Privacy

Updated: November 2023

This Privacy Policy (policy) applies to information collected in Australia by Artega Investment Administration Pty Limited (ABN 31 661 042 093) (Artega Investment Administration) and/or Challenger Limited (ABN 85 106 842 371) and their related bodies corporate.  It outlines how we manage your personal information and safeguard your privacy. At Artega Investment Administration, we understand your concerns about privacy and the security of your personal information. Customer privacy is important to us and we are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (‘APPs’). We are committed to protecting the personal information that we hold about you and, where applicable, your customers.

1. What personal information is collected?

Artega Investment Administration may collect personal information that is reasonably necessary for us to provide you with services and to administer them. The kind of personal information we collect and hold will depend upon the type of products and services that you request from us and may include:

  • information provided to us when you request a product or service from us. This information may include you (or your customers) name, date of birth, address, contact details, and other relevant identification documents; communications between us and your representatives including your broker or other agent as well as associations that you are a member of and with which we have an affiliation; communications between us; transactional information; financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks; in some cases sensitive information obtained with your consent or otherwise where required or permitted by law (e.g. in relation to anti-money laundering laws) information such as you (or your customers) name, address and date of birth where an investor or borrower has listed you as a beneficial owner or other related party in connection with the product or service you receive from Artega Investment Administration; if you are a financial adviser, investment manager, Trustee or other authorised representative of a customer, your name, contact details and any other information you provide when communicating with us in relation to our products and services, or in connection with a mutual customer; and information regarding your website interaction with us (i.e. the sections or features of our website that you have visited or used).

2. How is personal information collected?

Artega Investment Administration collects personal information in a number of ways including:

  • directly from you (including but not limited to data received via your financial, legal, or other adviser including your broker or other agent, administration service provider, registry provider, custodians, distribution partners or other financial institutions, as well as Trustees), such as when you provide the information by phone, email or in an application form, or as part of data migration activities.
  • from other Artega Investment Administration group companies where permitted by law;
  • from third parties such as your financial adviser, lawyer or other agents, or identity verification service providers, if you authorise us to do so;
  • from our appointed client registry services provider (where applicable to your services agreement with us);
  • from publicly or commercially available sources for the purpose of complying with customer due diligence obligations under relevant legislation (e.g. anti-money laundering laws).

3. What if you do not provide certain information?

  • If you provide an incomplete application form (including answering questions to ensure you are likely to be within the target market for the product), we may not be able to provide you with the product or service until the application is complete.
  • If you do not provide us with all relevant identity verification documents and information (for example, in relation to authorised signatories or beneficial owners of your company and/or the trusts, mandates or managed investment schemes for which Artega Investment Administration is to provide services), we may not be able to provide you, or continue to provide you with the product or service until the information is provided. This includes information regarding TFN, ABN and other details.
  • If you choose not to disclose your account details or correctly answer verification questions, we may not be able to process transactions requested or provide the relevant services.

4. How do we use and disclose your personal information?

Artega Investment Administration may collect, use and disclose your personal information for the primary purpose of providing the products and/or services requested, as well as for related purposes such as:

  • to verify your identity or transactions which you may enter into with us (including the identities of third parties connected with your application for products and services, such as beneficial owners, where applicable);
  • to process your applications for our products and services;
  • to administer and manage the provision of our products and services;
  • to respond to queries, complaints or to provide you with our general customer services;
  • to provide your agent or other representative (if applicable) with details of your investment, scheme or portfolio for which Artega Investment Administration is proposed to, or currently provides services;
  • to provide you with offers of other Artega Investment Administration products or services and to improve and personalise our products and services;
  • to provide you with offers from organisations with whom we have an alliance;
  • to comply with laws and regulatory requirements, including anti-money laundering, financial services and taxation laws, or complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;
  • to comply with Artega Investment Administration ‘s risk management policies and procedures;
  • to perform statistical analysis, product and market research, or to seek feedback relating to improving the customer experience;
  • to train our staff; or
  • if attending our offices in person, to assist Artega Investment Administration in providing a safe and secure environment for employees and visitors.

We may disclose your personal information to:

  • your adviser, agent or other person you have authorised to act on your behalf, including other financial institutions and Trustees;
  • professional service firms that provide services to you or us, such as, legal, audit or data/ information services;
  • your or our appointed sub-custodian y or client registry (where applicable) service providers; 
  • digital service providers, such as Facebook, Google and LinkedIn, to develop a better understanding of our current and prospective customers and advisers; 
  • electronic identity verification service providers, in order for identity information (about your company or product (trust, mandate or scheme), its beneficial owners/related persons) to be verified against relevant government and other databases, for the purpose of complying with anti-money laundering laws);
  • your appointed investment manager(s), Trustees, service providers or distribution partners; and
  • otherwise in accordance with this policy and the APPs.

5. Overseas disclosures

Personal information may also be used (or accessed) by third party service providers located overseas to perform administrative functions in relation to your investment. Artega Investment Administration has reviewed these arrangements to ensure appropriate security protections are in place to protect the personal information of its investors.

