1.1 This Privacy Policy sets out our policy relating to collection, use, disclosure and protection of your personal information by us or our related bodies corporate (Ninety One Group), as well as how you can access and change your information, ask a question or make a complaint. The term “Ninety One Group” refers to all entities within Ninety One plc and Ninety One Limited.
Our Privacy Policy applies to all your dealings with us as a customer, prospective customer or other member of the public, including with our specialist advisors, through our call centres, or via our websites.
2.1 We recognise that your privacy is very important and that you have the right to control your personal information. At Ninety One, we are committed to ensuring the confidentiality and security of your personal information. We are bound by the Privacy Act 1988 (Cth) and other applicable laws which protect your privacy.
3.1 We collect personal information that is necessary for our functions and activities. If it is reasonable and practical to do so, we collect personal information directly from you. We may do this when you complete an application form in hard copy or online, when you register with us to use any of our online services or products, or send an email to us, over the telephone, the internet or in person. We may keep records of communications including emails and telephone calls for purposes including training and verification.
3.2 In some instances, we may also collect personal information about you indirectly, from other people and this may happen without your direct involvement. For example, we may collect personal information about you from publicly available sources, third party brokers and government agencies. We may also verify your personal information with your current financial advisor
3.3 The types of personal information we collect include:
4.1 We collect, hold, use and disclosed personal information to:
4.2 If we are not provided with your personal information, we may not be able to fully provide our services to you.
Where personal information is exported to other parts of the Ninety One Group, that equivalent data protection processes are followed in accordance with the Data Protection Policy for the Ninety One Group.
4.3 How we usually use and disclose your personal information
Any personal information which we collect about you may be used by us for the purpose for which it was disclosed to us or any related purposes. For instance, we may from time to time use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you.
We may disclose your personal information to:
4.3.1 Some of these third parties may be located in South Africa, United Kingdom, Ireland, USA, Mauritius, Hong Kong, Switzerland, India, Luxembourg and other countries and may not be subject to Australia’s Privacy Act. Those other countries are subject to Data Protection laws that have the effect of protecting your information in a way that, overall, is at least substantially similar to the way in which the Australian Privacy Principles protect your information. Ninety One is required to comply with certain provisions of the Privacy Act to protect your privacy in relation to these disclosures.
4.3.2 On some occasions, we may also be obliged to disclose your personal information by law, e.g., court order or statutory notices pursuant to any legislation and to government authorities.
4.3.3 When you contract with Ninety One UK Limited your personal information and documentation will be held by Ninety One UK Limited in the United Kingdom. Ninety One UK Limited must comply with the United Kingdom Data Protection Act 1998 and Directive 95/46/EC of the European Parliament to protect your personal data.
4.4 Security, access to and correction of your personal information
We may store personal information in information systems and physical records, sometimes in our systems and premises, and sometimes with the assistance of our service providers. We will take all reasonable steps necessary to secure any personal information which we hold about you and to keep this information accurate and up to date. Your electronic information is stored on secure servers that are protected in controlled facilities.
4.4.1 In most cases, you can gain access to your personal information which we hold, by contacting us. Please provide us with as much detail as you can about the particular information you seek, in order to help us retrieve it.
4.4.2 If you think the information we have about you is incorrect or incomplete, please write or email us with the updated information. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to record a note of your requested correction with the information.
You should keep us informed about all changes to your personal information.
4.5 Additional information for users of our website
The company may collect personal information from you via the website www.ninetyone.com which is managed by Ninety One UK Limited in the United Kingdom.
Ninety One maintains its website for distribution to, and use by, the website’s visitors. The website is not directed at you if we are prohibited by any law of any jurisdiction from making the information on the website available to you. You should satisfy yourself before accessing the website that we would be allowed to advertise investments and investment services to you under you’re the laws applicable to you. Nothing on the website constitutes investment, legal or other advice; nor is it to be relied upon in making any investment decision. Nothing on the website constitutes an offer or an invitation to make an offer to sell securities or to provide investment services of any description. Any application for our products or services should be made only after consultation with your legal, tax and financial advisors and review of the applicable prospectus, Key Investor Information Document, or other offering document(s) and terms and conditions applicable to such products or services. Any information, including the prospectus, Key Investor Information Documents or other offering document(s), in respect of applications can be obtained from the local office or local representative of Ninety One.
