Privacy Policy

This is the Privacy Policy for the Pacific East Coast group of companies (we, us, or our), which includes (among other companies) Pacific East Coast Pty Ltd ACN 003 135 617 and Property

Investment Management Limited ACN 073 310 451 (PIML), an Australian financial services licensee (number 247097) and an operator of managed investment schemes.

This is Privacy Policy applies to all Pacific EastCoast group companies in their personal capacity, as well as to PIML in its capacity as trustee for managed investment schemes operated by it.

Your privacy

We respect your privacy and we are committed to managing your personal information responsibly and in accordance with our legal obligations under the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles contained in the Privacy Act. The Privacy Act regulates the way we collect, use, disclose, hold and give you access to, your personal information.

This Privacy Policy sets out the type of information we collect and how we collect, hold, use and disclose your personal information, and the purposes for which we do so.

You are not required to provide us with your personal information, but if you do not do so we may not be able to provide you with our products or services.

If you apply for or accept any of our products or services or otherwise provide us with your personal information, then you agree to your information being managed by us as set out in this Privacy Policy.

Changes to our Privacy Policy

We will update this Privacy Policy when our information handling practices change. This version of our Privacy Policy was last updated in July 2022.

This Privacy Policy sets out the type of information we collect and how we collect, hold, use and disclose your personal information, and the purposes for which we do so.

You are not required to provide us with your personal information, but if you do not do so we may not be able to provide you with our products or services.

What kind of personal information do we collect and hold?

We will only collect personal information from you which is necessary for us to provide our financial products and services and to comply with our legal and regulatory obligations. In order to provide our products and services, we may collect the following information:

1. Your full name, date of birth and contact details (including your residential address, e-mail address, and fax and telephone number).

2. Information and documentation to verify your identity, such as a copy of your driver licence or passport, to ensure compliance with the Anti-Money Laundering and Counter- Terrorism Financing Act 2006 (AML/CTF Act) and/or other legislation and regulations regarding identification verification, and tax reporting and withholding.

3. Your tax file number (as authorised under the tax laws and Privacy Act) and bank account details for the purpose of administering investor accounts and tax reporting and withholding.

4. Investor contribution details and investment choice.

5. Copies of any relevant trust deeds, partnership agreements or constitutions, which may be relevant to comply with the AML/CTF Act.

6. Any correspondence between you and us.

7. Any other personal information you provide when you make an inquiry, request information or otherwise correspond with us.

It may, on occasion also be necessary for us to obtain other details, including information relating to powers of attorney or for probate and estate administration.

How do we collect and hold your personal information?

Unless it is unreasonable or impractical for us to do so, we will collect your personal informationfrom you directly, including

1. when you retain our services

2. when you apply for employment with us

3. from you filling out application forms, such as an application form completed by you to acquire a financial product or receive other financial services from us

4. through your use of our website

5. from communications between you and our officers, employees and representatives (including communications conducted in person, over the phone, by email or otherwise), and

6. from promotional and marketing activities undertaken by us, in which we request or otherwise receive personal information from you.

However, we may also collect information about you from third parties, such as

1. your financial or other professional advisor or broker

2. your authorised representatives, such as executors or administrators,

3. outsourced service providers or contractors, and

4. subject to your consent, identification verification service providers that we may engage to collect and verify personal information electronically.

Use of our website

We may use “cookies” to help us tailor our website to better suit your needs and improve our service. Cookies are small text files that are stores in your computer’s memory and hard drive when you visit certain web pages. Cookies are used to enable websites to function or to provide information to the owners of a website.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note this may interrupt your ability to use the full functionality of the website.

We use cookies on this website for the following purposes:

1. Analytical purposes – Analytical cookies allow us to recognise, measure and track visitors to the website. This helps us to improve and develop the way the website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of the site that are of the most interest to them.

2. Usage preferences – Some of the cookies on the website are activated when visitors to our sites make a choice about their usage of the site. Our website then settings preferences of the user concerned. This allows us to tailor aspects of the site to the individual user.

3. Terms and conditions – We use cookies on the website to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and for example, it avoids a user from repeatedly being asked to consent to the same terms.

4. Session management – The software that runs the website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of the site they can access, verify the origin of requests, keep track of order for the site to function.

5. Functional purposes – Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

Storage and security

All personal information we collect will be held securely and in accordance with this Privacy Policy. We will protect your personal information and prevent unauthorised access through the use of secure passwords, user logins, or other security procedures, including firewalls and antivirus technology. All external service providers engaged by us are required to hold personal information in accordance with the Privacy Act.

However, we cannot provide any assurance regarding the security of information transmitted to us online, as the internet is inherently insecure. Nor can we guarantee the supply of information to us from you will not be intercepted. Information you transmit to us online is at your own risk.

We will take reasonable steps to securely destroy or de-identify personal information when it is. no longer required or where we have received unsolicited personal information. However, we may be required by law to retain certain personal information for a specified period of time, after which we will securely destroy or delete the information.

Part IIIC of the Privacy Act established the Notifiable Data Breaches Scheme (NDB Scheme) in Australia. The NDB Scheme sets out obligations for notifying affected individuals and the Australian Information Commissioner (Commissioner) about a data breach which is likely to result in serious harm. Where serious harm to affected individuals is likely, we will notify those individuals and the Commissioner in accordance with our legal obligations. You may contact our Privacy Officer should you require additional information.

