- VanEck understands that privacy is important to you
VanEck Investments Limited (ACN 146 596 116) AFSL 416755 and VanEck Australia Pty Ltd (collectively ’VanEck Australia’) are subject to the requirements of the Australian Privacy Principles which are contained in the Privacy Act 1988 (the Privacy Act) and govern how private sector organisations in Australia handle personal information.
Personal information refers to any information which can be used to identify someone. Sensitive information is a subset of personal information, and refers to information that is highly personal and if used improperly might lead to significant harm. References to personal information in this policy include sensitive personal information.
VanEck Australia’s offices are found at Level 47, 25 Martin Place, Sydney NSW 2000. If you have any questions about this policy please email firstname.lastname@example.org or you can call our investor services on 1300 68 38 37.
- VanEck’s Business
VanEck is an investment manager located in Sydney, Australia – we are the responsible entity for a range of exchange traded funds (ETFs) which are quoted and traded on the Australia Securities Exchange. We are one of the world’s largest exchange traded product issuers. In Australia our range of ETFs provide investors with:
- opportunities to asset classes often underrepresented in investor portfolios; or
- beyond-the-usual approaches to established investment categories.
Any personal information we collect is to ensure our commercial services are provided to you efficiently, honestly and fairly.
- Information we collect
VanEck Australia or its service providers may collect certain information about you, including but not limited to information you provide when you:
- request or register for a fund, service, newsletter, or online account;
- contact the Registrar or VanEck Australia with questions; or
- complete a survey or poll or enter a competition or other promotion.
VanEck Australia may collect information provided via our website, through email exchanges, or from the registrar used to manage shareholdings for our exchange traded funds.
This information we collect may include personal information, such as your:
- Title or primary role;
- Company name;
- Contact/postal address;
- E-mail address;
- Phone, mobile and/or fax number;
- Bank account details;
- Investor type;
- Assets under management;
- Transaction history; and/or
- Areas of interest.
VanEck Australia or its service providers may use ’cookies’, web server logs, web beacons, or other electronic tools to collect other information about you, such as:
- IP address;
- browser type;
- operating system;
- computer platform;
- information about your mobile device;
- geo-location data; and
- the state or country from which you accessed this Website.
- the web pages you visit on the Website;
- the date and time of your visit;
- the number of links you click within the Website;
- the functions you use on the Website;
- the databases you view and the searches you request on the Website;
- the data you save on, or download from, the Website, etc.; and
- the websites you visited immediately before and after visiting the Website.
A cookie is a small text file placed on your computer. 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. Thus, 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. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of the Website, such as certain areas for which you need to log in, will not function properly, and the advertising you receive when you visit the Website may not be advertisements tailored to your interests.
- How we may use your personal information
VanEck Australia may use your personal information for reasons directly related to the legitimate commercial activities of VanEck Australia and/or in the following ways:
- to provide you with the services, products, or information that you request;
- to communicate with you (e.g. about updates to your accounts, products, or services, or to provide information about VanEck Australia, or its parent company’s products or services in which you have indicated an interest);
- ensure compliance with all applicable regulatory or legal requirements. This includes (but isn’t limited to) the requirements of ASIC, ATO, AUSTRAC, ASX and other regulatory bodies or relevant exchanges including requirements under the Corporations Act, ASX Operating Rules and superannuation law;
- ensure compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act;
- to conduct research and analysis (e.g., analyse and compile statistics about your use of the Website and other websites, and produce data analytics and reports containing only anonymous and aggregate information that we may share with third parties for their own use);
- to save your preferences and account information;
- to enhance your experience with the Website; and/or
- to provide information, special offers, and promotions to you regarding products and services offered by us, our affiliates, or non-affiliated third parties.
We may also use information collected about you as otherwise required or permitted by law or with your consent.
To assist us with the uses described above, information we or our service providers have collected from or about you may be combined and may be enhanced by other information about you that we or our service providers obtain from other sources.
- How we may disclose your personal information
VanEck Australia may disclose some or all of your personal information to:
- 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 of the funds and certain software providers related to the operational management and settlement of trades of fund units, and for fraud monitoring);
- your financial adviser if you provide us either directly or through our service providers with written consent to do so;
- our affiliates for their own marketing purposes as permitted by law;
- companies conducting market research who assist us in marketing products and services to you and improving customer service;
- a purchaser of VanEck Australia or VanEck or replacement responsible entity of any of the funds, so that new or replacement entity may continue to serve you;
- comply with legal orders (e.g., a subpoena or court order), government requests, or other legal process;
- protect the interests, rights, safety, or property of VanEck Australia or any member of the VanEck group of companies or its affiliates or any of their service providers;
- enforce any legal notices, terms of service, or agreements on or related to products or services requested by you or in relation to your use of the Website;
- operate VanEck Australia’s and VanEck group’s systems properly; and
- any other disclosure to which you consent.
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, and which they, in turn, may share with other third parties for their own use.
- 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;
- remove you from mailing lists;
- refrain from sharing your personal information;
- not to use your personal information to provide you with special offers and promotions or any other marketing or other communications; or
- not to share your personal information with non-affiliated third parties for their use to produce data analytics and reports containing only anonymous and aggregate information
at any time by e-mailing us at email@example.com or by writing to us at Level 47, 25 Martin Place, Sydney NSW 2000.
All e-mail requests must include your:
- first name,
- last name, and
- e-mail address.
- 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 unauthorized 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 comprehensive and thorough 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.
- Accessing, updating and rectifying your personal information
To access, review, rectify, or delete personal information collected about you please contact us at firstname.lastname@example.org or write to us at Level 47, 25 Martin Place, Sydney NSW 2000. All e-mail requests must include the following information: first name, last name, and e-mail address.
While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if permitted or required by applicable laws.
- 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.
- Links to third-party websites
The 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.
- Privacy complaints
If you wish to complain that you believe we have breached your privacy, please contact us at email@example.com . We will investigate and respond to your complaint as soon as is practicable after we receive it, in accordance with our Complaints Handling 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.