Privacy Policy

Right to privacy:

The below privacy policy is set out for the Premium China Funds Management Pty Ltd (ABN: 98 113 856 214). By visiting our website, you agree to the statement as outlined when it comes to but not limited to using any of our services or otherwise providing us with your personal information (or authorising it to be provided to us by someone else). By agreeing to these terms and conditions you advise that you agree to the use of your personal information in being collected, stored, used, disclosed and otherwise managed as set out in this Privacy Policy. We understand the importance of protecting an individual’s right to privacy, and outline the way in which we collect, hold, use, disclose and otherwise manage your personal information alongside its practises and producer. In handling your personal information, we comply with the Privacy Act 1988 (Cth) (‘Privacy Act’) and the Australian Privacy Principles (‘APPs’) under the Privacy Act. Please note that over time practices and procedures regarding how we collect, hold, use, disclose and otherwise manage personal information, will change in the course of operations and hence this policy may be updated from time to time in accordance with the Privacy Act 1988 (Cth) (‘Privacy Act’) and the Australian Privacy Principles (‘APPs’) as stipulated within the Privacy Act.

What information we collect:

At all times Premium China Funds Management will only collect personal information, which is deemed necessary to assist us in providing our services to our clients. For the purposes of the 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. In line with the Privacy Act, by way of definition personal information refers to 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 provided. The details could include but are not limited to information such as name, phone numbers, address, email address, banking details, date of birth, country of residence, investment details, payroll details, taxation details (including Tax File Number) and other accounting, audit, driver’s licence details, passport details and other financial services related information. In certain circumstances, we may also hold other kind of details provided by you under Australian anti-money laundering legislation for identification and other purposes. If other personal information has been provided to us, which we have not requested (unsolicited personal information), unless otherwise required or permitted by law, delete or destroy it at the earliest possible time after receiving it. We will at times but are not limited collect information in accordance with the information required under the following acts Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (“AML/CTF Laws”), Income Tax Assessment Act 1997 / Tax administration Act 1953 and Superannuation Industry (supervision) Act 1993. To comply with the Foreign Account Tax Compliance Act (FATCA), we are compliantly required to collect and disclose certain personal information to the Australian Taxation Office. If you do not provide us with the relevant required personal information, we may not be able to provide our services or assistance to you or our clients on your behalf and may not be able to process any application by you for investment in our funds. From time to time we may also collect statistical information, which may relate to but is not limited to information relating to your use of our website or other online services.

Who we disclose this information to:

The sole purposes of the collection of your personal information is for the management and provision of our funds management services and will generally only disclose this information to anyone of the few individuals/entities stated people for the purposes of abiding by laws/regulations and internal compliances. These type of organisations in, which we disclose personal information include but is not limited to Premium China Funds Management and other relatable entities which include but limited to value partners group, financial advisers or other professional advisers, Governments bodies and regulators as required, as well as other professional advisers/organisations involved in the operations of the funds management business this could include, however not limited to legal accounting firms, auditors, consultants and other advisers, this also extends to the administers of the fund, which allow us to operate and manage investor accounts. Information may be disclosed to overseas receipts and maybe held in both hard or electronic form. All personal information that is held and disclosed to other parties, we will take as reasonable basis to ensure that the information is protected against misuse, loss, unauthorised access, modification or disclosure. Personal information is held on secure servers or in storage located in controlled, access restricted environments. Our employees are required to maintain the confidentiality of any personal information held by us. However by agreeing to the disclosure of your personal information, when you engage with us as a service provider entities outside of Australia, we will no longer be required to take reasonable steps to ensure the overseas recipient’s compliance with the Australian privacy law in relation to your personal information and we will not be liable to you for any breach of the Australian privacy law by these overseas recipients. On this basis, you consent to such disclosure.

How we protect the personal information:

Premium China Funds Management always ensures it takes the upmost reasonable steps to ensure that your personal information held and received from you is protected and ensures that we take the reasonable steps to ensure that personal information is free from misuse, interference and loss and from unauthorised access, alteration and disclosure. A few of many security measures taken to protect your personal information includes the implementation of a security procedures on our physical premises on 330 Wattle street Ultimo NSW 2007, beyond this within our IT security protocols, we ensure that that personal information has the adequate protections, which includes password protection, firewalls, intrusion detection and site monitoring; and mandatory confidentiality guidelines for all staff within the business (as outlined in employment contracts). This personal information maybe held in both electronic or hard copy, by relatable entities that Premium China Funds Management uses to operate it funds management business. This personal information held by another entity creates an obligation that falls on the confidentiality and privacy obligations on the service provider. However, even with the best efforts of data protections, we cannot ensure that in full that all data will be secure and hence cannot guarantee the security of your personal information in certain situations. As result you must take care to protect your personal information as best fit possible and notify us as soon as possible if you become aware of any security breaches.