In some cases, Artega Investment Administration may utilise ‘Cloud’ storage solutions for data storage purposes, and the relevant servers may be located overseas. Please see ‘Storage and security of information’ section of this policy for further details. Artega Investment Administration has reviewed these arrangements to ensure appropriate security protections are in place to protect personal information.

Please note, if you are investing with Artega Investment Administration Europe (which engages UK-based investment managers to manage funds) then refer to the Artega Investment Administration Europe privacy policy. 

6. Use of service providers

We may contract out some of our administrative and support functions such as mailing, settlement services, client registry services, document and data storage, background checking or identity verification to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.

7. Keeping us up-to-date

Personal information such as contact details may change from time-to-time and we ask that you keep us informed of any changes by notifying us. Where you have previously provided information about your company’s beneficial owners or authorised persons (including authorised signatories) or fund/mandate details, and the information is no longer current, you must provide up-to-date information. Changes to some details may require additional documentation to verify the change.

Please see the ‘Contacting us’ section of this policy if you would like to request an update to the personal information we hold about you. 

8. Storage and security of information

Artega Investment Administration stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using trusted third parties. Some personal information may be held by data service providers located overseas (such as ‘Cloud’ service providers for data storage and management purposes) and Artega Investment Administration maintains effective control of the information under contractual arrangements.

We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure. Where data is held by a third party administrator (such as our appointed client registry services provider), we take reasonable steps to ensure that the provider has appropriate security measures in place to protect your information.

Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.

9. Openness

This policy sets out Artega Investment Administration ’s approach to the management of personal information and is made freely available on our website or in hardcopy if requested.

10. Access and correction

Generally, Artega Investment Administration will provide you with access to your personal information that we hold, unless a particular exception applies, such as where:

  • it would be unlawful to provide the information;
  • providing access would be likely to prejudice an investigation of possible unlawful activity;
  • the information is relevant to legal proceedings and would not be accessible in the normal discovery process;
  • giving access would have an unreasonable impact on the privacy of other individuals;
  • it would pose a serious and imminent threat to the life or health of any individual; or
  • the request is frivolous or vexatious.

If a request for access would divulge a commercially sensitive decision-making process, then Artega Investment Administration may provide an explanation rather than direct access to the information.

If we become aware that the personal information we hold about you is inaccurate, incomplete, misleading or irrelevant, then we will take reasonable steps to amend it. If we receive a request from you to correct your information, then we will seek to correct it within 30 days. If you and Artega Investment Administration disagree about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement on those records.

Please see the ‘Contacting us’ information below if you would like to request an update or seek access to the personal information we (or our appointed client registry services provider) hold about you.

11. Identifiers

Artega Investment Administration does not use any government-issued identifiers for use as its own identifier for clients.

12. Anonymity and pseudonymity

Given legal requirements on financial institutions to identify their customers, in most situations Artega Investment Administration is unable to allow you to transact with it on the basis of anonymity (including the use of a pseudonym). Access to the Artega Investment Administration public website, and some other interactions with Artega Investment Administration may be done anonymously, or in the case of general enquiries, using a pseudonym. However, we may not be able to respond to your queries unless you provide us with certain information.

13. Direct marketing

Artega Investment Administration will not use your personal information for direct marketing purposes unless;

  • we have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and
  • we have provided you with a simple means to ‘opt-out’ from receiving direct marketing; and
  • we have not received such a request from you.

Artega Investment Administration will not use any sensitive information collected from you for direct marketing purposes. To opt-out of receiving direct marketing, please refer to the ‘Contacting us’ section below for the relevant contact information.

14. Use of our website

We may collect some information from you and about your use of the site when you visit the Artega Investment Administration website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. This may be used in order to ‘personalise’ your experience on the site by displaying content that is likely to be most relevant to you.

Authenticated Portals

When accessing your account via authenticated portals, cookies may be used to store information related to your session and visit duration. For more information on cookies, please refer to the BoardRoom Privacy Policy. 

Because our portals have access restricted to users with an account, you will be required to use your secure login. Unique identifiers (such as your login identification) are collected from website visits to verify the user’s identity.

Unique identifiers may also be used to store information about preferences, to enable dynamic display of the site according to your preferences when you return.

Artega Investment Administration uses the data collected for statistical analysis and business purposes.

Website analytics

Artega Investment Administration may use third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful in our website.

Our web analytics providers use “cookies” and in some cases “clear gifs/web beacons” to collect information. For more information on our web analytics providers, please visit Adobe Analytics and Google Analytics sites.

Online advertising

Artega Investment Administration uses several advertising companies for our online advertising. These advertising companies may use cookies to collect information such as browser type, date and time of your visit, your interactions with banner advertisements and if you have visited our website through an online advertisement. None of the information collected by the advertising companies will personally identify you.

Artega Investment Administration use Google AdWords and the Google Marketing Platform, including Display & Video 360 to trigger advertisements across the Internet. The Google Marketing Platform will display advertising based on what parts of the Artega Investment Administration website have been visited by placing a cookie on your machine. The Google Marketing Platform will also let us know what parts of our website you interact with after clicking on one of our ads. The cookies used by Google Marketing Platform do not identify you as an individual and allows us to tailor our marketing to better suit your online activity and display ads that are relevant to you. Visit Google’s Privacy Policy for more information on the Google Marketing Platform cookie and how to opt out from the use of these cookies.