4.5.1 All information provided by you to Ninety One UK Limited through this website is used solely by us and is not sold or provided to any other company. Personal financial information and information about our investors is regarded as private, and as such is not shared with anyone in any manner, regardless of the method by which we obtained such information. Nonetheless, we reserve the right to co-operate fully with any state, local, federal, and international officials in any investigation relating to any content (including personal or private electronic communication(s) transmitted via this website) or any purported unlawful activities of any user of this website.
4.5.2 If you visit www.ninetyone.com (the Website) our system may record information such as the date and time of your visit, your computer’s IP address, the pages accessed, and any information downloaded. This information is used for statistical, reporting and website administration and maintenance purposes.
When you visit our site, our servers may attempt to load a small tracking file known as a "cookie" to your device. A cookie enables us to analyse usage patterns on our Website and tailor the Website to your needs.
4.5.3 What are cookies?
A cookie is a small data file that is essential for the proper functioning of our website. Cookies help our systems to recognise your browser and to provide features such as providing you with access to information that you have previously confirmed you are able to access. Cookies do not retrieve information about you stored on your hard drive, or corrupt or damage your computer or computer files. Cookies do not personally identify you but do identify your browser.
4.5.4 How do you block cookies?
The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. However, please note that cookies allow you to take full advantage of our website and are essential for its operation and we recommend therefore that you leave them turned on. Should you choose not to block cookies from our website you will be unable to access it fully.
While we take great care to protect your personal information, unfortunately no data transmission over the Internet can be guaranteed to be 100% confidential. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of guaranteeing that information is protected in transit. Once we receive your information, we make our best effort to ensure its security in our possession. If you are concerned about submitting your personal information to us online, please contact us to enquire about making other arrangements.
The Website may provide links to third party websites. These linked sites are not under our control and we are not responsible for the conduct of companies linked to this website. Before disclosing your personal information to any other website, you should examine the terms and conditions of using those websites and the privacy policies applicable to those websites.
5.1 We and our related corporations may provide you with information on an ongoing basis about new products, promotions, special offers, investment opportunities and other information which we think you may find interesting. We may contact you for these purposes by any means including telephone, email and other electronic messages. We take your preferences and our obligations under anti-spam and telemarketing laws seriously. If you receive any direct marketing communication from us and no longer wish to do so, please follow the instructions for unsubscribing in that communication.
If there are no instructions, please contact us as set out below.
5.2 If we are providing you with services or products, you will also be subject to the specific terms and conditions relating to that particular service and/or product and those terms and conditions may include additional information as to how we may contact you.
Please see other sections of this Privacy Policy for further information regarding access, correction, complaints, crossborder disclosures of personal information and how we collect and hold personal information.
6.1 If you have any queries relating to our Privacy Policy, or if you have a problem or wish to lodge a complaint in relation to an alleged breach of your privacy, please contact us:
Privacy Officer – Craig Miladinovic
Ninety One Australia Pty Limited
Level 28
The Chifley Tower
2 Chifley Square
Sydney NSW 2000
Tel: +61 2 9293 -2251
Fax: +61 2 9293 2429
Email: [email protected]
Where you raise any concerns that Ninety One has interfered with your privacy, Ninety One will respond to let you know who will be handling your matter and when you can expect a further response.
If your concerns are not resolved to your satisfaction, you may have rights to escalate your complaint to the Financial Ombudsman Service (FOS). Further details about FOS are available at the FOS website: www.fos.org.au. FOS can also be contacted by telephone on 1300 78 08 08 or email [email protected].
7.1 From time to time it may be necessary for us to review and revise our Privacy Policy. We reserve the right to change our Privacy Policy at any time and to notify you by posting an updated version of the policy on the Website. You should ensure that you check the Website regularly for any updates to our Privacy Policy.
8.1 Annual
| Responsible Office | Scope | Approver | Date of Approval | Effective Date |
| Jacqueline Smith | Australia | Global Policies Committee Ninety One Australia Board |
Date of Approval November 2020 [tbc] |
August 2020 |
Date of next review: August 2021