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Privacy Policy

Privacy Policy & Statement

  1. Intro – IPG Group of Companies

IPG Funds Management Pty Ltd (IPG FM or Company) is part of the IP Generation Group of Companies (IPG Group or Group). The IPG Group includes IP Generation Pty Ltd (IPG), IPG FM and each of their Subsidiaries (Group members) from time to time. IPG was established in 2018 to act as the holding entity for a property funds management business.  

IPG FM is a wholly owned subsidiary of IPG and holds an Australian Financial Services License (AFSL). IPG FM is authorised under its AFSL to offer unregistered managed investment schemes (Schemes) to Wholesale Investors. IPG FM, and other relevant Group members, have outsourced their corporate administrative activities to their parent IPG via a Business Services Agreement. In their capacity as Trustee for Schemes, Group Members may outsource management of the Schemes to IPG under an Investment Management Deed. IPG FM has entered an Investment Management Deed with IPG to outsource all investment management services in relation to Schemes for which it acts as Trustee. 

The IPG Group Charter governs the modus operandi of the IPG Group. The IPG Governance framework sets out the roles and responsibilities of the various Group members and documents the relationship between them.  For further detail, please refer to the IPG Board Charter, the Business Services Agreement and the Investment Management Deed, which includes a Pro Forma Services Matrix for each asset managed within the IPG Group.

  1. Purpose of Privacy Policy 

The purpose of the Privacy Policy (Policy) is to state the approach taken by IPG FM and the IPG Group to manage client & personal information and to safeguard the privacy of that personal information.

This Policy is based on the Australian Privacy Act 1988 and associated privacy principles.

  1. General consideration 

All Group members, including IPG FM, have a duty to act in the best interest of Wholesale clients that invest in the Group’s Schemes. As such, they must respect the information they receive from and about clients.  

IPG Staff should therefore avoid mentioning clients’ name, discussing their business relationship or affairs, or supplying reports to third parties unless this information is publicly available.  

Clients’ affairs should only be discussed internally, in the normal course of business. This means that even internal discussions of a client’s affairs should be restricted to staff members involved in processes and activities for the client.

Under the Anti-Money Laundering and Counter Terrorism Act, IPG FM has a responsibility to conduct identity checks on applicants investing in the Schemes issued for Wholesale clients. There are ongoing monitoring requirements applicable as well, as described in IPG FM’s Anti-Money Laundering and Counter Terrorism Financing Program (AML Program) which is applicable to the whole IPG Group.  

  1. Privacy Officer 

The Financial Controller is the appointed Privacy Officer for the company. The COO has been registered with the Australian Transaction and Reports and Analysis Centre (AUSTRAC) as the company’s Anti-Money Laundering & Counter Terrorism Financing Officer.

  1. New Investment Mandates – collecting client information

Where a Wholesale client participates in a Scheme operated by a Group member, or a client agrees for a Group member to arrange for it to deal with a financial advisor on the client’s behalf, the relevant client identification procedures detailed in the AML Program are to be followed at all times.   

  1. Privacy Statement

IPG FM has legislative obligations to make public its Privacy Statement containing information on such matters as to how it collects private information, retains and deals with that information. Examples of where the Privacy Statement will appear is on the company’s website (if applicable) and as part of the Information Memorandum by which Wholesale investors may subscribe for investments in Schemes. 

The following is IPG FM’s Privacy Statement.

Privacy Statement

IPG Funds Management Pty Ltd (IPG FM or Company) is part of the IP Generation Group of Companies (IPG Group or Group). The IPG Group includes IP Generation Pty Ltd (IPG), IPG FM and each of their Subsidiaries (Group members) from time to time. IPG was established in 2018 to act as the holding entity for a property funds management business.  

IPG FM is a wholly owned subsidiary of IPG and holds an Australian Financial Services License (AFSL). IPG FM is authorised under its AFSL to offer unregistered managed investment schemes (Schemes) to Wholesale Investors. IPG FM, and other relevant Group members, have outsourced their corporate administrative activities to their parent IPG via a Business Services Agreement. In their capacity as Trustee for Schemes, Group Members may outsource management of the Schemes to IPG under an Investment Management Deed. IPG FM has entered an Investment Management Deed with IPG to outsource all investment management services in relation to Schemes for which it acts as Trustee. 

The IPG Group Charter governs the modus operandi of the IPG Group. The IPG Governance framework sets out the roles and responsibilities of the various Group members and documents the relationship between them.  For further detail, please refer to the IPG Board Charter, the Business Services Agreement and the Investment Management Deed, which includes a Pro Forma Services Matrix for each asset managed within the IPG Group.

What kind of Personal information is collected and held?

IPG FM, and other Group members if applicable, are required to collect and hold personal information in the course of its normal business. The types of personal information we collect include:

Your name, home address, date of birth, contact details (including your address, phone numbers and emails, whether personal or for work. Other identification verification information, including photographic information from documents like your passport, driver’s licence, pension card, citizenship certificate, tax notice assessment, Medicare card and utilities notices. Financial information about your sources of wealth and purpose of investment, tax information, including your tax file number (TFN), banking information and payment details.

When recruiting employees or appointing contractors, the IPG Group may collect and hold personal information such as: 

The individual’s name, contact details, date of birth, citizenship, employment references, civil credit and criminal records, regulatory accreditation as may be required, driver’s licence information, education and employment history. Once appointed, we will also collect and hold TFNs, financial information relating to the appointment and banking details for payments.

How is it collected?

For our Wholesale clients, personal information is mainly collected through the application forms that you complete to access the financial products and services we provide

In addition, personal information may be provided to us via meetings, telephone, email and other correspondence. Information may also be received through third parties, such as financial advisors.

