Rubicon Asset Management Limited (Rubicon), as a member of the Allco Finance Group (AFG), is committed to protecting all personal information about you that we may hold.

This privacy policy describes how we manage your personal information and safeguard your privacy.

National Privacy Principles

Since 21 December 2001, most private sector organisations in Australia have been required to comply with the national privacy principles (NPP) which are derived from the Privacy Act 1988 (Cth) (Privacy Act).

Information collected

Rubicon holds personal information collected from unit holders and investors, shareholders, contractors, job applicants, employees, investors in Rubicon products and individuals who deal with Rubicon in the course of Rubicon’s business activities. This information may be held by Rubicon or Rubicon’s nominated agent.

The kinds of personal information we collect and hold will depend upon your relationship with us and/or the type of products and services you supply to, or request from, us. 
That personal information may include, for example:

• information you give us when you request a product or service from us (this information will include your name, address and contact details);
• communications between us and your financial adviser; and/or
• if you have or had an investment in Rubicon financial product or have received a service from us, transactional information about the use of that product or service.

Use of our website

We may collect some information from you when you use our website.

The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form or asking for a disclosure document for our products or by sending us an email. We will record your email address if you send us an email.

When you visit the website, our server places small pieces of data known as “cookies” on your hard drive. Cookies are pieces of information that are transferred to your computer when you visit a website for record-keeping purposes.  Most internet browsers are set to accept cookies.  However, if you do not wish to receive any cookies you may set your internet browser to refuse to accept cookies.  We use cookies to provide us with aggregate, anonymous, information on how people use our website and to help us to know what our customers find interesting and useful in our website.  We do not link this information back to other information that you have provided to us.

Using and disclosing your personal information - The purposes for which we collect and hold personal information and how we use it

Rubicon uses your personal information as required in order to perform its various roles as, issuer of shares, operator of a financial business, issuer of financial products, employer and investor.

Information we collect from our shareholders is used to assess applications for shares, keep proper company records and administer the company. Information we collect from contractors, job applicants and employees is collected to facilitate normal employment functions.  Information that we collect from individuals involved in Rubicon’s business is collected by Rubicon in order to facilitate the relevant business activities.  Information that we collect from investors in the financial products that we issue will be used by us:

• to assess your applications for products or services that we may provide; and
• to provide you with the products or services and related information; and
• to conduct transactions in relation to the products and services that you request we transact on your behalf.

We may also use your personal information to help us develop other products and services and to provide you with information about other products and services offered or distributed by Rubicon and AFG, and AFG’s related bodies corporate. If investors do not wish to receive such information, they should contact the Rubicon Privacy Compliance Officer, on (02) 9302 2100 during business hours.

Collection of personal information

Where possible, Rubicon collects personal information about individuals directly from the relevant individuals. If practicable, Rubicon provides disclosure as required under the Privacy Act prior to, or at the time of, collection. Where this is not practicable, the disclosures are provided as soon as practicable after the time of collection.

Where Rubicon collects personal information about individuals from sources other than individual themselves (for example, via Rubicon’s or AFG’s outsourced service providers), Rubicon takes reasonable steps to ensure that the individual has been made aware of matters covered by disclosures required under the Privacy Act.

Contracting out services and disclosures

When Rubicon collects your personal information, it seeks to inform you of the categories of third parties to whom your personal information may be disclosed either by the information provided in this policy or otherwise.  Please note that we contract out some of our functions (for example, registry services and mailing) to external service providers.  We may disclose your personal information to these third party service providers as well as law enforcement bodies, professional advisers and financial institutions who are involved in processing transactions.  We may disclose your personal information to these third parties but only so that they can provide the services that we have contracted out to them or process the transactions you have requested us to transact on your behalf.

Rubicon ensures that providers of outsourced services are subject to contractual provisions for the protection of personal information disclosed to them by Rubicon.

Data security

Where necessary and appropriate, Rubicon periodically reviews the personal information that it collects to ensure that it is accurate, complete and up-to-date.

Security of personal information

Rubicon takes precautions to protect the security of personal information that it holds. In particular, Rubicon has taken steps to promote physical security, computer security, communications security and personnel security and staff have received appropriate training in dealing with individuals’ privacy.

Your Access to your personal information

Subject to any legal constraints (including the NPPs), Rubicon will provide access to personal information to the individual who is the subject of the information. Persons who wish to obtain such access should direct their requests to the Rubicon Privacy Compliance Officer, on (02) 9302 2100 during business hours.

Destruction of personal information no longer required

Rubicon retains personal information to the extent required to conduct its business and for retention periods required under law. Once the information is no longer required, Rubicon’s policy is that the information should be destroyed.

Complaints

Any person who believes that the information held by Rubicon is incorrect or who has a complaint regarding Rubicon's management of personal information should direct their complaint to the Rubicon Privacy Compliance Officer, on (02) 9302 2100 or you can write to Rubicon Privacy Compliance Officer, Rubicon Asset Management Limited, Level 2, 287-289 New South Head Road, Edgecliff NSW 2027.

Changes to our Privacy Policy

From time to time our privacy statement may change. We may notify you about changes to our privacy statement by posting an updated version on this website.