PRIVACY POLICY

1. Introduction

Zone Q Investments Pty Ltd ACN 164 606 811 ("Zone Q") is subject to the Australian Privacy Principles contained in the Privacy Act 1988 (“Privacy Act”) and any relevant privacy code registered under the Privacy Act.

The purpose of this Policy is to describe how Zone Q complies with the privacy requirements in protecting the personal information Zone Q holds about individuals. This Policy is applicable to Zone Q and its controlled entities who collect “personal information” in Australia (collectively referred to as "Zone Q" below).

2. Personal Information

When using this Privacy Policy, the term “personal information” has the meaning given to it by the Privacy Act. In general terms personal information is defined as information or an opinion that can identify or can reasonably identify an individual.

3. Collection of Personal Information

Zone Q operates multiple business functions and activities. The type of personal information that Zone Q collects will depend upon what dealings the relevant individual may have with Zone Q. Zone Q may collect and hold information about:

  • (a)  purchasers or potential purchasers (for example, when purchasing a Zone Q product or service, or when responding to requests for information about a Zone Q product or service (including information associated with the use of Zone Q website portals and related applications));
  • (b)  lessees, potential lessees and other individuals related to lessees, including guarantors (for example, when enquiring about a premises or negotiating the terms of a lease or licence for a premises to which Zone Q has an affiliation);
  • (c)  suppliers (for example, when establishing records and systems to enable payment for goods or services);
  • (d)  employees and job applicants (for the purposes of employment);
  • (e  individuals as contractors (for example, when establishing records and systems to enable payment for services);
  • (f)  individual investors in our investment vehicles (for example, when establishing accounts and to carry out due diligence);
  • (g)  individuals as shareholders in Zone Q;
  • (h)  other individuals who may come into contact with Zone Q.

Zone Q only collects personal information which is reasonably necessary for its dealings with the relevant individual. The types of personal information may include, but are not limited to:

  • (a)  information that identifies the individual (for example, name, address, contact details,date of birth);
  • (b)  information about the individual's financial position;
  • (c)  information about the individual that is required or authorised by law;
  • (d)  the individual's tax file number;
  • (e)  the individual's opinion about Zone Q’s products, services or staff.

The Privacy Act imposes restrictions on collecting sensitive personal information (this includes information about religious views, ethnicity, political opinions, personal health information). Zone Q generally does not collect sensitive personal information about an individual. However, in certain circumstances, Zone Q may collect some sensitive information if it is necessary to allow Zone Q to deal with the individual and the individual has provided consent for Zone Q to do so. Whenever it is reasonable and practical to do so, Zone Q only collects personal information directly from the individual. In some circumstances, personal information may be provided to Zone Q by other parties such as the individual's agent and/or professional advisor(s). Zone Q will take reasonable steps to inform the individual that it has the individual's personal information, unless it is obvious from the circumstances.

Click here to download the Privacy Collection Notice PDF

4. Use and Disclosure of Personal Information

Zone Q operates a number of businesses which handle personal information. Zone Q's policy is only to use personal information for the purpose which was either specified or reasonably apparent at the time when the information was collected. Zone Q may also use or disclose the information collected for any other related purpose for which the individual would reasonably expect it to be used.

If Zone Q wishes to use or disclose the personal information in other circumstances, it needs to obtain the individual's consent to do so.

In general, Zone Q uses personal information for the following purposes:

  • (a)  providing products, services or investment opportunities that have been requested, access to protected areas of any website, including associated website portals and applications controlled or operated by Zone Q;
  • (b)  communicating with the individual;
  • (c)  helping Zone Q manage and enhance its products and services, including analysing customer feedback and future customer needs;
  • (d)  providing ongoing information about Zone Q products, services or investment opportunities to individuals that Zone Q believes may be interested;
  • (e)  conducting business processing functions including providing personal information to entities controlled by Zone Q, contractors, service providers or other third parties;
  • (f)  complying with regulatory and legal obligations;
  • (g)  recruiting of employees and contractors.

5. Disclosing Information to Other Parties

Personal information may be disclosed by one Zone Q group entity to another Zone Q group entity. External plude, but are not limited to:

  • (a)  Zone Q's contractors and service providers who assist Zone Q in the operation of its business or to provide a customer service (for example, professional advisors, or a company which helps maintain Zone Q's computer systems or sends out Zone Q's mail);
  • (b)  joint venture partners, including for the purposes of seeking relevant regulatory approvals;
  • (c)   third party lenders and insurers;
  • (d)  the Australian Securities and Investments Commission and to other government agencies as agreed to or required by law;
  • (e)  anyone authorised by a provider of personal information;
  • (f)  relevant parties in situations when Zone Q is required by law to provide the information.