What you need to do, if you have a complaint:

In the situation where you feel that your personal information has not been dealt with a manner that complies with the privacy act or similar acts, a complaint can be lodge to us directly. To do, this please lodge all complaints, directly to Premium China Funds Management in writing using the contact details as provided below in this document, please also provide us with enough details regarding your complaints along with any supporting evidence in relation to your complaint. With complaints lodged, we will ensure that they are dealt with the upmost seriousness, confidential manner, promptness and will not inherently affect your existing obligations or affect the commercial arrangements between you and us. Once we have received your formal complaint, we will begin a commencement of looking into your complaint and inform you of an outcome upon completion of the investigation. If we require any further detail from you, we will contact in relation to the specific items requested for us to investigate your complaint. In the situation were you feel unsatisfied with the outcome of the complaint resolution, you can contact us to further discuss your concerns or lodge a formal complaint to the Australian Privacy Commissioner via www.oaic.gov.au.

How we collect the information:

The way in which Premium China Funds Management collects your personal information can be through various ways, which include via telephone, our website, email or hardcopy and/or online forms. In most situations, we will collect this information directly from you, or collect this information via a third parties, such as trustees and Responsible Entities, fund managers, companies / trusts in which you are a unit holder, shareholder or officeholder, your employer, your financial adviser / planner and/or anyone you have authorised to deal with us on your behalf. From time to time, we may also request to collect information about someone else from you (for example, details of the members of your company/fund or your employees/contractors). However, we will never request nor request the personal information about another person unless provisional consent has been provided for that person to do so. In al these situations the personal information collected and retained will be, held, used, disclosed and otherwise managed by us in accordance with this Privacy Policy.

Why do we need your personal information?

Premium China Funds Management retains your personal information only for the purposes for which it was provided, which is made apparent at the time of collection, and could relate to but not limited for the purposes which may include, Establishing, maintaining and administering your account or your investment in any of Premium China Funds or other products. The specific details, that may be requested in conjunction with personal information may used for the purposes of conducting verifications, monitoring and reporting required under the AML/CTF Laws; recording tax information such as TFN, ABN, country of residence to report to the ATO (and other relevant bodies as required by law) and withhold tax correctly from payments. We also retain information for the purposes of communicating with you or our clients regarding the status of your unit / share holdings, value, distributions or responding to your and/or our clients’ enquiries / information requests; processing authorised payments to and from you. Providing you and/or our client with the services requested (such as unit registry and investor relations services, accounting and fund administration services, payroll services and compliance services); quality assurance and training purposes. From time to time Premium China Funds Management may disclose your personal information to inform you of products, services or offers of Premium China Funds Management, its related companies or commercial partners which may be of interest to you, which may include providing you with direct marketing information, if you do not wish to receive such material, you can opt out at any time. Personal information will be held only if it relates to the purposes of operation our funds management business and operations. One of few reasons why we require your personal information could relate to processing your application for investment in our funds or other products and establishing your investment in our funds or products ensuring that we are able to adequately administer any investment, you have with us in our funds or other products, including communicating with you about your investment. This includes but is also not limited to providing to online services, responding to enquires, performing internal business operations, Adequality being able to provide information relation to our products or services that may be of interest to you. Informing any governing bodies to the fund’s management business, i.e Australian Tax Office and other governmental authorities of your tax file number. This further extends to the making of distributions or withdrawal payments of your investment to your nominated bank account. Alongside this information is retained to ensure accounting, billing and other internal administrative purposes to adequately perform their duties to their clients. We may also retain personal information, for the reasons of the ensuring that we are able to comply with our legal requirements under any applicable laws, including the anti-money laundering legislation, as well as comply with any other legal requirements. There is no obligation to provide your personal information to us, that personal information is to be provided to us. We will, however be unable to proceed forward without receiving certain information from you, and as a result may be unable to provide our services to you and process any application by you for investment in our funds or other products. We may also use and disclose your personal information to inform you of products, services or offers which may be of interest to you that relate to our business operations. If you do not want to receive this information or do not want us to use or disclose your personal information for direct marketing purposes, you can opt out by letting us know that you wish to opt out of receiving this information and/or Premium China Funds Management using or disclosing your personal information for direct marketing purposes.

How do you contact us:

If you have any further enquiries regarding the privacy policy, personal information or would like to lodge a formal complaint: Please use the below the details.

Premium China Funds Management Pty Ltd

Suite 39, Level 2, 330 Wattle Street, Ultimo NSW 2007

Phone: (02) 9211 3888

Email: info@premiumasiafunds.com.au

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