Purposes for which we collect, hold, use and disclose personal information

We will only collect, hold, use and disclose your personal information for the purpose of providing our financial products and services to you. We may collect, hold, use and disclose your personal information to:

1. assess your application and establish and administer your investment

2. effectively operate a fund

3. maintain our relationship with you, including to respond to your enquiries, feedback or complaints and provide you with requested information

4. communicate with you (or your advisor) in relation to your investment

5. comply with our legal, regulatory and other obligations, including our reporting and recording keeping obligations

6. verify your identity before transactions are processed, your instructions are carried out, or providing you with information about your investment, including as required to comply with our obligations under the AML/CTF Act and other legislation and regulations regarding identification verification, and tax reporting and withholding

7. improve the quality of our services and for training purposes

8. assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of us and our contractors and service providers

9. prepare internal reporting that includes identifiable customer information (e.g. customer sales or marketing information, complaints or issues reporting, registry operations reporting) to satisfy any legal requirements, and

10. handle any enquiries or complaints relevant to our financial products or services or your investment.

We may disclose your personal information to others if we are required to, such as where we are required to by:

1. Australian Government regulators and entities such as the Australian Securities and Investments Commission, the Australian Taxation Office, and the Australian Transaction Reports and Analysis Centre

2. court order (including in family law matters), or

3. other regulatory or governmental entities outside of Australia.

It may be necessary to release information or provide access to external service providers, such as:

1. any outsourced service providers and organisations involved in the provision of, management or administration of our products or services (such as custodians, registries, administrators, mail houses and information technology providers)

2. auditors, consultants and other professional advisors (including accountants and lawyers)

3. printers and mailing houses, information technology systems software providers, actuaries and research organisations

4. financial services intermediaries, such as financial advisers

5. when required or permitted under law or in connection with legal proceedings

6. authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to an investment or account, or

7. other third partiers you have authorised to receive your personal information.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or that you have consented to us making the disclosure.

Where we contract with an outsourced service provider, we take reasonable steps to protect the privacy of any information disclosed to them, including by requiring them to comply with the Privacy Act. We may store, process or back-up your personal information on servers that are located overseas (including through third party service providers). In some circumstances, Pacific Eastcoast and our associated entities also use third party service providers located overseas to carry out its functions and provide services, such as Office 365 Microsoft services.

These service providers are typically located in Hong Kong and Singapore. The privacy laws in other countries might not be the same as in Australia. However, where we do provide your personal information to third parties overseas, Pacific Eastcoast companies will take such steps as are reasonable to ensure that your information is handled and stored in accordance with our privacy laws and the Privacy Policy.

We will not sell your personal information nor will we provide it to third parties unrelated to the management of your investment or the provision of our financial products or services to you.

Direct marketing

We may also send you direct marketing communications and information about any other products or services offered by us that we expect may be of interest to you. These communications may be sent in various forms, including email. You may opt-out of receiving marketing communications from us at any time by contacting the Privacy Officer.

Please note that, if we are currently providing you with services or products, we will still need to send you essential information about your account, the relevant services or products and other information required by law.

We will not sell your personal information nor will we provide it to third parties except as described in this Privacy Policy.

If you do not want to receive marketing material from us, you can unsubscribe as detailed below:

1. for electronic communications, you can click on the unsubscribe function in the communication

2. for hard copy communications, you can email inquiries@pacificeastcoast.com or

3. through our contact details set out in the ‘How to contact us’ section of our website and informing us that you wish to unsubscribe.

Links to other sites

Pacific Eastcoast and our associated entities’ website may provide link to other sitess for you to access. You should be aware that these other sites are not subject to this Privacy Policy or our privacy standards and procedures. You will need to contact them directly to ascertain their privacy standards.

How you can access and correct your personal information held by us

You may request access to any of your personal information held by us.

Your right to access is subject to some exceptions allowed by law. We will notify you of the basis for any denial of access to your personal information.

Please contact our Privacy Officer using the below details to request access to or to correct any of your personal information held by us.

How can you complain about a breach of privacy?

If you have a complaint about a breach of this Privacy Policy including the manner in which we have collected, held, used, disclosed, kept, or given people access to your personal information, then you may make a complaint to us using the contact details set out below. You will need to provide us with sufficient details regarding your complaint and any supporting evidence.

Your complaint will be referred to our Privacy Officer who will investigate the issue and determine the steps we will take to resolve your complaint. We may ask you to provide additional information.

We will notify you in writing of our determination, generally within 30 days. If you are not satisfied with our determination or you do not receive a response within 30 days, then you can contact us to discuss your concerns and you can refer the complaint to the Office of the Australian Information Commissioner (OAIC). Information on making a complaint to the OAIC is available at https://www.oaic.gov.au/privacy/privacy-complaints/.

Accuracy, currency, and completeness of information

We will endeavour to ensure your personal information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change. If you feel your personal information is not accurate, complete or up to date, then please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.

We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

We may allow an inspection of your personal information in person, or provide copies or a summary of relevant documents, depending on what is the most appropriate in the circumstances. Any charge we make for providing access will be reasonable and will not apply to lodging a request for access.

Your request to access your personal information will be dealt with in a reasonable time. Note that we need not provide access to personal information if a request is frivolous, or where to provide access would pose a threat to health or public safety, unreasonable interference with another person’s privacy, or be a breach of the law. If we refuse access, we will provide you with reasons for doing so.

Request a copy of this Privacy Policy and further information

A copy of our current Privacy Policy is available from us free of charge from our website,

https://pacificeastcoast.com/.

You can also request a copy of the Privacy Policy to be sent to you free of charge

1. by email, by emailing your request to inquiries@pacificeastcoast.com, or

2. by post, by writing to us.

Our postal address is:

Attn: Privacy Officer

Pacific EastCoast

PO Box 1082

Windsor VIC 3181, Australia

If you would like a copy of this Privacy Policy in a particular form, then please contact us and we will accommodate any reasonable request.

If you have any further questions relating to this Privacy Policy, or concerns about the way in which we have handled your personal information, then please contact our Privacy Officer.