We also collect some information from you when you use our website. Your use of the website will determine the amount and type of information which we collect about you. Some of this information will not be personal information because it will not reveal your identity.

The only personal information which we collect about you when you use our website is what you tell us about yourself, for example, by completing an online form, including registering to receive updates, promotional material or information you provide to us when you send us an email. We will record your email address if you send us an email.

The use of Cookies

We may use temporary (session) cookies or permanent cookies when you access our web site. This allows us to recognise your browser and track the web pages you have visited. We do not link this information back to your identity or other information that you have provided to us. We do not store any information that identifies you inside cookies. You can switch off cookies by adjusting the settings on your web browser.

Collection of Anonymous Information

We may track usage patterns on our website on an anonymous basis. Your identity cannot be reasonable ascertained from this information. When you visit our website, a web server will record your visit and specifically certain information, including information in relation to your operating and the pages you have visited.

Why we collect, hold, use and disclose clients’ personal information?

IPG FM, and other Group members if applicable, collect, hold, use and disclose personal information of our clients for the purposes of providing financial products & services. This includes the establishment of your investment in our unregistered managed investment schemes, the ongoing administration and regular reporting on the performance in relation to this investment.  We also need your personal information in order to comply with regulatory or legal requirements, including:

  • The Anti-Money Laundering & Counter-Terrorism Act 2006
  • The Corporations Act 2001
  • The Australian Securities and Investments Commission Act 2001
  • The Bankruptcy Act 1966
  • The Tax Laws Amendment (Implementation of the FATCA Agreement) Act 2014 the 
  • Tax Laws Amendment (Implementation of the Common Reporting Standard) Act 2016; and applicable taxation law.

How is the information held?

We respect the personal information you have entrusted to us and we have a responsibility to manage and protect that information. IPG FM will take all reasonable steps to protect your personal information from misuse, interference and loss from unauthorised access. The protection of your personal information is part of our cyber security measures, which includes all the practices we have in place to protect computers, mobile devices and our network from malicious external attacks. Cyber security is an important operational aspect in today’s world and especially in our industry, which is continuously subject to cyber risk,  threats and challenges. Therefore, and in order to mitigate this risk, we have outsourced the management of our Information Technology, including cyber security, to an external Information Technology (IT) matter expert. This external consultant manages the Group’s IT environment on a daily basis and benefits from experience, knowledge and latest market insights to keep personal and corporate data safe.

Your personal information will be securely stored in an electronic environment, as we avoid storing hard copy information. With the exceptions detailed in this Privacy Statement, your information will only be available to employees of IPG and to our service providers on a need-to-know basis in order to perform their obligations and duties.

All our (and our data service providers’) servers are located in Australia.

What happens if personal information security is breached?

We implement corrective plans if we identify a breach of our security measures. For example, if your personal information has inadvertently been accessed by an unauthorised person or lost as a result of this unauthorised access. We will advise IPG FM’s Privacy Commissioner and you if we assess the data breach is likely to cause you serious harm.

How do you access your personal information and seek correction of it?

Should you wish to know what personal information the IPG Group holds on you, you may request to view this information by contacting our Privacy Officer:

Name:  Harley Kras

Address: IPG Funds Management Pty Ltd

Mobile nr: 0402 511 888

Email: privacyofficer@ipgeneration.com.au

The Privacy Officer will promptly investigate your privacy enquiry and provide you with appropriate answers where required. You may also contact the Privacy Officer if you have any questions on our compliance with the Privacy Act 1988 (Cth).

In case you discover that any information held is outdated, incorrect or incomplete you should request to have the personal information corrected and IPG staff will update your records accordingly. 

If your personal data changes during the life of the unregistered managed investment scheme, you need to contact IPG staff as soon as possible, so we can update your personal information you initially provided to us in the application form.

How can I complain about a breach of my privacy?

If you wish to make a complaint about our handling of your personal information you should contact the Privacy Officer using one of the above alternatives. If we cannot resolve your complaint, then you may raise your issue with the Office of the Australian Information Commissioner.

All privacy breaches that have resulted in or are likely to result in serious harm to any individual affected, are ‘eligible data breaches’, which must be reported by IPG FM to the Office of the Australian Information Commissioner.

To whom might it be disclosed?

Generally, Group members, including IPG FM, will only disclose your personal information for the purposes of providing financial products and services to you. As Group members may outsource investment management and administrative services to IPG under an Investment Management Deed, your personal information will be disclosed to related entities within the IPG Group. Personal information will also be disclosed to external third parties, where necessary to provide you with our financial products and services. These third parties may include government departments, regulatory authorities and law enforcement bodies, our auditors, insurers, banks, custodians, solicitors. It also extends to third-party IT services and administrators who assist us in the daily management of business operations, including managing client data.

We do not disclose personal information to overseas entities or persons.  

Is sensitive personal information collected?

IPG FM and the IPG Group will not collect sensitive personal information on clients. Sensitive personal information is information about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information, biometric information or biometric templates.

Notifiable Data Breaches

IPG FM is required to notify individuals and the Office of the Australian Information Commissioner about ‘eligible data breaches”. An eligible data breach occurs when the following criteria are met:

  • There has been an unauthorised access to, or disclosure of personal information held by us (or information is lost in circumstances where unauthorised access or disclosure is likely to occur). This is likely to result in serious harm to any of the individuals to whom the information relates.
  • We have been unable to prevent the likely risk of serious harm with remedial action.

We will conduct an assessment if it is not clear if a suspected data breach meets these criteria. The assessment will determine whether the breach is an ‘eligible data breach’ that triggers notification obligations.

Additional information

Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner (OAIC) at: http://www.oaic.gov.au/. We regularly review the OAIC website to keep informed of issues and developments in privacy law and changing legal obligations.