Privacy Policy

Privacy Policy

1. Introduction

This Privacy Policy applies to Steller Property Funds Pty Ltd (SPF) and its subsidiary or associate entities.

SPF is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy sets out how SPF handles personal information.

This Privacy policy does not apply to personal information collected by SPF that is exempted under the Privacy Act, for example employee records.

SPF may amend this Privacy Policy from time to time to reflect its current privacy practises.

In this Privacy Policy, ‘SPF’, ‘we’, ‘us’ and ‘our’ is a reference to SPF and includes any entity carrying on business in Australia that is a subsidiary or division of SPF.

2. Personal information we collect

The types of personal information we collect include:

  • names, titles, contact and address details;
  • information in identification documents (for example, passport, drivers licence);
  • tax file numbers and other government-issued identification numbers;
  • date of birth and gender;
  • bank account details and details of investments;
  • details of superannuation

it may be necessary for SPF to collect sensitive information about you in order to provide specific investments, services or for recruiting purposes (e.g. professional memberships, ethnic origin, criminal record and health information).

3. How we collect and manager personal information

How we collect personal information

We will generally collect your personal information from you directly. Sometimes it may be necessary for us to collect your personal details from a third party such as your personal representative or professional advisor.

We may also collect personal information about you from your use of our websites and information you provide to us through contact mailboxes or through the registration process on our website.

Where you provide us with personal information about someone else

If you provide us with someone else’s personal information, you should only do so if you have their authority or consent to provide us with their personal information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy or any Privacy Collection Statement we give you.

Holding personal information

SPF holds personal information in hard copy and electronic formats. We take security measures to protect the personal information we hold including physical (for example secured premises and storage of files in lockable cabinets) and technology (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates) security measures. We also have document retention policies and processes.

Purpose for collecting, holding, using and disclosing personal information

SPF collects, holds and uses personal information for a number of purposes including:

  • to provide investment products;
  • to provide professional services;
  • to respond to requests or queries;
  • to maintain contact with our clients;
  • to keep our clients informed of our products, performance and developments;
  • to notify of seminars and other events;
  • to verify your identity;
  • for administrative purposes, including processing payment transactions;
  • for recruitment purposes;
  • for purposes relating to the employment of personnel;
  • when engaging service providers, other SPF member companies, contractors or suppliers relating to the operation of our business;
  • to manage any conflict of interest or independence obligations or situations;
  • to conduct surveys;
  • for seeking feedback;
  • to meet regulatory obligations;
  • as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including SPF’s business) or entering into an alliance, joint venture or referral arrangement;
  • to perform internal statistical analysis, including f our databases or websites;
  • for any other business related purposes.

If you do not provide us with the personal information we have requested, we may not be able to complete or fulfil the purpose for which such information was collected, including providing you or our clients with services we were engaged to perform or interests in investments applied for.

The types of third parties to whom we may disclose your personal information include:

  • experts or third parties contracted as part of an engagement;
  • our service providers;
  • our professional advisers;
  • other SPF member companies;
  • as part of an engagement, if you are a customer, an employee, a contractor or supplier of services to one of our clients, then we may disclose your personal information as part of providing services to that client;
  • as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including SPF’s business) or entering into an alliance, joint venture or referral arrangement; or
  • government or regulatory bodies or agencies, as part of an engagement or otherwise, (e.g. the Australian Taxation Office).

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you. However, we may share non personal, de-indentified or aggregated information to them for research or promotional purposes.

Disclosure of personal information overseas

We may store, process or back-up your personal information on servers that are located overseas (including through third party service providers).

In some circumstances, SPF may use third party service providers to carry out its functions. Some of these providers may be located overseas.

4. Direct marketing

SPF may also use your personal information for the purpose of marketing its investment products or services. if you do not want to receive marketing material from us, you can contact us as detailed below:

  • for electronic communications, you can click on the unsubscribe function in the communication; or
  • for hard copy communications, you can email ; or
  • through our contact details below.

5. Privacy on our websites

Cookies and web beacons

Cookies and web beacons may be used on some SPF websites, primarily used to enhance your online experience and to make our sites more user friendly.

Cookies are small text files placed on your computer when you first visit the site. Most browsers now recognise when a cookie is offered and permit you to refuse or accept it. If you are not sure whether your browser has this capacity, you should check with the software manufacturer, your company's technology help desk or your internet service provider.

A web beacon is a clear picture file that is placed on a website or in an email that is used to monitor the behaviour of a user visiting the website or sending an email. When the HTML code for the web beacon points to a site to retrieve the image, at the same time it can pass along information such as an IP address of the computer that retrieved the image, the time the web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookies values.

Your choices

You have several choices regarding your use of SPF websites. In general, you are not required to provide personal information when you visit our websites. However, if you apply to receive information about our products, services, events and updates or wish to apply for employment, provision of certain personal information will generally be required.

Links to third party websites

SPF’s websites may contain links to third parties' websites. Those other websites are not subject to our privacy policy and procedures. You will need to review those websites to view a copy of their privacy policy. SPF does not endorse, approve or recommend the services or products provided on third party websites.

6. Children

We understand the importance of protecting children's privacy, especially in an online environment. In particular, our websites are not intentionally designed for or directed at children under the age of 13. It is our policy to never knowingly collect or maintain information about anyone under the age of 13, except as part of a specific engagement to provide professional services, including investment products, which necessitates such personal information be collected.

7. Gaining access to personal information we hold

You can request access to your personal information, subject to some limited exceptions permitted or required by law. Such request must be made in writing to the Privacy Officer. Please see the 'How to contact us’ section for details.

SPF may change reasonable costs for providing access to your personal information.

8. Keeping personal information current

If you believe that any personal information SPF has collected about you is inaccurate, not up-to- date, incomplete irrelevant or misleading, you may request correction. To do so, please contact the Privacy Officer and we will make reasonable steps to correct it in accordance with the requirements of the Privacy Act. Please see the 'How to contact us' section for details as to how to contact the Privacy Officer.

9. Complaints

If you wish to make a complaint to SPF about our handling of your personal information, you can contact the Privacy Officer as set out in the ‘How to contact us section. You will be asked to set out the details of your complaint in writing in a form provided.

SPF will endeavour to reply to you within 14 days of receipt of the complaint form and, where appropriate, will advise you of the general reasons for the outcome of the complaint. In some circumstances, the Privacy Officer may decline to investigate the matter, for example if the matter relates to an act or practice that is not an interference of the privacy of the person making the complaint. If you are not satisfied with the outcome of your complaint, you can refer our complaint to the Office of the Australian Information Commissioner.

10. How to contact us

If you have a query in relation to this Privacy Policy or you would like to notify SPF that you no longer wish to receive marketing material from us, access or correct your personal information or to make a complaint about SPF's handling of your personal information, please contact SPF as follow:

Compliance Officer
Steller Property Funds
Suite 5, 69 -71 Rosstown Road
Carnegie VIC 3163

Phone: 03 8658 8341