This policy governs the handling of all personal information in the possession of UBS Asset Management (Australia) Ltd (UBS AM Australia, we/us/our), an Australian business operating within the UBS Asset Management business division of UBS AG. UBS AG is incorporated in Switzerland and is the ultimate parent of UBS AM Australia and its related bodies corporate (collectively referred to in this policy as the 'UBS AG Group').
1. What personal information does UBS AM Australia collect?
The term personal information, as used in this policy, is as defined in the Privacy Act 1988 (Cth) (Privacy Act). The types of personal information that we may collect and hold will include information used to identify you, your financial position and any other related information necessary or incidental to the financial products and services which we provide or propose to provide to you. This may include but is not limited to your:
- Contact details
- Tax File Number, exemption reason or country of residence
- Bank account information
- Investment information
- Employment information
- Identification information
- Organisational affiliations and positions held
- Details of your interactions with us and our products and services (including from our records of any telephone, email and online interactions).
UBS AM Australia will collect personal information about you through various means including your use of a UBS AM Australia website or in your dealings with us. In some circumstances, UBS AM Australia may gather information about you from a third party. These include credit agencies, financial advisers, fund managers or intermediaries, and spouses.
2. Why UBS AM Australia collects personal information
The personal information that you provide will enable UBS AM Australia to perform its functions or activities, including to identify you, your financial position and any other related information necessary or incidental to the financial products and services which we provide to you. If you do not provide any or all of the information we request, we may not be able to provide you with the products and services you seek.
3. How will UBS AM Australia use your personal information
The purposes for which UBS AM Australia will use your personal information will depend upon the relationship that you have with UBS AM Australia. In most instances your personal information will be collected, used and disclosed to:
- provide you with a financial or related product or service;
- monitor the quality of the product or service that we provide to you and our clients;
- administer, improve and further the services we provide our clients;
- administer our client relationships;
- offer you further products and services, which may include using your personal information for marketing to you on an ongoing basis by telephone, electronic messages (eg. email), online and other means (in which case we will give you the opportunity to request that your personal information not be used for future direct marketing); and/or
- comply with legal and regulatory requirements including the Corporations Act 2001 (Cth), the Proceeds of Crime Act 1987 (Cth), the Financial Transaction Reports Act 1988 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the rules of relevant stock exchanges (such as the Australian Stock Exchange).
We will also be entitled to use your personal information for any purpose which is related to the purpose for which your personal information was originally provided by you.
UBS AM Australia may also use your personal information to facilitate any potential or actual acquisition of an interest in any part of our business or our parent companies and for other purposes with your consent or where required or authorised by law.
4. Storage of your personal information
Your personal information will be held in writing, electronically or both, either at our own premises or with the assistance of our service providers. We have security measures in place which are intended to protect your personal information that we hold from misuse, interference and loss, and from unauthorised access, modification of disclosure.
5. Disclosure of personal information to third parties
You acknowledge and agree that your personal information may be exchanged with any of the following third parties:
- Any regulatory or legal body which governs the conduct of any part of UBS AM Australia’s business. We may need to disclose your personal information to regulatory bodies such as, but not limited to, the Australian Securities and Investments Commission, tax authorities and relevant stock exchanges.
- Other companies that form part of the UBS AG Group, whether in Australia or any overseas jurisdiction (see clause 6).
- A third party who is supplying a service to UBS AM Australia or another member of the UBS AG Group, whether in Australia or an overseas jurisdiction. A UBS AG Group company may provide your personal information to third parties such as information technology maintenance companies, software providers, share registries and providers of administration, custody, investment management, identity verification, auditing, mailing or printing services.
- Other third parties with your consent.
6. As otherwise permitted by law. Disclosure of personal information to related bodies corporate and third parties outside Australia
You acknowledge and agree that if you supply your personal information to UBS AM Australia, this personal information may be transferred between related bodies corporate or to third parties who supply services to us or our related bodies corporate. These related bodies corporate and third parties to which your personal information may be transferred may be located throughout the world (including but not limited to China Mainland, Hong Kong SAR, India, New Zealand, Poland, Singapore, Switzerland, United Kingdom, and United States of America) and be registered and governed by laws outside the Australian jurisdiction. As such, the laws regulating a related body corporate may differ to Australian laws and may apply a greater or lesser standard of protection for your personal information.
The UBS AG Group has policies in place that are designed to adequately protect your personal information in accordance with applicable laws. Should your personal information be transferred to a jurisdiction with inadequate privacy protection, we will take reasonable steps to ensure that the relevant overseas recipient does not breach the Australian Privacy Principles set out in the Privacy Act in relation to such personal information.
7. UBS AM Australia websites
8. Sensitive Information
In many cases UBS AM Australia will not collect your sensitive personal information. The Privacy Act 1988 (Cth) defines sensitive personal information as information about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, genetics, biometric details or health information. We will only collect sensitive personal information about you with your consent or as otherwise permitted by law. You have consented to such collection in accordance with this policy.
This policy does not apply in respect of acts and practices of UBS AM Australia which are directly related to an employee record of a current or former employee.
10. Accessing and updating your personal information / contact details
Should you wish to know what personal information UBS AM Australia holds about you, you may request to view this personal information by contacting our dedicated Privacy Officer:
We may ask to verify your identity and may charge a reasonable fee for access to this personal information. Should you discover that any personal information is outdated, incorrect or incomplete you may request to have the personal information corrected.
You may also contact the relevant Privacy Officer if you have any questions on our compliance with the Privacy Act or if you wish to make a complaint about our handling of your personal information. Your complaint should first be made in writing to the Privacy Officer at the address above, as required by the Privacy Act.
If you are not satisfied with our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner as follows:
1300 363 992
GPO Box 5218
This policy was approved by the UBS Asset Management (Australia) Ltd Board on 14 December 2018.