Privacy Policy

A Collection

Purpose of collection

Betashares will collect personal information about a Client through varied means. For example, when they invest in a Betashares fund, visit the Betashares website, contact us by email or phone or when they participate in a webinar or other event. Additionally, we may collect Personal Information from third party data providers when the Client has consented to disclosure of the information.

The information Betashares collects depends on the nature of the interaction. For example:

• When a person visits the Betashares website to browse or download information: our system will collect data such as the date and time of their activities, as well as the information viewed and downloaded
• When a person interacts with us during a webinar or other similar event: we will collect data on their preferences and other information provided to us
• when a person invests in a Betashares fund: we will collect their name, address and other information required to maintain the investment holding.

Information collected

The information (being personal or otherwise) Betashares collects varies depending on the type of Client and nature of the interaction.

Personal Information collected from Clients may include:

• name
• date of birth
• contact details
• residency status
• bank account information
• investment holdings.

Betashares will only collect the personal information necessary to operate our funds and to communicate with our Clients i.e. we do not collect any unnecessary information.

We will advise when Personal Information is mandatory to provide and explain the reason for this, including the consequences of not providing the relevant information.

Means of collection

Betashares will endeavour to only obtain Personal Information directly from the Client, so as to mitigate the risk of obtaining unsolicited and potentially inaccurate personal information.

Where information is obtained via an intermediary, we will ensure that this was obtained following the Client’s consent and that steps have been taken to ensure it is accurate.

To mitigate the risk of obtaining inaccurate information, Personal Information will generally only be collected via these means for example:

• Completion of an online form e.g. where a Client signs up to receive marketing material
• Completion of a fund application form
• Via our unit registry provider’s system

1. Use and disclosure of information

As an overarching policy, Betashares will only use and disclose information collected about the Client for:

• a purpose made clear to the Client, via disclosure in a product disclosure statement for example
• a purpose required, authorised or permitted by, or under any law, such as AML/CFT related requirements
• a purpose otherwise authorised by the Client
• a purpose the Client would reasonably expect.

Importantly, Client Personal Information will not be used for any purpose not considered by this Policy.

In connection with the above, Client Personal Information may be used for the following purposes for example:

• monitoring and evaluating Betashares’ products and services
• statistical, risk management and research purposes (which may include information being deidentified to mitigate risk)
• assisting with fund investment related queries
• marketing and client communication purposes
• establishing and administering investment holdings
• building investor profiles
• market research purposes
• taking measures to detect and prevent fraud, identity theft, money laundering or other illegal activities.

Betashares will never use Client Personal Information for its own personal gain e.g. selling data to another entity.

Telephone, email and ‘Contact us’ correspondence

Betashares may monitor and record Client correspondence for training, account management and security purposes.

Direct marketing

Betashares may provide Clients with further information and marketing material relating to our products and services, unless specifically requested not to do so.

If Betashares uses or discloses Personal Information for direct marketing, the Client may request that Betashares:

• no longer provide them with direct marketing communications; and/or
• provide the source of the personal information.

Parties that may be provided Betashares’ Client Personal Information 

Betashares may disclose Client Personal Information to (note this is not an exhaustive list):

• Betashares’ related parties
• Betashares’ auditor
• regulatory bodies and government agencies
• service providers for fund-related purposes, such as account administration and the production and mailing of state­ments
• service providers to improve customer service (including companies conducting market research), and to keep Investors informed of Betashares’ or its partners’ products and services.

All such disclosure must be consistent with this Policy.

Distribution outside of NZ

From time to time, Personal Information may be provided to entities outside of NZ. In particular, it is likely that Personal Information will be shared with Betashares’ related parties (for reasons contemplated by this Policy), which are all based in Australia.

Disclosure required by law

Betashares may be required or authorised by law to disclose Client personal information, for example, under Court Orders or Statutory Notices.

Betashares may also be required by a Government Agency to produce information and records.

Additionally, AML/CFT related law requires Betashares to establish its Clients’ identity (where necessary) and, where relevant, the identity of other persons associated with the investment, by collecting personal information and taking steps to verify some or all of this information. Betashares may request further information from Clients (as well as other persons who act on their behalf or who are associated with the investment) to comply with these laws.

Betashares may disclose personal information to authorities investigating criminal or suspicious activity, such as the Department of Internal Affairs.

Betashares is committed to keeping Client Personal Information secure. BetaShares takes all reasonable precautions to protect the information it holds from misuse, loss, unauthorised access, modification or disclosure.

Where Client Personal Information is no longer required for any purpose, Betashares takes reasonable steps to securely destroy it or otherwise ensure that the relevant Client(s) cannot be identified by the information.

Personal information-related requests

Betashares aims to ensure the information retained is current, accurate and complete. If a Client wishes to know what information is held about them, wants to request their Personal Information be corrected or otherwise opt out of receiving marketing material, they can contact Client Services via the methods set out in section 11 (‘Contacting Betashares’) of this Policy.

A Client can only access their own Personal Information, we will decline any request to obtain other Clients’ Personal Information (unless the request was made under Power of Attorney or similar).

If a Client wishes to update the details relevant to their BetaShares fund investment, they need to contact Link Market Services in the first instance (see contact details in section 5 (‘Third parties’) of this Policy).

Cost

As a general rule, Betashares does not expect to charge a fee to any Client that wishes to access their Personal Information.

If we do need to charge a fee (e.g. to cover administrative related costs associated with the request), the Client will be notified of any fees payable in advance of the information being provided.

Exception to access

In some instances, access to information will be restricted. Examples of scenarios where an access request may be limited or declined include for example:

• giving access would have an unreasonable impact on the privacy of others
• the information relates to existing or anticipated legal proceedings, and would not be accessible by the process of discovery in those proceedings
• giving access would be unlawful.

The Client will be notified of the basis for any request for access being declined or limited.

Correcting information

Clients are encouraged to advise us when they believe the Personal Information held about them is incorrect.

Link Market Services

When a Client invests in a Betashares fund, Personal Information will be collected by Link Market Services (as Unit Registrar of Betashares’ funds).

Information collected by Link Market Services is governed by their privacy policy.

Clients should contact Link Market Services with any questions surrounding their privacy framework (including to obtain a copy of their privacy policy). Contact details are here: https://www.linkmarketservices.co.nz/ContactUs.html.

External websites

Betashares’ website may contain links to other external websites. BetaShares is not responsible for the material or privacy practices of any external website referenced.

If a Client believes Betashares has inappropriately handled or used their personal information, they can lodge a complaint via complaints@betashares.com.au or by contacting Client Services on [ ].

A complaint will be dealt with in accordance with the Betashares Complaints Handling Policy which will be made available upon request, at no charge.

If Betashares is unable to resolve the complaint, or it has not been satisfactorily addressed, the Client may lodge a complaint with the PC via complaints@betashares.com.au

If a Client has any questions relating to Betashares’ privacy framework, or if they wish to access or correct the personal information Betashares holds about them, they can contact client services via:

Telephone: [ ]

Email: info@betashares.co.nz