SIGN UP TO OUR INSIGHTS → THE OPHIR FUNDS NEWS & INSIGHTS OUR TEAM HOW TO INVEST CONTACT US CAREERS Privacy Policy Ophir Asset Management (Ophir) is bound by the Australian Privacy Principles set out in the Privacy Act which impose certain requirements on Ophir with respect to handling personal information. Ophir has implemented procedures to ensure that personal information is handled in accordance with the Act. Ophir has issues this policy in compliance with the Act. Please read the following policy to understand how Ophir deals with the personal information that it may collect about you from time to time. This policy may change from time to time, so please revisit the policy periodically. WHO DO WE COLLECT PERSONAL INFORMATION FROM? In the course of providing our products and services, Ophir may collect personal information from clients, or potential clients. What types of personal information do we collect? In the course of providing products and services we may collect: Personal Information including names, addresses and other contact details; dates of birth; and financial information. Sensitive Information including government identifiers (such as your TFN), your nationality, country of birth, professional memberships, family court orders and criminal records. HOW DO WE COLLECT AND HOLD YOUR PERSONAL INFORMATION? How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you. Where possible, Ophir has attempted to standardise the collection of personal information by using specifically designed forms (e.g. our Application Forms). We may also collect personal information from other people (e.g. a third party administrator) or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly. We also use cookies to tell us how you use our website and how we can help you. Cookies are digital identifiers that are automatically stored on your computer. These help us personalise our service to you and may collect and store your server address, top level domain name (e.g. .com, .gov, .net etc), the date and time of your visit, country your service address is located in, the type of browser you used, the pages viewed and any downloads made, the previous site you visited and the site you visited next. Cookies can make your subsequent visits to our website simpler and more efficient. We may also use the information to assist in improving the website, marketing and product development. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. By not accepting cookies, some pages on the website may not display properly or you may not be permitted to access certain information. Cookies can be turned off or deleted at any time through your browser settings. A server cannot find out a name or email address, or anything about you by using cookies. We do not store or collect cookie information. HOW WE USE YOUR PERSONAL INFORMATION? We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented. Our uses of personal information include but are not limited to: Providing you with one or more of our financial services or products; To assess your application for a financial product or service; and/or To communicate with you about the products and services that we offer. We may also need to collect personal information in order to comply with our legal obligations, such as the AML/CTF laws, under the Anti-Money Laundering and Counter Terrorism Financing Act 2006. It may be necessary for Ophir to disclose your personal information to certain third parties in order to assist us with one or more of our functions or activities. This may include organisations providing fund administration or custodial services under an arrangement with us. We only collect sensitive information reasonably necessary for one or more of these functions or activities if we have the consent of the individuals to whom the sensitive information relates, or if the collection is necessary to lessen or prevent a serious threat to life, health or safety or another permitted general situation. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION We store personal information in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers. The security of your personal information is of paramount importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure. These steps include: Restricting access to information on our databases on a need to know basis Implementing ICT security systems, policies and procedures designed to protect personal information storage on our computer networks. Undertaking due diligence with respect to third party service providers who may have access to personal information, including customer identification providers and cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime. Personal information we hold that is no longer needed, or required to be retained by any other laws, is destroyed in secure manner, deleted or de-identified as appropriate. Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION We only use personal information for the purposes for which it was given to us, or for purposes which are directly related to one or more of our functions or activities. We may disclose your personal information to government agencies, and other recipients from time to time, only if one or more of the following apply: you have consented; you would reasonably expect us to use or disclose your personal information in this way; we are authorised or required to do so by law; disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; where another permitted general situation applies; disclosure is reasonably necessary for a law enforcement related activity. DISCLOSURE OF YOUR PERSONAL INFORMATION TO OVERSEAS RECIPIENTS We may disclose personal information about an individual to overseas organisations that help us provide our services, in certain circumstances, such as when storing information with a “cloud service provider” which stores data outside of Australia. We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless: we have the individual’s consent (which may be implied); we have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime; we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or we are taking appropriate action in relation to suspected unlawful activity or serious misconduct HOW WE ENSURE THE QUALITY OF YOUR PERSONAL INFORMATION We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up to-date. These steps include ensuring that the personal information is accurate, complete and up-to-date at the time of collection and when using or disclosing the personal information. On an ongoing basis we maintain and update personal information when we are advised by individuals or when we become aware through other means that their personal information has changed. Please contact us if any of the details you have provided change. You should also contact us if you believe that the information we have about you is not accurate, complete or up-to-date. HOW TO GAIN ACCESS TO YOUR PERSONAL INFORMATION WE HOLD You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us. If we do not agree to provide you with access or to amend your personal information as requested you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record. PRIVACY COMPLAINTS If you wish to make a complaint about a breach by us of the Australian Privacy Principles, you may do so by providing your written complaint by email or letter to any one of our contact details as noted below. You may also make a complaint verbally. We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we may seek further information from you in order to provide a full and complete response. HOW TO CONTACT US You can contact us about this Privacy Policy or about your personal information by emailing us (ophir@www.ophiram.com.au) If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so. CHANGES TO OUR PRIVACY AND INFORMATION HANDLING PRACTICES This Privacy Policy is subject to change at any time. Please check our Privacy Policy on our website (www.ophiram.com) regularly for any changes. Get our latest insights By subscribing to Ophir News & Insights you'll understand more about our investment philosophy and process and the investment decisions we make on all of our behalf. WHAT YOU'LL GET Monthly Ophir Letter to Investors Timely investment ideas Exclusive event invitations LEARN MORE OPHIR Level 26, Governor Phillip Tower One Farrer Place, Sydney, NSW 2000 Phone: +61 (0) 2 8006 5476 Email: ophir@ophiram.com OUR FUNDS Funds Overview The Ophir Opportunities Fund The Ophir High Conviction Fund (ASX:OPH) The Ophir Global Opportunities Fund Investment Philosophy & Process How To Invest LEGAL Privacy Policy FSG Disclaimer FOLLOW US Follow us on LinkedIn Disclaimer: While all reasonable care has been taken in the preparation of this information, Ophir Asset Management take no responsibility for any actions taken based on information contained herein or for any errors or omissions. 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