Natixis Investment Managers Australia Pty Ltd. and other members of the Natixis group (together “we” or “Natixis Investment Managers Australia”) are committed to safeguarding the personal information that they receive. Natixis Investment Managers Australia (NIMA) will hold it in confidence in accordance with:
- the Australian Privacy Principles (“APPs”) in the Privacy Act 1988 (Cth) as amended (“Australian Privacy Act”) if you are an Australian resident; and
- the Information Privacy Principles in the Privacy Act 1993 (“New Zealand Privacy Act”) if you are a New Zealand resident.
This policy describes how we may collect, hold, use, disclose or otherwise process your personal information.
What is personal information?
Under the Australian Privacy Act personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. Under the New Zealand Privacy Act personal information is any information about an individual (a living natural person) as long as that individual can be identified.
What personal information do we collect and why do we collect it?
Natixis Investment Managers Australia (including through the registrars of the relevant products or solutions) may collect personal information from investors (including their staff and representatives). This information includes, but is not limited to:
- Name;
- Date of birth;
- Contact details;
- Gender;
- Tax File Number;
- Country of residence;
- Investment information; amd
- Bank account information.
We collect this information to facilitate your investment in the relevant product or service and to comply with relevant laws, for example anti money laundering and counter terrorism financing laws. We collect this information directly from the investor (or their staff and representatives) and not from third parties.
Natixis Investment Managers Australia will also collect personal information of people who subscribe/register to various general advice, newsletters, webinars, events and marketing services, including those of our affiliated entities Investors Mutual Limited (www.iml.com.au), Loomis Sayles (www.loomissayles.com.au) and Vaughan Nelson (www.vaughannelson.com.au).
This information includes, but is not limited to:
- Name;
- Contact details;
- Country of residence;
- Email address.
We collect this information to facilitate the provision of the requested information and services.
Additionally, Natixis Investment Managers Australia may also collect personal information from people we do business with, in order to fulfill the relevant business purpose. This will usually happen when we collect the name and business contact details of a person who is an adviser, supplier or other business contact. We collect this information to facilitate the relevant business purpose. Natixis Investment Managers Australia may also collect personal information from people who send us correspondence. Information collected includes name and contact details. We collect this information to deal with correspondence. We collect this information directly from the relevant individuals and not from third parties.
Sensitive Information
This is a subset of personal information and includes information or an opinion about an individual's racial or ethnic origin, trade union membership or associations, sexual orientation, information about any criminal record or health information. We will not generally collect sensitive but if it is reasonably necessary to collect and record sensitive information, Natixis Investment Managers Australia will obtain the individual’s specific consent.
What if the information is incomplete or inaccurate?
Natixis Investment Managers Australia may not be able to provide you with the products or services you are seeking.
How do we use and disclose personal information?
We use personal information to facilitate the investment in the investment product or service or the provision of any requested information services, to personalise and customise your online experience including by tailoring any promotional and marketing materials. By completing either a fund application (PDS) or an online subscription/registration form Investors/subscribers are deemed to have consented to such information being processed for the purposes referred to above and for receiving additional information about the full range of services offered by Natixis Investment Managers Australia and its affiliates (you will need to email Natixis Investment Managers Australia if you do not want to receive this additional information). Other personal information will be used to facilitate the business purpose for which it is provided. Natixis Investment Managers Australia may disclose the information to its affiliates and service providers. Where we disclose information to a third party, confidentiality arrangements will be in place.
Personal information may be disclosed to the relevant investment manager, who may be located overseas. The country they are located in will be set out in the relevant offering document or the section titled “Transfers of personal information outside of Australia”.
Natixis Investment Managers Australia may be required by relevant laws to disclose personal information to a regulator (such as the Australian Taxation Office) or to a court or tribunal.
Transfers of personal information outside of Australia
The personal information that we collect from you may be transferred to recipients, and stored at a destination, outside of Australia, including, France, India, Hong Kong, Portugal, and Singapore, for the purposes described above. Due to the global nature of our business, your personal information may be disclosed to related entities of NIMA outside of Australia, including in France, Portugal, India, Singapore and Hong Kong. It may also be processed by personnel operating outside Australia who work for us or for one of our suppliers who act on our behalf.
In those cases where we transfer your personal information to countries outside Australia, we will take steps to ensure that prior to such transfer, the transfer is subject to appropriate safeguards, and that your personal information is handled in accordance with the Privacy Act.
How do we protect the confidentiality of personal information?
We will take reasonable steps to ensure that any identifiable personal information that we have collected is stored securely. The measures utilised include password protection to our systems, restricting access to our systems and education of staff.
Our website
Our website may collect non-personal information when you visit our website. Our website also uses cookies. A 'cookie' is a packet of information that allows the server (the computer that houses the web site) to identify and interact more effectively with your computer. This information does not typically identify individual users and it is unlikely to be personal information. Any personal information collected through subscription requests on our website is outlined above under “What personal information do we collect and why do we collect it?”
Links to other websites
Our website may have links to external third-party websites that may benefit the user. External websites should contain their own privacy statements and we recommend you review them when using their websites. Please note, however, that third party websites are not covered by our Privacy Policy and these websites are not subject to our privacy standards and procedures.
Access to personal information, corrections and complaints
You have a right to access any personal information we hold about you (although there are some exceptions to this) and correct any personal information that may be incorrect by contacting Natixis Investment Managers Australia at the address below. We may deny such a request in some circumstances, if we do this we will explain why.
Please note that the personal information we hold about you will be information that you (or your representative) have provided.
Natixis Investment Managers Australia will respond to requests for access or correction within a reasonable time. Natixis Investment Managers Australia may ask you to pay its reasonable costs of responding to your request.
You may also make a complaint to Natixis Investment Managers Australia concerning a breach of the Australian and New Zealand Privacy Acts by writing to the address below. We will acknowledge complaints and provide an initial response within 20 working days and provise a final response within 30 days of receipt of the complaint.
Additional information
Natixis Investment Managers Australia may change this Privacy Policy at any time. We will make this Privacy Policy available to anyone who requests it, free of charge, either at our offices or through our website.
For further information about privacy issues, see the Office of the Australian Information Commissioner's website at www.oaic.gov.au or New Zealand Privacy Commission at www.privacy.org.nz.
If you have a privacy concern, complaint or query, please contact +61 (2) 8224 2900 or Email: dpo-natixisimid@natixis.com or by mail at:
Privacy Officer
Natixis Investment Managers Australia Pty Ltd.
Level 16
39 Martin Place
Sydney NSW 2000
Australia
Please note that the Natixis Investment Managers company group has also adopted a global Privacy Statement in relation to: (1) our global marketing activities, which is available here as well as (2) our various other country sites, which is available here. Both of these privacy statements contain important additional contact details and information about our global data processing activities in relation to our marketing activities and our websites in particular.
Natixis Investment Managers Australia Pty Ltd.