Who Are We?

‘We’, ‘us’ and ‘our’ refer to PortNordica Limited or simply “PortNordica”, ABN: 87 109 872 228, AFSL: 288298

Located at Suite 9.03, Level 9, 56 Pitt Street, Sydney NSW 2000

Our Commitment to Protect Your Privacy

We understand how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of personal information we hold about you and what we do with that information.

We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.

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 attached to Investment Memorandum statements issued by us), information you provide through our website, and when you phone or contact our staff.

The type of personal information PortNordica 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 additional personal information from you.

Phone calls to our Investor Services staff may be recorded or monitored for quality control, training, regulatory or other compliance reasons.

If you do not provide personal information to us, we may not be able to provide you with the services or information you require. In most cases, we will collect your personal information directly from you. In some cases, we may also collect your personal information from a third party such as a financial planner.

When browsing our website PortNordica’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. Generally, personal information is collected on our websites when you login, complete a form or perform a transaction.

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. Session cookies are also used when you login to our website to manage your security and enhance your user experience.

Website analytics measurement software is used to assist in tracking traffic patterns to and from our websites, anonymously surveying users of the sites. The system is used to collect such information as the number of unique visitors, how long these visitors spend on the website when they do visit, and common entry and exit points into and from the website.

This non-personal information is collected and aggregated by third party software and provided to us to assist in our analysis of our websites You cannot be identified personally from this information and no personal information is stored about you.

How We Use Personal Information

PortNordica 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. We may also send you educational and marketing material about our other products and services we offer – you may contact us at any time to ask us not to send this information.

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

Staff may also use personal information to verify your identity over the phone.

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 PortNordica may disclose your personal information to persons/entities outside of PortNordica, including:

• to agents, contractors and external service providers who help us provide our services to you (such as our registry provider, custodian, mailing houses, printing companies, information technology service providers and external consultants) and to auditors and professional advisors;
• to governmental or regulatory bodies or agencies (such as ASIC, ATO, AUSTRAC or a law enforcement agency) and to stock exchanges, 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.

PortNordica may disclose your personal information to agents, contractors and external service providers in the following offshore locations: India, China, United States of America.

PortNordica 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 PortNordica, 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.

Exemptions Note – PortNordica intends to rely on some of the exemptions permitted under the Privacy Act. For instance, the exemption for disclosing personal information to our related bodies corporate. Similarly, the employer exemption relating to employee records (we have, however, adopted a number of measures designed to protect the privacy of our employees).

If you nominate an individual contact within an Advisory firm or Administrative firm, PortNordica deems (in order to protect the privacy of our investors) that you give authority to the firm and not the individual contact.

Personal Information Security

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

You should be aware that the internet is not a secure environment. Whilst PortNordica takes reasonable steps, we cannot guarantee the security of the information you provide to us via our website or that we make accessible to you via the secure investor site. No personal data is stored on our public website. Personal data is stored on our secure investor site.

Access to Your Personal Information

In many circumstances, you can request access to personal information we hold about you. Sometimes it is not possible for us to give you access in which case we will explain why.

PortNordica will take reasonable steps to correct personal information held about an individual where PortNordica is satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading or, you request that PortNordica corrects the information.

Need to Contact Us?

If you have any questions about this Privacy Policy, or wish to make a complaint about how PortNordica has handled your personal information, or you wish to access or correct your personal information held by us, please contact the Privacy Officer:

PortNordica Limited

Royal Exchange Building

Suite 9.03, Level 9

56 Pitt Street

Sydney NSW 2000

Email: contact@portnordica.com.au

About this Policy

This policy is effective as of 1 December 2018. We will update this policy when our information handling practices change, and any amendments will apply to the information we hold at the time of the update. We will post the updated policy on our website; we encourage you to check our website from time to time to view our current policy or contact us for a printed copy.

This policy incorporates the relevant provisions of the Privacy Act and the Australian Privacy Principles.