Sterling Managed Investments Pty Ltd  is committed to protecting your personal information.

Sterling Managed Investments Pty Ltd  ABN 85 138 834 590 , AFS Licence Number 340744 is subject to the requirements of the Australian Privacy Principles and the Australian Privacy Act 1988.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Policy; so please check our website for updates from time to time. If there are important changes to how we handle your personal information; we may contact you to let you know.

Our Cookie Policy forms part of our Privacy Policy. When you browse our websites we use cookies to store information about how you use these websites in order to improve the quality of service provided to you. To understand what type of cookies we use and how these work when you use our websites you can access our Cookie Policy on our website

1. Information we collect and use

Information about you that we collect and use includes:

• Information about who you are e.g. your name, date of birth and contact details
• Information connected to your product or service with us e.g. your bank account details
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information that is automatically collected e.g. via cookies when you visit one of our websites
• Information classified as ‘sensitive’ personal information e.g. relating to your health
• Children are not able to buy products and services from us. However, on instruction from a parent or guardian, a child can also be named as a beneficiary on some funds and trusts. In these cases, we collect limited personal information to identify the child (such as their name, age, gender).

Where we collect and use sensitive personal information, this information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information.

2. Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

• An application form for a product or service
• Phone conversations with us
• Emails or letters you send to us
• Meetings with one of our business development or relationship managers
• Registering for one of our events
• Participating in research surveys to help us understand you better and improve our products and services
• Our online services such as websites, social media and mobile device applications (‘Apps’)We may also collect personal information about you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.
• If you have a financial adviser, the information we collect and use will most likely have been provided by them on your behalf.

3. Why we collect and use your information

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only if we are able to satisfy one of the lawful processing conditions set out in the data protection laws. This will be the case where:

• it’s necessary to provide the product or service you have requested e.g. if you wish to invest in one of our funds or products we will require some personal information which may include your name, address, date of birth, and bank account details
• it’s necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud
• it’s in the legitimate interests of Sterling Managed Investments Pty Ltd e. to deliver appropriate information and guidance so you are aware of the options that may help you get the best outcome from your product or investment; where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services. Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be
• you have given us your permission [consent] to use your information in this way. For example, if we are collecting and using your sensitive personal information or for certain types of direct marketing

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

4. Marketing and Analytics

Where you have given your permission to do so (or when given the opportunity have not objected), we will send you information from Sterling Managed Investments Pty Ltd  about products and services offered by Sterling Managed Investments Pty Ltd , Even though the materials may refer to the third party, we (and not the third party) will send you the information about such events and sponsorship activities. These are parties we have chosen to work whose products or services we believe may be of interest and benefit to you.

You can withdraw your consent or manage your preferences by contacting us (see how to contact us)

We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we offer you now or in the future. We use automated decisions in the following ways:

• Tailoring products and services e.g. placing you in groups with similar customers to make decisions about the products and services we may offer you to help meet your needs
• When designing and enhancing our online services to help meet your requirements for ongoing guidance and support

5. Who we share your information with and why We may share your information internally, and with third parties for the reasons outlined in ‘Why we collect and use your information’.

We will share your information with:

• Other parts of the Sterling Managed Investments Pty Ltd who support us in the provision of the product or service you have
• Credit reference agencies for the purposes of conducting a credit check and ID verification
• Your adviser, trustee, business associate, professional advisor where this is required as part of the product or service you have agreed with us
• Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers. For example, research, consultancy or technology companies who help us improve our service to you
• Companies who can help us in our contact with you, for example an internet service provider
• Our regulators;
• Law enforcement and other appointed agencies who support us (or where they request the information) in the prevention and detection of crime; and for the purposes of tax reporting where necessary.

6. Where your information is processed

The majority of your information is processed in Australia. However, some of your information may be processed by us or the third parties we work with offshore, including countries such as the United Kingdom, United States, Singapore, and Malaysia. Where your information is being processed outside of Australia, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by the Australian data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.

7. How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

8. How long we keep your information

To provide your product or investment, and meet our legal and regulatory obligations, we keep your personal information and copies of records we create (e.g. calls with us) while you are a client or customer of ours.

Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we regularly review our retention periods to make sure they comply with all laws and regulations.

9. Your rights

You have a number of rights under data protection laws which may be exercised in certain circumstances. These are:

• the right to be informed about how and why we are processing your personal information
• the right of access to personal information relating to you
• the right to rectification of inaccurate or incomplete personal information
• the right to request erasure of your personal information
• the right to restrict processing of your personal information
• the right to data portability
• the right to object to processing of your personal information (e.g. profiling or direct marketing)
• the right not to be subject to automated decision making (including profiling) which significantly or legally affects you

For more information on your rights and how to exercise them please contact us (see ‘How to contact us’ section).

10. Complaints

If you have a complaint relating to the Policy or a breach of the Australian Privacy Principles you can contact us.

Address: Complaints Handling Officer/Client Service Manager

Sterling Managed Investments
GPO Box 4000
Brisbane Qld 4001

Telephone: 07 3018 0400
Email: info@sterlingmi.com.au

Sterling Managed Investments Pty Ltd  has a Complaints Handling Officer who is responsible for ensuring that complaints are dealt with appropriately and in accordance with our complaints handling process. When a complaint is received we acknowledge and record the details in our Complaints Register. We review the merits of the complaint, determine appropriate action to address the concern and keep you informed of our progress. Our aim is to resolve a complaint as quickly as possible and provide a final response to you within 45 days.

If, despite our best efforts, you are not satisfied with the outcome or believe your complaint has not been satisfactorily dealt with you may wish to contact the Office of the Australian Information Commissioner. Their contact details are:

Address: GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au

11. Questions

If you have any questions relating to the Policy or how we use the personal information we have about you, please contact our Client Services team by phone on 07 3018 0400