Privacy and Security Policy

This Privacy Policy applies to the activities of:

• Gresham Partners Limited
• Gresham Advisory Partners Limited
• Gresham Private Equity Pty Limited
• Gresham Funds Management Pty Limited
• Gresham Property Funds Management Limited
• Gresham Property Asset Management Pty Limited
• Gresham Partners Capital Limited
• Gresham Partners Group Limited
• Gresham Partners Holdings Limited
• Gresham Property Investments Pty Limited
• Gresham Nominees 1 Pty Limited
• Gresham Securities Pty Limited
• Gresham Capital Solutions Pty Limited
• Gresham Royalties Management Pty Limited
• Melsox Limited

 (together, Gresham)

This Privacy Policy explains how Gresham handles personal information and complies with the requirements of the Privacy Act 1988, including the Australian Privacy Principles (APPs).  If you have any questions relating to this policy, please e-mail privacy@gresham.au or contact Lauren Magraith or Danielle Denham on +61 2 9224 0217. 

Gresham recognises the importance of your privacy, and that you have a right to control how your personal information is collected and used.

1. Collecting information about you

Gresham may collect personal information from clients, employees, contractors, shareholders and other individuals.  Personal information Is information or an opinion relating to a natural person who is identified or reasonably identifiable. We collect this information when it is necessary for our business purposes.

The main types of personal information Gresham collects are names and contact details, such as addresses, telephone numbers and e-mail addresses.  In some circumstances, we are authorised by anti-money laundering laws, tax laws or the Privacy Act 1988 to collect other information about you, such as your securityholder reference number (SRN) or tax file number (TFN).  We may also collect information about your criminal record where this is necessary to comply with anti-money laundering laws.  

We collect most of this information directly from you where possible.  This information may be provided by you in forms you fill out, in face-to-face meetings, in e-mail messages you send us, via our website, or during telephone conversations.  In some cases we may collect your personal information from:

• publicly available sources of information, such as public registers, LinkedIn and other online networks or platforms;
• our service providers, such as credit reporting bodies and companies that provide fraud prevention reports or identity verification services;
• other organisations who, jointly with us, administer a Gresham managed fund;
• your agents and delegates, such as a broker, legal representative, persons holding a power of attorney; or
• a bank.

If you contact us, we may keep a record of that contact.

When you use our website, we may collect other information about you, such as your IP address and information stored in cookies. 

If you do not provide us with personal information we request from you, we may be unable to provide you with our full range of services.

2. Using and disclosing your personal information

Gresham’s purpose in collecting, holding, using and disclosing information about you is to provide you with information or services that you request and as otherwise set out in this Privacy Policy. 

In some cases, we may be required to disclose your personal information to regulators, such as AUSTRAC or the Australian Taxation Office.

We use service providers to help us maximise the quality and efficiency of our services and our business operations.  This means individuals and organisations outside of Gresham, such as mail houses and IT service providers, such as website hosts and back-up service providers, will sometimes have access to personal information held by Gresham and may use it on behalf of Gresham.  We require our service providers to adhere to strict privacy guidelines and only use this information for authorised purposes.

Gresham may also disclose personal information to one or more third parties located outside Australia (such as in the United States) or that have overseas or cloud-based data access or storage, with whom it has a business relationship. By providing your personal information, you will be deemed to have provided your consent to the disclosure of your personal information to entities located outside of Australia and to have acknowledged that Gresham is not required to take reasonable steps to ensure that an overseas recipient does not breach the Australian Privacy Principles and Gresham may not be liable under the Privacy Act if the recipient does not act consistently with the Australian Privacy Principles.

Gresham will otherwise only use or disclose personal information about you:

• in accordance with this Privacy Policy;
• for any other purpose communicated to you at or near the time your personal information is collected;
• as permitted or required by law;
• if we believe it necessary to provide you with a service you have requested;
• to implement our terms of service;
• to protect the rights, property or personal safety of another Gresham client, any member of the public or Gresham;
• if some or all of the assets and operations of the business are or may be transferred to another party by way of sale of some or all of the business; or
• if you have provided your consent.
  
  

3. Employee information

Employee records are not generally subject to the Privacy Act, and therefore this Privacy Policy does not apply to the handling of information about employees by Gresham.  For information about our practices relating to employee information, please contact us directly.

4. Job applicants

If you apply for a job at Gresham, we may collect personal information from you or from recruitment agencies for the purpose of assessing and processing your application.  This information may include your name and contact details, information about your previous and current employment, and other information relating to your suitability for employment.  In some circumstances and if you consent, Gresham may collect sensitive information about you, such as information about your health, membership of a professional or trade association, or criminal record, where appropriate and where this is reasonably necessary for one of our functions or activities. 

