1. Introduction & 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 and infrastructure. 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 is a member of the Responsible Investment Association of Australasia.
2. Our Commitment to Privacy
This Privacy Statement relates to IIG and its subsidiaries (IIG Group).
In this policy, "us", "we" or "our" means IIG and its related bodies corporate within the IIG Group.
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 1998 (Cth) (Privacy Act). These principles govern how organisations handle personal information.
This Privacy Statement 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 from you can include your name, contact details (such as your address and telephone number), date of birth, individual investment details, bank account information and tax file number.
The Corporations Act 2001 (Cth) requires us to collect your 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.
4. Personal Information Security
We regard the security of your personal information as a priority and have a number of physical and electronic protection measures in place. Please be aware that the Internet is not a secure environment hence no personal data is stored on our public website.
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 products and services. Collection of your personal information allows us to identify you and assess applications for your investment in our Schemes. This includes:
checking whether you are eligible for the product or service;
verifying your identity;
helping to manage the product or service;
managing relationships with our clients;
providing our clients with information about our products, services, the markets and developments that may interest them; and
facilitating our internal business operations, including to fulfil our legal requirements.
Your personal information will also be used for related purposes which include, the administering and ongoing management of your investment, communication with you and compliance with Australian taxation laws, the Corporations legislation, the AML/CTF Act and other laws and regulations.
Throughout the life of the investment product or service, we may collect and hold additional personal information about you. This may include transaction information or making a record of queries or complaints you make. 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).
We take steps to ensure that our agents and third parties(e.g.: consultants, advisors and partners)keep your personal information confidential and use it only for the purposes for which they, and the IIG Group are authorised.
You may also authorise us to disclose information to other persons nominated by you. These persons may include accountants, financial planners and investment managers. Your express consent is required in these circumstances. We reserve the right to contact you directly pursuant to our statutory obligations under the AML/CTF Act.
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 Schemes or talk to us in person or on the phone.
Sometimes we collect personal information about you from other people or organisations. This may happen without your direct involvement, but as referred to above, your express consent will be required. For example, we may collect personal information about you from:
- your representatives (including your legal or financial adviser, administrator, trustee, or attorney); and
- other organisations, who jointly with us, provide products to you.
7. Disclosure of your Personal Information
We may disclose personal information for the purposes for which it was collected to:
- our staff within the IIG Group;
- our professional advisors including financial advisors, legal advisors, auditors and consultants;
- our agents, contractors and external service providers;
- Authorised Representatives on our AFSL who sell products on our behalf;
- 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 out-sourced back-office providers. The privacy standards of these providers must be at least in accordance with ours.
No personal information that we receive is disclosed by us to recipients based outside of Australian territory.
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. However, we recommend 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.
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 let you know 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.
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:
Address: Impact Investment Group
11 Princes Street
St Kilda Vic 3182
Telephone: (03) 8534 8060