Zone Q limits the information disclosed to external parties to what is required for them to perform their services for Zone Q or the relevant individual, or what is required by law. Zone Q requires these parties to agree to Zone Q's Privacy Policy and to strict conditions governing how this information may be used and stored.

Zone Q may sometimes disclose personal information overseas to allow external parties to perform their services for Zone Q but Zone Q will only do so in accordance with the Australian Privacy Principles.

Zone Q does not sell personal information to entities outside Zone Q.

6. Marketing

Zone Q may send marketing materials to its customers or investors or potential customers or investors where Zone Q has collected the personal information from the individual and the marketing material is related to the purpose for which the information was collected.

The individual's prior consent will be obtained before personal information is used for marketing purposes in situations where the personal information has not been collected directly from the individual or where sensitive information is involved.

If the customer or investor no longer wishes Zone Q to use his or her personal information in order for Zone Q to provide marketing materials, the customer or investor is to advise Zone Q via the relevant method provided for in the electronic marketing message sent to the customer or to the email address infozq@zoneq.com.au. Zone Q will act and amend its records promptly.

7. Cookies

A cookie is a small data file that may be placed on the computer of a web user (usually in the browser software folder) during a visit to a Zone Q web site. Cookies are necessary to allow the Zone Q web site and the user's computer to interact effectively and enhance security. Cookies can record information about the user's visit to assist Zone Q in better understanding the needs of the user. If users of a Zone Q website do not wish to receive any cookies, they should set their browser to refuse cookies but this means that they may not be able to use the Zone Q website.

8. Applying for Employment with Zone Q

Zone Q collects personal information from individuals who submit applications or register interest for employment with Zone Q. If the application is unsuccessful, Zone Q may retain the information in case a more appropriate opportunity becomes available. The unsuccessful applicant will be advised that he or she can contact Zone Q to request Zone Q not to retain the applicant's information.

9. Security of Personal Information

Zone Q will take reasonable steps to protect personal information that it holds from unauthorised access, modification, misuse, interference and loss. Personal information is held on secure servers or in storage located in controlled environments. Zone Q employees are required to maintain the confidentiality of any personal information held.

If other parties provide support services, Zone Q requires them to agree to appropriately protect the privacy of the information provided to them.

10. Notification of Collection of Personal Information

When Zone Q collects personal information, Zone Q provides notification of the collection to the individual to inform the individual about the purpose for the collection, the types of entities that the information is disclosed to, the overseas recipients the information is disclosed to (where applicable), and that Zone Q Privacy Policy contains information about how the individual may access the personal information held by Zone Q and how the individual may make a complaint.

11. Access to Personal Information

Any individual can request access to the personal information Zone Q may hold about them. To obtain access to the information, the individual needs to write to Zone Q at infozq@zoneq.com.au. Zone Q will require evidence to verify the identity of the individual.

This service is free of charge unless the personal information requested requires preparation time. In this situation, Zone Q will provide an estimate of how much this service will cost and request agreement before proceeding.

In normal circumstances, Zone Q will provide the individual with access to the individual's personal information. However, in some circumstances, there may be legal, regulatory or administrative reasons to deny the requested access. If access is denied, Zone Q will provide the individual with the reason.

12. Changing Personal Information

If an individual wishes to update personal information that the individual believes may be inaccurate, out-of-date, incomplete, irrelevant or misleading, the individual may write to Zone Q at infozq@zoneq.com.au requesting the information to be updated or deleted.

13. Changes in the Future

Zone Q reserves the right to change this Privacy Policy at any time. Zone Q will notify any changes by posting an updated version of the Policy on the Zone Q website at infozq@zoneq.com.au

14. Complaints

An individual can make a complaint about the way in which Zone Q has handled an individual's personal information by writing infozq@zoneq.com.au Zone Q will endeavour to act promptly in response to a complaint.

15. Data Breach

If Zone Q have reasonable grounds to believe an eligible data breach (as defined by the Privacy Act) has occurred, Zone Q will notify the Privacy Commissioner and take reasonable steps to notify affected individuals in accordance with the Privacy Act.

16. Additional Information on Privacy

For further information about privacy issues and the protection of privacy, visit the Office of the Australian Information Commissioner's website at http://www.oaic.gov.au.

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