Privacy Policy

Protection of your personal information is important to us at Foundation Funds Management Ltd, Stronghold Investment Services Pty Ltd and our Authorised Representatives (together referred to as “Stronghold” or “we”, “us” or “our”). We are committed to respecting your right to privacy and protecting your personal information. This policy has been drafted having regard to our obligations under the Privacy Act 1988 and the National Privacy Principles.

Personal information is any information about you that makes you reasonability identifiable. It may include your name, address, phone number, date of birth and other information about you, but sometimes it will include broader information about you.

To deliver financial services, we must identify you and hold records with personal information that is consistent with any identification documentation we have been required to validate.

Due to the nature of the services we provide, we are unable to accommodate anonymity or the use of a pseudonym beyond initial, general enquiries about the organisation.

Who the policy applies to?

This privacy policy applies to websites and applications on electronic devices such as mobile phones and tablets managed by us in Australia.

It applies to any individuals in respect of whom we may collect in the future and personal information. This policy describes the personal information we collect, and how we use and handle that personal information.

By using our websites and applications on electronic devices and providing your personal information to us, you agree to the terms of this policy, and the collection and use of the personal information provided to us as set out in this policy.

We may amend this Privacy Policy from time to time and without notice.

If we decide to change our policy, we will post any new terms on this page so that you can always be aware of how we collect, use and handle your personal information.

The information we collect

To administer your financial products or interest in our products we are required to collect your personal information.

We may collect and hold personal information about you if you are an individual or one of the following individuals in relation to:

• company: the directors and shareholders of that company;
• partnership: the partners;
• sole trader: the sole trader; or
• trust: the trustee and beneficiaries.

We primarily collect your personal information directly from you, for example through the application process, telephone calls and written correspondence.

The personal information that we collect directly from you may include:

• information we use to identify you such as your name, date of birth, phone number and residential address;
• financial information about you such as bank account details;
• information about your source of earnings;
• social media information about you; and
• other information we request in relation to the provision of our products.

We may also collect personal information about you from third parties and from publicly available information.

At or soon after the time that we collect personal information, we will take reasonable steps to ensure that the person is aware that we have undertaken the collection, the purpose(s) of the collection, the main consequences (if any) if the information is not collected, the types of organisation (if any) to which the information may be disclosed (including those located overseas), any law that required the particular information to be collected, and the fact that this policy contains details on access, correction and complaints.

We may also use cookies to collect statistics on the performance of websites (see below). If you do not wish to share this information, you should adjust the settings of your browser to refuse cookies completely or to notify you each time a cookie request is received.

If we receive personal information which we have not requested from you (unsolicited information) and we determine that we could not have collected that information lawfully under Australian privacy law if we had requested it, then we will destroy or de-identify the information so far as it is lawful to do so.

You have the option to not identify yourself (or to use a pseudonym) when dealing with us. However, if you do, it may be impractical for us to deal with you and we may elect not to do so.

We do not collect sensitive information about you. And will not make a record of sensitive information even if it is disclosed to us.

What happens if you don’t provide information

If you don’t provide your information to us that we are entitled to request under the law, it may not be possible for us to consider a request you make or provide products to you, and we may choose not to do so.

Also, you are not obliged to provide some information such as a tax file number, but there may be financial consequences where this information is not provided.

Purpose of Collecting Personal Information

We collect, hold, use and disclose personal, information to third parties primarily to assess whether to offer our financial products to you and in the ongoing management of your investment.

We may also use your information as permitted or required by law and government agencies.

We are also required to collect your personal information to comply with our obligations under Australian law, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

We may use your information for purposes relating to:

• processing requests you make;
• managing and better understanding our relationship with you including tracking and making payments due to you;
• managing our relationship with financial institutions;
• identifying opportunities to improve our service to you and improving our service to you;
• allowing us to run our business efficiently and to perform administrative and operational tasks;
• preventing or investigating any fraud or crime or any suspected fraud or crime;
• assisting in improving industry standards relating to financial products;
• telling you about other products or services we or our related companies make available and that may be of interest to you, unless you tell us not to;
• as required by law, regulation or codes binding us; and
• any purpose to which you have consented.

We may disclose information to our related companies or our related entities. We will only disclose an individual’s information in accordance with the Privacy Act 1988 (Cth).

We may exchange personal information with the following types of entities, some of which may be located overseas. The types of entities include:

• finance brokers, mortgage managers, and persons who assist us to provide our products to you;
• any person or entity who represents you including financial consultants, accountants, lawyers, mortgage brokers, persons holding power of attorney, guardians and advisers;
• any industry body, government authority, tribunal, court or otherwise in connection with any complaint regarding the approval or management of your lease or loan – for example if a complaint is lodged about us;
• agents or advisers, trustees, ratings agency or businesses assisting us with providing you with our financial products;
• where we are authorised to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), government and law enforcement agencies or regulators;
• entities to whom we outsource some of our functions or that provide information and infrastructure systems;
• auditors, insurers and re-insurers;
• any person where we are required by law to do so or where you have provided us consent;
• any person considering acquiring an interest in our business or assets;
• associated businesses that may want to market products to you;
• any organisation providing online verification of your identity.