Artega Investment Administration uses the Facebook Pixel, Microsoft Advertising and the LinkedIn Insight Tag to enable in-depth campaign reporting and to help us unlock valuable insights about our website visitors. We use both the Facebook Pixel and the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about Facebook and LinkedIn members interacting with our Facebook and LinkedIn adverts. Challenger will only use the Pixel and the Insight Tag to retarget and analyse aggregate data for non-EU residents.

Both the Facebook Pixel and the LinkedIn Insight Tag enable the collection of metadata such as IP address information, timestamp and events such as page views. All data is encrypted, and Artega Investment Administration is unable to identify you and will not attempt to identify you at any point. Artega Investment Administration may share metadata collected via the Facebook Pixel with Facebook, and metadata collected via the LinkedIn Insight Tag with LinkedIn. Facebook or LinkedIn may then be able to identify you using the Facebook or LinkedIn browser cookie.

The LinkedIn browser cookie is stored in a visitor’s browser until they delete the cookie, or the cookie expires (there is a rolling six-month expiration from the last time the visitor’s browser loaded the Insight Tag). You can control the use of cookies from Facebook or LinkedIn on your Facebook settings page or LinkedIn settings page. We recommend you read Facebook’s Cookie Policy and LinkedIn’s Cookie Policy for more information.

Clear gifs

Clear gifs (also known as web beacons) are used in combination with cookies to help us understand how visitors interact with our website. A clear gif is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear gif allows us to measure the actions of the visitor opening the page that contains the clear gif.

Matched audiences

Artega Investment Administration may use a lookalike audience service provided by LinkedIn, Facebook and Google. These services allow us to reach people who are similar to our current customers. In simple terms, we provide encrypted information about our customer base to LinkedIn, Facebook and Google (including your name, email address and phone number), which is used to check if you have an existing profile with them. If you do, they will already hold this information about you. LinkedIn, Facebook and Google then use this information to help us understand the types of customers that are more likely to be interested in our products, so that we can develop more effective online marketing strategies. At no stage can they de-crypt the information we provide them about you (i.e. they can’t read it or know it relates to you as an individual). They can only use it to determine whether it matches information they already hold about you (if you have a profile with them). We only receive anonymised data back from LinkedIn, Facebook and Google (consisting of aggregated ‘lookalike audience’ data).

Cookies

Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. 

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.

Many of the third-party advertising and other tracking services listed above offer you the opportunity to opt out of their tracking systems. You can read more about the information they collect and how to opt out through the privacy policy links listed above.

15. Electronic verification

We may be required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) to verify your identity before we can provide you with financial products and services. If relevant to your services agreement with Artega, our appointed client registry services provider may utilise electronic verification services (via a third party provider) to verify the identity of investors in relevant funds.

This service allows for certain fund investor information (name, date of birth, residential address and relevant government identifier) to be passed to official State and Commonwealth record holders via the service provider to electronically match your information with information on their databases and confirm that the document is valid and has not expired.

If you have any questions about our service provider’s electronic verification process, please contact us (refer to ‘Contacting us’ below). 

16. Employment opportunities at Artega Investment Administration

If you are seeking employment or contracting opportunities with us, we will collect personal information from you and, where applicable, from any referees you have provided to us during the recruitment process. Personal information gathered during the recruitment process will only be used to assess your suitability for the relevant role, and if you are not the preferred candidate, your information may be retained to assess your suitability for roles offered in the future.

We may also collect sensitive information about you as part of our background checking process (with your consent). This information may be disclosed to (and obtained from) third party agencies that we engage to conduct screening checks on our behalf, including overseas agencies where you have prior residential or working history in those locations.  For some roles, we may request that candidates complete psychometric testing to assist in candidate selection. This may involve you taking an ability assessment or providing information about your work style and preferences.  Testing is undertaken via our service provider’s online system, with results provided to Artega Investment Administration. Results are also stored by the provider in its Australian data centre and are backed-up in its UK data centre.

If you complete psychometric testing but are not subsequently employed by us, you may contact us at any time to request that your results are de-identified by Challenger and/or our third party provider, and we will take reasonable steps to comply with such requests.

17. Contacting us

If you would like more information please contact Artega Investment Administration on 0407 899 647 or write to us at the following address:

GPO BOX 3993 
Sydney NSW 2001 

If you have a specific privacy query, you can also contact:

The Privacy Officer
Artega Investment Administration
Level 2, 5 Martin Place
Sydney NSW 2000

Or send an email to: 

18. Complaints about your privacy

If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following:

  • Your complaint should be made in writing to the Privacy Officer (via post or email).
  • We will attempt to respond within 30 days from receipt of your request.

The complaint may also be taken to the Office of the Australian Information Commissioner (OAIC)

For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email 

19. Changes to our Privacy Policy

Artega Investment Administration may make changes to this policy from time to time for any reason and we will update the website in a timely manner.

Copyright © 2024 Artega Investment Administration. All rights reserved.