Lumen Investment Management Pty Ltd (“Lumenary”) is committed to protecting your privacy and maintains a policy of strict confidence concerning any personal information you provide to us.

Our commitment to privacy

This Privacy Policy relates to Lumen Investment Management Pty Ltd and its related bodies corporate (“Lumenary”, “we”, “us” and “our”).

We hold your privacy with the utmost importance. We are bound by the Privacy Act 1988 (Cth).

This Privacy Policy outlines the type of personal information we collect, how that information is collected, used, stored and protected, and to whom we may disclose your personal information.

Personal information we collect

Any information that identifies you is deemed to be personal information. We primarily collect this information through our standard forms (for example, application forms) and when you contact us.

The type of personal information Lumenary collects from you includes – your name, contact details (such as your address and telephone number), date of birth, individual investment details, bank account information and tax file number. The Corporations Act 2001 (Cth) requires us to collect your name, address and date of birth. The Government’s anti-money laundering laws may also mandate us to collect proof of personal information from you.

If you do not provide personal information to us, we may not be able to provide you with the services or information you require.

When browsing our website Lumenary’s webservers automatically collect standard information as part of the HTTP web protocol – your IP address, browser type, operating system, access times, referring sites, pages viewed and other anonymous information.

Cookies are a small simple text file placed on your computer by a website. We use cookies to collect statistical usage information to enable us to improve our websites. These cookies cannot be used to personally identify you.

How we use personal information

Lumenary uses your personal information to administer your investment, comply with relevant laws and regulations and communicate with you on an ongoing basis about your investment and the market. You may contact us at any time to ask us not to send you this information.

Lumenary may use information that you provide through our website or over the phone for analysis to improve our products and services.

We may also use your personal information to prevent fraud, crime or other activity that may cause harm in relation to our products or services and to help us run our business.

In some circumstances Lumenary may disclose your personal information to persons/entities outside of Lumenary, including:

• to agents, contractors and external service providers who help us provide our services to you (such as our auditors);
• to governmental or regulatory bodies or agencies (such as ASIC, ATO, AUSTRAC or a law enforcement agency), in connection with their information requests or to meet our legal and/or regulatory obligations in any relevant jurisdiction, or for the purposes of processing tax reclaims for our funds. Some of these recipients may be located outside of Australia; and/or
• as required or authorised by law, regulation or by a court order.

Lumenary takes steps to ensure that our agents and third parties keep your personal information confidential and use it only for the purposes for which they, and Lumenary, are authorised. You may also authorise us to disclose information we hold about you to your financial adviser, administrator or other person nominated by you.

Personal information security

Lumenary regards the security of your personal information as a priority and has a number of physical and electronic protection measures in place.

No personal data is stored on our public website. Personal data is stored separately on a secure server.

Access to your personal information

You can request access to personal information we hold about you at any time. We endeavour to keep the information you supply us accurate and up to date. If you feel the information we hold about you is incorrect please contact us and we will amend your details immediately.