Marketing Activities

We engage in direct marketing and may, from time to time use your personal information to inform you of investment opportunities about our products and services. This may also include disclosing your information to companies outside Stronghold who help us market our products and services.

If you do not wish to receive direct marketing material, you may decline to receive such material by using the unsubscribe option in emails or if more appropriate, by contacting our Privacy Officer on the contact details below. You may also contact any other point of contact you have with Stronghold.

Other than investor personal information, we may retain records of interactions with current and prospective investors. This data is managed in line with this Privacy Statement, is housed in a Customer Relationship Management system (CRM) and may be analysed by the third party providers we engage.

Personal information provided by prospective investors may be used for direct marketing. They may opt out of marketing correspondence by using the unsubscribe option in emails or by contacting our Privacy Officer on the contact details below. You may also contact any other point of contact you have with Stronghold.

Cookies and pixels

A cookie is a small file placed in your web browser that collects information about your web browsing behaviour. Use of cookies allows a website to tailor its configuration to your needs and preferences. Cookies do not access information stored on your computer or any personal information (e.g. name, address, email address or telephone number). Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. This may, however, prevent you from taking full advantage of our website.

A pixel is a snippet of code added to the code of a website in order to gather information, similar to a cookie.

Our website uses cookies to analyse website traffic, provide social media sharing and linking functionality and help us provide a better website visitor experience. In addition, cookies and pixels may be used to serve relevant ads to website visitors through third party services such as Google Adwords and Facebook Adverts. These ads may appear on this website or other websites you visit.

How do we protect your personal information?

Whenever it is reasonable and practicable to do so, we will collect information about you directly from you. In certain cases we collect your personal information from third parties. For example, we may need to collect personal information from a credit reporting agency, your representative (such as a legal adviser), your financial adviser, your employer or publicly available sources of information.

We hold personal information in both physical and digital formats. Your personal information held in a digital format is protected from unauthorised access through the use of secure passwords, user log-ons or other security procedures. We regularly review our security of digital information. Personal information is only used in a physical format if strictly necessary and has appropriate processes restricting the physical access to these investor files.

We will only grant access to your personal information where you have specifically stipulated this (for example you have a nominated financial planner or legal representative) or we are required to do so by law. Where investments are held jointly, by a trust which you are beneficiary of or by a business you are director of, we may disclose information about you or your investment to other parties associated with this legal entity during the course of administering your investment.

Cross Border Disclosure

We may disclose your personal information to overseas entities including related entities and service providers located overseas. Overseas entities may be required to disclose information to relevant foreign authorities under a foreign law. More information on overseas disclosure may be found in the entities’ privacy policies. Whilst we attempt to select and secure reputable offshore service providers, we are not liable for any breach or misuse of information sent offshore. An overseas entity may not be subject to privacy laws or principles similar to those which apply in Australia, and any information disclosed to an overseas entity may not have the same protection as under the Australian Privacy law. You may not be able to seek redress for any breach of your privacy which occurs outside of Australia.

Keeping information accurate and up to date

If you feel the information we have about you is inaccurate, out of date or incomplete please they can be updated in the Investor Portal or by contacting the Privacy Officer on the below contact details to have it updated. You may also contact any other point of contact you have with Stronghold.

Contacting us and accessing your personal information

You may access the personal information about you held by us, except in limited circumstances. You can contact us to request access to your information. In normal circumstances we will give you full access to your information.

We will provide you with the information unless:

• the request is frivolous or vexatious;
• providing access would have an unreasonable impact on the privacy of another person;
• providing access would pose a serious and imminent threat to the life or health of any person;
• providing access would prejudice our legal rights; or
• there are other legal grounds to deny the request.

Data Retention

Stronghold retains personal information and customer records for time frames in line with our requirements under Financial Services Laws and Regulations as well as the Anti-Money Laundering and Counter Terrorism Act. This means that we will keep records for a minimum of 7 years after our relationship with you ceases and can not accommodate requests to completely destroy or deidentify all records of your investment during this time.

Where you have not made an investment with us, we will periodically review your details for ongoing relevance to remain on file and destroy records when we become aware that they are out of date, or you request that they be destroyed.

Requests, Complaints and further information

If you have comments about our privacy practices or if you think we have breached your privacy rights or if you simply want to know more about our privacy practices, you can contact us by writing to:

The Privacy Officer
Stronghold Investment Services Pty Ltd
PO Box 3355 Darra, QLD 4076

Or email us on: privacy@strongholdinvest.com.au

In order for us to investigate the complaint, you will need to provide us with sufficient details as well as any supporting information. We will acknowledge your complaint in writing within 7 days, conduct an investigation and notify you in writing within a reasonable time (usually 30 days from the date on which the complaint was made) about the outcome of our investigation. If you would like more information about the privacy laws, you may contact:

The Privacy Commissioner:

Office of the Federal Privacy Commissioner
GPO Box 5218, Sydney NSW 2001
Phone: 1300 363 992
Website: www.oaic.gov.au

Updates to this Policy

Our privacy statement will be provided to you when you invest with us, published on our website and Investor Portal and, where updated, we will make you aware of how you can access an updated policy via our routine communications.

“This Stronghold Privacy Policy has been updated and is current as of 9 August 2023.”