5. Marketing

When you provide your personal information to us, we may use this information, such as your email address or telephone number, to contact you on an ongoing basis in order to:

• provide you with updated information about our products and services; or
• provide you with information about other products and services which you may have an interest in.

If you are receiving promotional information about Gresham and do not wish to receive this information any longer, you may remove your name from our mailing list either by e-mailing us at privacy@gresham.au or calling us on +61 2 9224 0226 and asking to be removed from our mailing list.

6. Our website privacy practices

We sometimes use cookie technology on our website to provide information and services to website visitors.  Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes and are a necessary part of facilitating online transactions.  Most web browsers are set to accept cookies.  Cookies are useful to estimate our number of members and determine overall traffic patterns through our website.

If you do not wish to receive any cookies you may set your browser to refuse cookies.  This may mean you will not be able to take full advantage of the services on the website.

For the purposes of viewing certain parts of our website, you may be required to provide log-in information.  You are responsible for the security and confidentiality of this information.  

If our website contains links to other websites outside of the Gresham site, these linked sites are not under the control of Gresham and we are not responsible for the conduct of the companies that operate these linked sites.  Before disclosing your personal information on any other website, we recommend you review the terms and conditions of that site. 

7. Gresham Licensees

The following members of Gresham (each a Licensee) hold an Australian financial services licence (AFS licence):

• Gresham Advisory Partners Limited (ABN 88 093 611 413) (AFS Licence no. 247113)
• Gresham Partners Capital Limited (ABN 62 003 004 279) (AFS Licence no. 247110)
• Gresham Property Funds Management Limited (ABN 37 092 191 270) (AFS Licence no. 247112)

A Licensee may be responsible for issuing certain material, as indicated on this website or document (as applicable) in which that material appears.

Wholesale clients only

No Licensee provides financial services or financial products to “retail clients” within the meaning of the Corporations Act 2001 (Cth) (Corporations Act).  The material presented on this website or document (as applicable), is intended solely for use by “wholesale clients” within the meaning of the Corporations Act.

Investment risk, past performance information and prospective financial information

An investment in a Gresham investment fund is subject to investment risk, including loss of principal invested and income.  No member of Gresham guarantees the capital value or performance of any Gresham investment fund. 

Past performance is not a reliable guide to future performance.

This website or document (as applicable) may contain prospective financial information, such as forecasts, projections or target returns.  Such information is predictive in character, may be affected by inaccurate assumptions or by known or unknown risks and uncertainties, and may differ materially from results ultimately achieved.

General information only

This website or document (as applicable) is intended to provide general information only and has been prepared without taking into account any person’s objectives, financial situation or needs.  Before acting on any material on this website or document (as applicable), you should therefore consider the appropriateness of the material having regard to your objectives, financial situation and needs.  You should also seek investment, tax, legal and any other appropriate professional advice.

For Australian residents only

This website or document (as applicable) is intended only for use by persons accessing or obtaining it from Australia.  Applications to invest in any Gresham investment fund will only be accepted from Australian residents unless the relevant offer document expressly states otherwise.

8. Storage and security of your personal information

Gresham will endeavour to take all reasonable steps to keep secure any personal information which we hold about you, and to keep this information accurate and up-to-date.  Your information may be stored in hard-copy or electronically.  Any information we hold electronically is stored on secure servers that are protected in controlled facilities.  We require our employees and data processors to respect the confidentiality of any personal information held by Gresham.

No data transmission over the internet can be guaranteed to be 100% secure, so Gresham cannot give an absolute assurance that the information you provide to us via the internet will be secure at all times.  

9. You can access the information we keep about you

If at any time you want to know what personal information we hold about you, you are welcome to request access to your record by e-mailing us at privacy@gresham.au.  Our file of your information will usually be made available to you within 14 days.

10. Correcting or deleting the information we have about you

If at any time you wish to correct or delete your personal information we hold about you that is inaccurate, out-of-date, incomplete, irrelevant or misleading, please contact us by e-mailing us at privacy@gresham.au and we will amend this record unless there is a reason why we cannot amend it.  

If you wish to have your personal information deleted, please let us know using the e-mail address above and we will take all reasonable steps to delete it unless we need to keep it for legal, auditing or internal business reasons. 

If you wish to make changes to your SRN or TFN, please contact us at privacy@gresham.au so we can assist with this process.  

11. What to do if you have a complaint or question

You may contact us by e-mailing us at privacy@gresham.au if you have a complaint about a breach of the APPs or any privacy code which may bind us or how we have handled your personal information. 

If Gresham becomes aware of any ongoing concerns or problems concerning our privacy practices, we will contact you about the issue, investigate the issue, and take all reasonable steps to work with you to resolve the issue. If you are dissatisfied with the response that you receive from us, you may make a complaint to the Office of the Australian Information Commissioner (OAIC).