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Client Privacy Policy

Introduction

Safeguarding the privacy of your personal information is an integral part of the service provided by FIRSTUNITY This Client Privacy Policy outlines the ways in which FIRSTUNITY aims to protect your personal information and describes what personal information we hold about you, for what purposes, how we obtain and make use of that information, and how we ensure your privacy.

The personal information you disclose to FIRSTUNITY will be collected, held, used or disclosed in accordance with the National Privacy Principles (NPP) set out in the Privacy Act 1988 (Cth) and other privacy laws and regulation.

The sort of information we collect and why

If you are a client of FIRSTUNITY or you wish to become one, we need to obtain sufficient information about your financial situation and your needs and objectives in order to offer you quality advice. One of our investment professionals or a member of our investment team will request this information in the first instance.

We will only collect personal information relevant to our business relationship with you. Depending on the services you have requested, examples of the information we may need to collect are your name, address, contact details, tax file number, date of birth, employment and financial information such as your income, expenses, credit history and financial needs and objectives.

If you choose not to disclose this personal information, we may not be able to provide you with some or all of our investment and advisory services. Should you direct us to invest all or part of your portfolio in a particular product or investment, personal information will be collated from your client financial profile form to establish and administer that investment.

The collection of sensitive personal information is restricted by the provisions of the Privacy Act. As such, FIRSTUNITY will not obtain, use or disclose information about your racial or ethnic origin, political opinions, memberships of a political association, memberships of a professional or trade association or trade union, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, criminal record or health information unless you have given us express consent to do so or unless it is required by law.

The provision of your Tax File Number is covered by federal legislation and is also protected.

How personal information is collected

We collect personal information when you complete a Client Profile Form, or when you give us information in person, by mail, telephone or internet, or through your personal representative, accountant or lawyer.

FIRSTUNITY may also collect information from our website for internal purposes but not information that can directly identify you. Such information may include the number of users who visit the site, date and time of visits, number of pages viewed and other user patterns. To collect this information we use ‘cookies’, or small computer data files that are saved on your hard drive. Cookies do not contain any personally identifying information.

Furthermore, we may collect information from you on behalf of another person such as your spouse, your children or the name of a friend or colleague that you may decide to refer to us. In this case, it is your responsibility to tell them of your disclosure and that they may access their information held by FIRSTUNITY.

The personal information you provide to us is confidential for use only within the FIRSTUNITY group, primarily for the provision of services requested and the administration of that service.

How we use and disclose personal information

FIRSTUNITY may also use your personal information to communicate with you about your investments and to inform you about new products and services that may be of interest to you. While some communications are required by law, you can notify us at any time if you do not wish to receive this information.

We will not use your information for any other purpose than is specified here unless you have given us your consent or it is for another related purpose that is within your reasonable expectations.

We will not reveal, disclose, sell, distribute, rent, licence, share or pass your information to third parties, other than to service providers contracted to FIRSTUNITY under strict confidentiality arrangements; your accountant or lawyer when required to implement financial investment advice; or where we have your express written or oral consent. An exception to this is where FIRSTUNITY may be required by law to disclose certain information.

How we protect your personal information

We will use reasonable steps and up-to-date techniques and processes, which meet current NPP standards, to protect your personal information from misuse, loss and unauthorised access, modification or disclosure.

We will also take reasonable steps to destroy personal information or remove any identifying features from it once it is no longer required, subject to any legal requirements that call for the retention of information for a certain period of time.

How to access or update personal information

To ensure the information collected, used and disclosed by FIRSTUNITY is accurate, complete and up-to-date, we ask that you immediately notify us in the event that you change your contact details, such as your telephone number and address.

As a client of FIRSTUNITY you are also entitled to access the personal information we hold about you, provided that access does not contravene privacy laws or reveal a commercially sensitive decision-making process.

Contacting FIRSTUNITY

If you would like more information, or would like to access, update or amend the personal information FIRSTUNITY holds about you or you wish to make a complaint, please contact us on (02) 8256 3100 or write to us at:

FIRSTUNITY FINANCIAL GROUP PTY LTD

PO Box R1727

Royal Exchange NSW 1225

This policy is published by FIRSTUNITY FINANCIAL GROUP PTY LTD ACN 120 704 789 and is current as at August 2008. FIRSTUNITY is entitled to make changes to our policies, processes and systems relating to how we handle your personal information from time to time and for any reason. We will update this policy to reflect any changes.