UAL PRIVACY POLICY

Last Reviewed: January 2016

United Almonds Limited (UAL) will always respect the privacy of those persons that invest in our Projects.  
 

Type of Information Gathered

The information that is gathered from Investors is of a general nature and is used for administering and managing their investments and for complying with Australian laws.   It is usually collected directly from Investors or their Advisers via application forms, email messages, letters and telephone calls.  Such information includes names of and contact details for Investors and their Advisers, and investor details relating to date of birth, tax file numbers, copies of Power of Attorneys and correspondence between Investors, Advisors and UAL.

Almond Investors Finance Pty Ltd, a wholly owned subsidiary of UAL, may also collect information from investors that apply for a loan to finance their investment in a UAL Project.  Such information would include a potential investor’s annual income and other financial details, place of work, credit history etc. 

We do not collect sensitive information about Investors 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
  • health information.

There may be some situations where we need to source personal information from an external party e.g. credit reporting agency or a government agency.

We generally hold personal information relating to:

  • the products and services we provide or have provided to Investors
  • Investors’ financial interests and sometimes their financial position, if you are a customer or potential customer of ours
  • an Investor’s name, contact details and identification information
  • records of our interactions with Investors, including details of any enquiries or complaints.

A copy of the Privacy Act 1988 (Cth) (“Act”) is maintained in the office.  UAL must comply with the Act and in particular the National Privacy Principles.  Each Product Disclosure Statement and Financial Services Guide must contain privacy disclosure in accordance with the Act.
 

Anti-money laundering

UAL is required to collect certain customer identification information and verify that information in compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 ("AML/CTF Act") and AML/CTF Rules before it can issue Units or Allotments to the applicant.

Customer identification information may include detailed know your customer ("KYC") information in relation to the applicant such as:

  • for an individual applicant: name, address, and date of birth;
  • for an applicant that is a business entity: details of directors and beneficial owners; and
  • for an applicant that is a trustee: details of the trust and beneficiaries.

UAL may require further KYC information such as information concerning business activities, structure and source of funds of applicants and from time to time may require an investor to provide updated or additional information.

The information that must be collected and the material must be provided to verify that information is set out in the Project’s Application Form.

UAL may refuse an application or decline to issue Units or Allotments to an application until it has satisfactorily concluded a customer identification procedure in relation to the applicant.  Further, UAL may delay or refuse any request or transaction, including suspending the issue or redemption of Units or Allotments in the Project if UAL is concerned that the request or transaction may cause UAL to contravene the AML/CTF Act.  UAL will incur no liability to the applicant if it does so.
 

Security of Information

The electronic and hard copy information that we have gathered is confidential and secure. Our electronic files are protected by personal User IDs and passwords and our hard copy files are stored in lockable filing cabinets.  No one can enter our office premises after business hours without a security pass.   

Where the personal information we collect is no longer required, we delete the information or permanently de-identify it.
 

Destruction of Information

We will destroy personal information if it is no longer needed for the purpose for which we collected it or for the purposes of meeting legal requirements.  All hard copy information will be shredded and all electronic information will be deleted from our systems.    
 

Disclosure and use of Information

We only use and disclose personal information about Investors for the purpose for which it was disclosed to us or related purposes which would reasonably be expected without permission. For example, we may use and disclose personal information to process applications, administer and manage our products and services including monitoring, auditing, and evaluating those products and services, model and test data, communicate with Investors and deal with any complaints or enquiries. We may also use and disclose personal information in connection with acquisitions or potential acquisitions of our business.

We do not sell personal information to other organisations to allow them to do this.

We may share personal information inside and outside the UAL group of companies:

  • as required by applicable laws or rules, such as those relating to Anti-Money Laundering and Counter-Terrorism Financing;
  • to service providers in, or outside of, Australia who provide services in connection with our products and including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, information broking, research, investigation, insurance, identity verification, website and technology services;
  • to your Adviser or dealer group with your permission.

 

Direct Marketing

UAL does not currently engage in direct marketing campaigns.  However, if our current policy were to change, Investors would have the chance to “opt out” of receiving direct marketing material.   Those that do would have their names removed from the mailing list.   UAL would never disclose its mailing list to any other organisation. 
 

How you can access or correct your information

Investors can contact us as set out below to request access to or correction of their personal information. In normal circumstances we will give full access or make the requested corrections to the relevant information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why.
 

UAL Contact Details

For questions regarding our privacy policy or handling of information, please direct enquiries using the contact details below. Where an Investor contacts us seeking resolution of any concerns that we have interfered with the Investor’s privacy, we will respond to advise who will be handling the matter and when the Investor can expect a further response. For information about privacy generally, or if concerns are not resolved to the Investor’s satisfaction, Investors may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.

 

The Privacy Officer

United Almonds Limited
Level 11, 470 Collins Street, Melbourne VIC 3000

Tel: (03) 9629 2777
Fax: (03) 9629 1944
Email: Melbourne@unitedalmonds.com.au