Privacy Policy

Review date: February 2026, version 1

Introduction

We recognise that your privacy is important to you. This policy has been prepared by Kinkora Investment Services Pty Ltd (ACN 607 865 305) to provide you with how we protect your privacy and how we comply with the requirements of the Privacy Act 1988 (Cth) (‘Act’) and the 13 Australian Privacy Principles (‘AAP’). This policy also describes:

  • who we collect information from
  • the types of personal information collected and held by us
  • how this information is collected and held
  • the purposes for which your personal information is collected, held, used and disclosed
  • how you can gain access to your personal information and seek its correction
  • how you may complain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or inquiry will be handled, and
  • whether we are likely to disclose your personal information to any overseas recipients.

What personal information we collect and hold

‘Personal Information’ is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not. Information where we have removed reference to a person, so that person cannot be reasonably identifiable from the information, is not personal information.

The kinds of personal information that we collect and hold from you may include:

  • contact information, such as your name, postal address, telephone number(s) and e-mail address; and
  • any other personal information submitted to us by you.

We will not collect sensitive information about you (such as relating to your ethnic origin, religious or philosophical beliefs, memberships of a political or trade association, or health information). If sensitive information is required, it shall be obtained with your consent.

You have the right to remain anonymous or use a pseudonym when dealing with us, unless:

  • the use of your true identity is a legal requirement; or
  • it is impracticable for us to deal with you on such basis.

How we collect your personal information

We aim to collect personal information from you directly, unless it is unreasonable or impractical for us to do so. For example, we may collect personal information about you from:

  • information you provide to us when you make an enquiry;
  • information derived from direct communications between us and you; and
  • information you submit to us via our website.

In some circumstances, it may be necessary for us to collect personal information through other lawful means such as from third parties or from a source of publicly available information.

If we receive personal information that we have not requested (unsolicited information) and we determine that we could not have collected that information under the APPS if we had requested it, then we will destroy or de-identify the information if it is lawful and reasonable to do so.

How we hold personal information

We will take reasonable steps to keep secure any personal information which we hold.

Your personal information is held and stored on paper, by electronic means, or both. We have physical, electronic and procedural safeguards in place for personal information and take reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorised access, modification and disclosure.

Use of your personal information

We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us in order to provide our services to you, to carry out our business functions or for such other purposes as specified at the time of collection, or for related purposes that you would reasonably expect.

The legal basis we rely upon to legally permit us to process your personal information is:

  • you have given us consent for the processing of your information for the provision of services by us to you; and
  • processing is necessary for compliance with a legal obligation to which we are subject.

Generally, we will only use and disclose your personal information:

  • to provide you with services; or
  • to provide you with such information as requested by you or to answer your enquiries.

We respect the privacy of your personal information and will take reasonable steps to keep it strictly confidential.

We will only disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose that could be reasonably expected.

Where such a disclosure is necessary, we will require that the third party undertake to treat the personal information in accordance with the APPs.

Disclosure of your personal information overseas

We do not disclose your personal information to overseas recipients at this time. We will notify you if circumstances change regarding overseas disclosure and will comply with the Act in all relevant aspects.

Security of your personal information

Access to and use of personal information is appropriately limited to prevent misuse or unlawful disclosure of the information. Where information collected is no longer required, we delete the information or permanently de-identify it.

How we ensure the quality of your personal information

We take all reasonable steps to protect your personal information – ensuring the personal information we hold, use and disclose is accurate, complete and up‑to‑date. These steps include ensuring that the personal information is accurate, complete and up-to-date at the time of collection and when using or disclosing the personal information.

On an ongoing basis we maintain and update personal information when individuals advise us or when we become aware through other means that their personal information has changed.

Please contact us if any of the details you have provided change. You should also contact us if you believe that the information we have about you is not accurate, complete or up-to-date.

How to gain access to your personal information we hold

Under the APPs, you may request access to the personal information we hold about you, or request that we change the personal information, by contacting us which we may need to verify your identity. In the case of access and correction requests, please provide as much detail as you can about the particular information you seek, in order to help us locate it.

We will provide the reasons if your request for access to or correction of personal information is denied. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.

Website

When you visit our website

We not directly collect information from users of the website. Your email address will not be recorded unless you send us a message. It will not be automatically added to a mailing list.

We do not try to identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the service provider’s logs.

Where you contact us, we may store information such as your name, company, postal address, telephone number, type of request and possible further information to enable us to respond to your request. We will only use such personal information for the purpose for which it has been provided.

We will not provide your information to any organisation outside our corporate group.

Cookies

As is very common for companies, we use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. We use cookies to improve the experience of people using our website. You can configure your web browser to reject cookies, but you then may not be able to use all or part of our website.

Privacy complaints

If you wish to make a complaint about a breach by us of the APPs, you may do so by providing your written complaint by email, letter, or by personal delivery to any one of our contact details as noted below. You may also make a complaint verbally. Where you express any concerns that it has interfered with your privacy, we will respond to let you know who will be handling your matter and when you can expect a further response.

We will respond to your complaint within a reasonable time (usually no longer than 20 days after receipt of the complaint). We may seek further information from you in order to provide a full and complete response.

If you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner who may investigate your complaint further.

Changes to privacy policy

Please be aware that we may change this Privacy Policy in the future. The revised versions will be uploaded onto our website, so please check back from time to time.

Our contact details

You can contact us about this Privacy Policy or about your personal information by contacting:

Privacy Compliance Officer
Kinkora Investment Services
GPO Box 2985, Melbourne, VIC, 3001
Email: privacy@kinkorainvestments.com.au
Telephone: +61 3 8623 3333

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to:

Complaints Officer
Kinkora Investment Services GPO Box 2985, Melbourne, VIC, 3001
Email: compliance@kinkorainvestments.com.au
Telephone: +61 3 8623 3333