Privacy statement

1. Background

Impact Investment Group Pty Ltd ACN 139 328 108 (IIG or the Company) is a leading Australian Impact Investment fund manager, advisor and co-investor. Established in early 2013, IIG has originated investments in commercial real estate, renewable energy infrastructure and venture capital. IIG believes that values-aligned investment can be sustainable and profitable for all stakeholders. IIG is an early adopter of Impact Investing principles and is regarded as a thought leader in the emerging Australian Impact Investment space. IIG originates and transacts on investments which generate financial performance with sustained environmental and social impact. IIG regularly reports to its investors on the financial, social and environmental returns generated by its assets.

IIG is one of Australia’s first certified B Corporations and believes in using the power of business to drive positive social and environmental change. As a B Corporation, IIG has met high standards of transparency, governance and accountability assessed by the B Lab international standards committee. IIG has been a member of the Responsible Investment Association of Australasia since 2015.

2. Our Commitment to Privacy

This Privacy Policy relates to IIG and its related bodies corporate (IIG Group, we,us). We recognise an individual’s right to privacy and understand that the protection and confidentiality of your personal information is important to you.

We have practices in place to comply with the 13 Australian Privacy Principles set out in The Privacy Act 1988 (Cth) (Privacy Act). These principles govern how organisations handle personal information. This Privacy Policy outlines the types of personal information we collect, how that information is collected, used, stored, and protected and to whom we may disclose personal information.

3. The Types of Personal Information That We Collect

Personal information is information or an opinion about an identified, or reasonably identifiable individual.

The types of personal information that we may collect about you can include your name, contact details (such as your address and telephone number), date of birth, identification, individual investment details, bank account information and tax file number. 

Throughout the life of your investment product, we may collect and hold additional personal information about you. This may include transaction information or recording your queries and/or complaints. We may also collect personal information about individuals who are not clients of the IIG Group (e.g. business contact details of a company representative with whom we deal) but who represent or act as intermediaries on behalf of IIG clients.

The Corporations Act 2001 (Cth) requires and authorises us to collect personal information in certain circumstances, and this may include name, address and date of birth. Pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act) we are also required to collect additional personal information from you to verify your identity, including, for example, your primary identification documents.

4. Personal Information Security

We regard the security of your personal information as a priority and we have a number of physical and electronic protection measures in place. Depending on the circumstances, this may include system access controls, building security, network firewalls and steps to ensure that our agents and third parties (e.g.: consultants and advisors) keep your personal information confidential and use it only for the purposes for which they, and the IIG Group are authorised.

5. For What Purposes Do We Collect, Hold, Use and Disclose Your Personal Information?

We collect, use, hold and disclose your personal information for the purpose of providing you with our investment products and services. Collection of your personal information allows us to identify you and assess your application for investment in our managed investment schemes. Our purposes for handling personal information also include:

  • Determining whether you are eligible for the product or service;
  • Verifying your identity and information;
  • Communicating with you about the product or service;
  • Maintaining and updating our records;
  • Managing our relationship with you;
  • Providing you with information about our products, services, and business development over time;
  • Facilitating our internal business operations, including fulfilment of our legal and compliance obligations; and
  • Facilitating any sale or potential sale of our business.

We reserve the right to contact you directly pursuant to our statutory obligations under the AML/CTF Act.

We may not be able to do the things described above without your personal information. For example, we may not be able to communicate with you or consider your application.

6. How Do We Collect Your Personal Information?

We collect most personal information directly from you. For example, we will collect your personal information when you apply to invest in one of our managed investment schemes or when we communicate with you either in writing, by phone or in person.

Sometimes we collect personal information about you from other people or organisations, including for purposes related to verifying your identity or otherwise complying with our obligations under the AML/CTF Act. For example, we may collect personal information about you from:

  • your representatives (including your legal or financial adviser, administrator, trustee, or attorney) who you have nominated on your application form as the appropriate contact persons in relation to your investment(s);
  • financial intermediary organisations;
  • other organisations, who jointly with us, provide products to you;
  • trusted third party service providers that assist us to meet our statutory obligations
  • publicly available sources; and
  • the parties to whom we disclose personal information as set out below.

7. Disclosure of your Personal Information

We may disclose personal information to:

  • our staff and other companies within the IIG Group;
  • our professional advisors including financial advisors, legal advisors, auditors and consultants;
  • our agents, contractors and external service providers;
  • Authorised Representatives who sell products on our behalf;
  • Responsible Managers of our products and services for compliance purposes;
  • other organisations, who jointly with us, provide products or services to you;
  • your representatives (including your legal or financial adviser, accountant, trustee, or attorney); and
  • fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct.

We may also disclose your personal information to service providers, such as providers of IT, payment, delivery, data analysis, research, investigation and insurance services.

From time to time some of our service providers or contractors may be based in other countries such as in the United States.

8. Accessing or Correcting Your Personal Information

You may contact us to request access to the personal information we hold about you at any time. You may also ask us to correct information about you that you may believe is inaccurate, incomplete or out of date.

We will need to verify your identity before giving you access to, or correcting your information.

In certain circumstances, we may not be able to correct or provide you with access to your information. In these circumstances, we will write to you to explain and provide the reasons as to why access cannot be granted.

We take all reasonable precautions to ensure that the personal information that we collect, use and disclose is accurate, complete and current. We require that you advise us if there are any errors in your personal information and that you update us on any changes to your personal information such as changes of name, address or bank account details.

If we receive a request to update your personal information we will undertake the following identification verification procedure:

  • If the request is received in writing, we will contact the nominated contact person for the client as per our records to verify that the written request was authorised by the client. We will do this even if the written request appears to have come from the client directly. Once we receive verbal confirmation from the nominated contact person, we will respond to the request accordingly.
  • If the request is received verbally, but not from the nominated contact person for the client, we will contact the nominated contact person to verify that the verbal request is authorised by the client.

Only once the relevant process outlined above has taken place, will we proceed to update our client records.

9. Resolving Your Privacy Concerns & Complaints

If you have a query or a complaint regarding your personal information, please contact us (contact details provided below).

We will acknowledge your complaint within 10 business days of receipt of your complaint. We will inform you if we need any further information from you to resolve your complaint. We aim to resolve complaints as quickly as possible.

If a complaint remains unresolved, you may apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. The Commissioner may be contacted on the privacy hotline: 1300 363 992.

Contact details

If you have any questions about this Privacy Statement, or wish to make a complaint about how we have handled your personal information, please contact the Privacy Officer:

Email: privacy@impact-group.com.au

Address: Impact Investment Group

11 Princes Street

St Kilda Vic 3182

Telephone: (03) 8534 8060

Last Review Date: June 2017