PRIVACY POLICY

Overview

At GERAF (ACN 691 316 579) along with our associated entities and affiliates, including Corporate Authorised Representatives (“GERAF”, “we”, or “us”), we prioritise the confidentiality and protection of data concerning our clients and prospective investors. We gather only the essential personal details required to deliver our services effectively. This policy outlines our practices for handling your personal information, including collection, storage, usage, disclosure, and management.

In this document, Personal Information refers to any data that, either alone or combined with other details we hold, identifies or can identify an individual, such as a name, contact number, email, or investor identifier (“Personal Information”).

By accessing our websites that reference this policy (the “Site”), utilising our offerings, or supplying us with your Personal Information (or permitting others to do so), you consent to the handling of your Personal Information as described here, which may involve sharing with third parties or transferring across borders.

Types of Information We Collect

To support our services, such as account setup, transactions, phone discussions, emails, event registrations, webinars, or Site usage, GERAF may gather, handle, and share necessary Personal Information.

We detail our collection practices below, with further explanations on usage and sharing in later sections.

Should you submit unsolicited Personal Information, we will delete or destroy it promptly unless legally obligated or allowed to retain it.

Laws or judicial orders may mandate collection of specific details, including name, address, residency country, birth date, business details, directorships, and more, under statutes like:

Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and related rules (“AML/CTF Laws”)
Income Tax Assessment Act 1997 / Tax Administration Act 1953
Superannuation Industry (Supervision) Act 1993

For some investors, compliance with FATCA or CRS may require collecting and reporting Personal Information to the Australian Taxation Office.

Failure to provide requested details may prevent us from offering services, processing investments, or assisting you.

Specific Personal Details

We obtain information straight from you during account openings, Site registrations, info requests, or event sign-ups. This can encompass:

Full name and organizational details (if relevant)
Contact numbers
Residential or mailing address
Email
Bank account info
Birth date
Residency country
Investment specifics
Payroll data
Tax-related info (e.g., Tax File Number)
Dietary preferences for events
ID proofs like driver's license, passport, Medicare, or bills
Other financial, audit, or accounting data

We might also receive your details from authorized third parties, such as employers or verification services.

Details on Related Individuals

You may provide info about others linked to your account, like signatories, dependents, or agents. By doing so, you confirm their consent to our handling as per this policy.

Communications Data

Records of phone, email, or Site interactions are kept. Calls may be recorded for quality, training, security, or service reasons, per legal standards.

Public and Social Media Info

We could collect data from open sources or social platforms if it pertains to GERAF or our offerings.

Methods of Collection

Personal Information is gathered through various channels like phone, Site, email, or forms (digital or paper). Primarily, it's directly from you.

Occasionally, it's from others such as fund managers, trustees, employers, advisors, or authorized representatives.

When providing others' details (e.g., company members or staff), ensure you have their explicit consent and inform them of this policy's location.

All handling adheres to this policy.

Additional Data Gathering

When you visit our Site or engage with emails, we automatically collect usage data via technologies like cookies and web beacons for insights into interactions.

This includes device type, OS, browser, connection, visit timing, pages viewed, clicks, searches, IP address, location (general), and referral sites. See “Analytics on Our Site” for details.

About Cookies

Cookies are small data files stored on devices to recognize users and preferences. We use session (temporary) and persistent (ongoing) cookies to enhance experience and Site functionality.

You can manage cookies via browser settings—block, notify, or delete them—but this might limit Site features. For ad-related opt-outs, see below.

Web Beacons Usage

Also called pixel tags, these help track email opens, device info, IP, and link clicks to evaluate communication effectiveness and target ads.

We link this with known data to personalize, assess Site/tools utility, and identify relevant products.

Purposes for Collecting and Using Your Information

We use Personal Information only for intended or related purposes, or as legally permitted, including:

Setting up and managing accounts or investments
AML/CTF verifications and reporting
Tax recording and reporting to ATO, withholding correctly
Updating on holdings, values, distributions, or queries
Payment processing
Delivering requested services (e.g., registry, admin, payroll, compliance)
Training and quality control
Legal compliance
Site visitor tracking and performance
Analytics, navigation improvements, design enhancements
Security for Site and accounts
Other specified purposes at collection

Additionally, we may use it to notify you of GERAF, affiliates, or partners' offerings. For fund investors, this includes marketing other products—opt out via “Get in Touch”.

Sharing Your Information

To achieve collection purposes, we may share with:

ATO for compliance/reporting
ASIC/ASX for regulatory needs
Service providers (e.g., registry, payroll, audit, storage, trustees)
Your advisors (with consent)
Entities we serve (e.g., managers, employers)
Authorities, regulators, or as required by law

Analytics on Our Site

We employ tools like Google Analytics for usage reports and traffic analysis. Visit Google's privacy policy at https://policies.google.com/privacy. Opt out via https://tools.google.com/dlpage/gaoptout.

External Website Links

Our Site may link to others; we're not responsible for their privacy. Review their policies.

Safeguarding and Storage of Information

We implement appropriate measures against misuse, loss, unauthorized access, alteration, or disclosure, using secure systems and encryption. Retention is for necessary periods or legal mandates.

Requesting Access to Your Information

You can seek access to held Personal Information; we'll grant it unless legally restricted.

Updating or Correcting Your Details

Notify us of inaccuracies; we'll reasonably correct them.

Handling Data Breaches

If a breach risks serious harm, we'll inform affected parties and the Office of the Australian Information Commissioner per law.

Filing a Complaint

Policy Updates

We may revise this; changes posted on Site.