy Act 1988 (Cth), the National Privacy Principles (or, after 12 March 2014, the Australian Privacy Principles) or any other relevant laws or guidelines.

Disclosing your personal information

We may provide your personal information on a confidential basis to third parties in the course of delivering our products and services to you and to achieve the purposes specified in "Using your personal information", above. These parties may include our related entities, a responsible entity or administrator of a Fund, regulatory or government authorities, your authorised representatives on your account, and representatives, agents or contractors (“Service Providers”) who are engaged by us in the ordinary operation of our business to assist us in providing our products or services or administering our business (such as responsible entities, fund administrators and IT Service Providers). We may also disclose your personal information to our Site hosts or IT Service Providers in certain limited circumstances, for example when s Site experiences a technical problem or to ensure that it operates in an effective and secure manner.

Generally, we'll only disclose your personal information to these parties:

  • for the purposes set out in this privacy policy (please refer to “Using your personal information”) or any agreement you enter into with us;
  • if we deem it reasonably necessary to protect our rights or property, our clients, investors in the funds we advise, the Sites or other Site users (for example in response to a denial of service attack or the introduction of malicious software to any Site);
  • in circumstances permitted by the National Privacy Principles (and, from 12 March 2014, the Australian Privacy Principles);
  • if we are otherwise required or authorised by law or regulation, including without limitation the National Privacy Principles (and, from 12 March 2014, the Australian Privacy Principles) under the Privacy Act 1988 (Cth); or
  • if the disclosure is made with your consent. 

We will not sell, rent or lease your personal information to any other party.

Overseas disclosures

Some of your personal information may be disclosed, processed or stored overseas by us, our related entities or by our Service Providers.  In particular, as at the date this privacy policy was most recently updated, your personal information will be collected and disclosed to recipients in The United States of America, The Republic of Ireland, the Cayman Islands and other countries from time to time.  This may happen if our related entities are overseas, if our Service Providers are located overseas, or if transactions, information, services or products have an overseas connection.  Where such parties are located overseas, you may have rights to enforce such parties' compliance with applicable data protection laws, but you may not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information. 

You agree to the disclosure and use of such personal information in accordance with this privacy policy, and consent to its disclosure overseas and its use by third parties, including our related entities and Service Providers, in The United States of America, The Republic of Ireland, the Cayman Islands and such other countries in which those parties or their computer systems may be located from time to time, where it may be used solely for the purposes described in this privacy policy, without us being responsible for such use (or for any breach).

Marketing

You consent to our using your personal information for marketing purposes, including sending you information about our and our business partners’ products, services, events and research, as well as responding to requests for information, whether by means of direct mail, telemarketing or email. In connection with that use, we may use software and systems that allow us to view and analyze whether email addresses are active, individual responses to correspondence, viewing of messages, and other data points and analytic information.  You should also be aware that the level of protection in relation to the storage, processing and use of personal information may not be the same in countries outside your own.

Tracking

The Sites do not currently recognize automated web browser tracking method signals, such as “do not track” instructions. You can change your privacy preferences regarding the use of cookies and other technologies through your browser, including blocking all cookies; however blocking all cookies may affect your use of our Sites and other websites and services online, and may prevent you from using all the features and elements of our Sites and other websites and services.

Cookies

We may keep a record of visits to the Sites using “cookies,” which are small text files that are stored on your computer that retain your information and preferences relative to your activities on a website. They are meant to enhance your experience on the Sites, and are used primarily to recognize registered users who are logged on.  For example, if you tell us to, we will send a cookie to your machine that remembers your login credentials to the Sites, so you don’t have to enter them every time you access the Sites. This information is collected automatically whenever you access a Site.

Should you wish to prevent your computer from accepting cookies from the Sites, you can change the settings on your web browser to either block cookies sent from the Site, or to disable cookies altogether. Please note that the Sites may not function properly, or may function differently, if you choose not to accept cookies.

Accessing and updating your personal information

You are entitled to access personal information that we hold about you.  If you request access to your personal information, in ordinary circumstances we will give you full access.  However, there may be some legal or administrative reasons to deny access.  If we refuse your request to access your personal information, we will provide you with reasons for the refusal unless it is unreasonable to do so.

In order to access and update your personal information or opt out of receiving certain communications from us, you may edit your information using the log-in name and password described under “Registered Access” in the Terms of Use.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request amendment of it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

Contact us

If you would like to access the personal information that we hold about you, have a complaint or would like further information about our privacy policy, you can contact us by:

  1. Email at: IT@aqr.com
  2. Calling AQR Australia on 1800 778 019 in Australia or +612 8023 6500

We will investigate your queries and complaints within a reasonable period of time and will notify you of the outcome of our investigation.

Last updated: June 20, 2014