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Introduction
VanEck Investments Limited (ACN 146 596 116) and VanEck Australia Pty Ltd (ACN 137 160 528) (together referred to as ‘VanEck Australia’, ‘we’ and ‘us’) are committed to managing your personal information privately and transparently.
This Privacy Policy explains how we collect, use and handle your personal information.
In this Privacy Policy, references to ‘you’ and ‘your’ are to you as an investor in our funds, or otherwise as an individual from whom we collect personal information.
VanEck Australia is bound by the Australian Privacy Principles and the Privacy Act 1988 (Cth) (‘Privacy Act’). These govern how Australian organisations handle personal information.
Our office is located at Level 47, 25 Martin Place, Sydney NSW 2000. If you have any questions about this policy please email privacy@vaneck.com.au or call investor services on 1300 68 38 37.
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Information we collect
We will collect information about you to help us provide financial services and products to our investors. How we do this will depend on how you engage with us. For example, we will collect information about you when you:
- contact us through e-mail;
- request or register for marketing material;
- contact the Registrar with questions, who then passes these questions on to us; or
- complete a survey or poll or enter a competition or other promotion.
VanEck Australia has appointed Link Market Services Limited (‘Link’) as the registrar of our exchange traded funds (‘ETF’). Your personal information will be collected by Link when you purchase shares in any of our ETF’s. The manner in which Link handles your personal information is subject to their privacy policy, available on their website.
What personal information do we collect?
Personal information is defined in the Privacy Act and includes information or an opinion about an identified individual, or an individual who is reasonably identifiable. Common examples of personal information include your name, email address, date of birth and bank account.
There are two types of information referred to in this policy: personal information and sensitive information. We do not intend on collecting sensitive information about investors or future investors. Any sensitive personal information we do collect will be dealt with compliantly with the Privacy Act and this Privacy Policy.
Sensitive information is a subset of personal information that includes information or opinion about an individual’s racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record, health or genetic information and some aspects of biometric information. References to personal information in this policy include sensitive information.
We would collect personal information which enables us and our service providers to perform our functions and activities. The information we do collect may include your personal information, such as your:
- Name;
- Title or primary role;
- Company name;
- Contact/postal address;
- E-mail address;
- Phone, mobile and/or fax number;
- Investor type (individual, financial adviser, institutional);
- Personal photo identification (such as passport and drivers license details); and/or
- Areas of interest
If you are an employee or a job applicant, we may collect your personal information to administer your employment or process your application, those may include your qualifications, residency and visa status, medical records, health information and results from record checks.
Where appropriate and necessary, we may also collect personal information about other individuals from you, which may include your spouse, partner, dependents, emergency contacts, business representatives, company directors and shareholders. We would rely on you to inform them that their personal information is being provided to us and that they can contact us for further information.
Cookies and related tools
A cookie is a small text file placed on your computer which tracks your use of a website.
VanEck Australia or its service providers may use ’cookies’, web server logs, web beacons, or other electronic tools to collect information such as your:
- IP address;
- browser type;
- operating system;
- computer platform;
- mobile device details; and
- geo-location data.
VanEck Australia or its service providers may also use cookies, web server logs, web beacons, or other electronic tools to collect and compile statistical and other information about your use of our Website and the services provided on our Website, such as:
- the web pages you visit on our Website;
- the date and time of your visit;
- the number of links you click within our Website;
- the functions you use on our Website;
- the databases you view and the searches you request on our Website;
- the data you save on, or download from, our Website, etc; and
- the websites you visited immediately before and after visiting our Website.
Managing cookies
Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web.
If you use multiple browsers (e.g. AOL, Safari, Internet Explorer, Firefox, etc.) you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g. work and home) you need to set each browser on each device.
If you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of our Website, such as certain areas for which you need to log in, will not function properly, and the advertising you receive when you visit our Website may not be advertisements tailored to your interests
Website
Information about your visits to and activity on our website, your IP address, the number of times you viewed an advertisement, and other information may be automatically collected by us.
We may use web beacons, provided by third-party advertising companies, to help manage and optimize our online advertising and product performance. Web beacons enable us to recognize a browser’s cookie when a browser visits our Website, and to learn which banner ads bring users to our Website.
The use and collection of your information by these third-party service providers, and by third-party advertisers and their advertising servers, is covered by their privacy policies and not covered by this Privacy Policy.
Third parties
We may also collect your personal information from our service providers, business partners or third parties, such as the registrar, search engines, information service providers, financial advisers, intermediaries, and from your representatives and associations (such as your partners). We may also collect personal information form sources that are publicly available.
If you are a job applicant, we may collect your personal information from a recruiter, your previous employers, referees or others who may be able to assist us with our decision making.
We would assume you have provided your consent for that third party to provide us with your personal information, unless you let us know otherwise. If you have any questions, you can contact us and the third party to discuss.
Using personal information
We collect, hold, use and share your personal information to enable us to undertake our business operations and activities. The purposes for which we will use your personal information will ultimately depend on the relationship we have with you and the nature of the products and services you require from us.
VanEck Australia may use your personal information:
- to provide you with the products and services you require from us;
- to facilitate our marketing and promotional activities;
- to provide you with information that you specifically requested;
- to investigate complaints between you and VanEck;
- to conduct research and analysis (e.g., analyse and compile statistics about your use of our Website or our financial products, and produce data analytics and reports containing only anonymous and aggregate information that we may share with third parties for their own use);
- to monitor, administer and improve the products and services you receive from us;
- to save your preferences and account information;
- to enhance users experience with our Website; and
- as required by all applicable regulatory or legal requirements (including the Anti-Money Laundering and Counter-Terrorism Financing Act, the Corporations Act, the Foreign Account Tax Compliance Act, the Proceeds of Crime Act, the Tax Laws Amendments (Implementation of the Common Reporting Standard) Act) and the rules of stock exchanges and government bodies (such as ASIC).
We may also use information collected about you as otherwise required or permitted by law or with your consent. At all times our use of your personal information is directly related to the commercial activities of VanEck Australia
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Who will we disclose your personal information to?
VanEck Australia may disclose some or all of your personal information to:
- our employees and officers, including the employees and officers of our related bodies corporate;
- our service providers, related bodies corporate or other third parties that help us to operate our business (e.g., to deliver the information, products, or services requested by you; for the purpose of account maintenance and administration and the production and mailing of statements, such as share registries, custodians, accountants and auditors and certain software providers related to the operational management and settlement of trades of fund units, and for fraud monitoring);
- financial institutions and payment system operators;
- our auditors, consultants, legal advisors and other professional advisors;
- any financial market, clearing house, settlement facility, lender, credit provider, custodian, share registry and software provider;
- your financial adviser, dealer or broker if you provide us either directly or through our service providers with written consent to do so;
- companies conducting market research who assist us in marketing products and services to you and improving customer service;
- your agents, legal representatives, attorneys and other professional advisers;
- companies conducting market research who assist us in marketing products and services to you and improving customer service;
- recruitment checking agencies (if you are a job applicant);
- a purchaser of VanEck Australia or VanEck Group or replacement responsible entity of any of the funds, so that new or replacement entity may continue to serve you;
- state and federal government agencies, regulatory bodies and law enforcement agencies;
- state and federal government agencies, regulatory bodies and law enforcement agencies;
- comply with legal orders (e.g., a subpoena or court order), government requests, or other legal process;
- operate VanEck Australia’s and VanEck group’s systems properly; and
- any disclosure to which you consent or have authorised us to release personal information.
We may also share your personal or other information with non-affiliated third parties for their use to produce data analytics and reports containing only anonymous and aggregate information that does not personally identify you.
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You may opt out of VanEck using or sharing your personal information
You can instruct VanEck Australia to:
- identify what personal information we hold about you;
- correct any personal information we hold about you;
- unsubscribe you from mailing lists.
Please note that this opt-out process may take some time to complete, consistent with applicable law. You can also opt out from receiving our promotional emails by clicking the ’Unsubscribe’ link provided in such emails.
Accessing, updating and rectifying your personal information
To access, review, rectify, or delete personal information collected about you please contact us at privacy@vaneck.com.au or write to us at Level 47, 25 Martin Place, Sydney NSW 2000.
All e-mail requests should include the following information: first name, last name, and e-mail address.
While we will do everything we can to accommodate your request. Sometimes we may not be able to comply with some or all of your requests, if this is the case, we will let you know why
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How we hold and secure your personal information
We may hold your personal information in a combination of either electronic or (rarely) hard copy files. To protect your personal information from unauthorised access and use, we use commercially reasonable administrative, technical, personnel, and physical measures. These measures include computer safeguards, internal risk management policies and procedures, and secured files and buildings.
We have in place a an appropriate risk management framework to ensure compliance with worldwide industry standard, such as the AS/NZS ISO 31000:2009 International Risk Management Standard and the AS/NZS 5050:2010 Business Continuity Standard.
To help us protect your privacy, you should maintain the secrecy of any username and password you set up in connection with your use of our Website
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Transfer of personal information to other countries
VanEck Australia has centralised servers located in the United States, which are managed on our behalf by our parent company – VanEck Associates Corporation. VanEck Australia may also disclose your personal information to third party service providers located outside of Australia who assist us with our business operations and activities.
Some of the uses and disclosures described in this Privacy Policy may involve the transfer of your personal information to the United States and other countries which may have different levels of privacy protection than Australia.
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Links to third-party websites
Our Website may include links to third-party websites. Since we do not control third-party websites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.
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Concerns and enquiries
If you wish to understand more about our privacy policy, please contact us at privacy@vaneck.com.au.
If you believe that VanEck Australia has not complied with the Privacy Act, or feel that your privacy has been compromised by us in any way, you can send a complaint to complaints@vaneck.com.au.
We will investigate and respond to your complaint as soon as is practicable after we receive it, in accordance with our Complaints Policy, a copy of which is available on our website.
You may also contact the Office of the Australian Information Commissioner if you believe we have breached your privacy.
If you are not happy with our response, you may refer the matter to the OAIC. The OAIC can be contacted as follows:
- Office of the Australian Information Commissioner
- Address: GPO Box 5218, SYDNEY NSW 2001
- Online: www.oaic.gov.au
- Phone: 1300 363 992
- Email: foi@oaic.gov.au
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Modifications to this Privacy Policy
VanEck Australia reserves the right to change this Privacy Policy at any time by posting revisions on our Website. Such changes will be effective upon posting.
