For the purposes of this document the term “Priomha” is used to be representative of Priomha Capital Pty Ltd, Priomha Global Limited and all related entities.

Priomha & its affiliated companies respects the privacy of its investors and other people it does business with, and it strives to comply with the National Privacy Principles (NPPs) contained in the Privacy Act 1988 (the Privacy Act). This Privacy Policy outlines how Priomha & its related entities will handle personal information about you.

As Priomha may collect personal information online through our website, this Privacy Policy also outlines our approach to online privacy issues.

Priomha’s Privacy Policy is divided into the following sections:

  1. How and why Priomha collects personal information?
  2. Will your personal information be given to anyone else?
  3. How is your personal information stored?
  4. Your right of access and correction
  5. Online collection of personal and non-personal information
  6. Additional Privacy Information & How to Contact Priomha

1. How and why Priomha collects personal information?

Priomha needs to collect personal information in order to conduct its business.

Investors: Priomha retains a number of service providers for custodian, registry and administration services. These service providers collect personal information about investors in Priomha funds on behalf of Priomha Capital & Priomha Global Limited.

Business contacts: Sometimes, Priomha needs to collect personal information from people we do business with. This will usually happen when we collect the name and business contact details of a person who is the contact in a government agency or company we deal with, or in one of our contractors or suppliers.

Website users: Priomha may also collect personal information through its website (for example, if you e-mail our webmaster with a question about our website).

Priomha’s policy is only to use personal information collected from its business contacts or the users of its website for the business purpose for which it was collected, and not for any other purpose.  We do not collect personal information that we do not need.

2. Will your personal information be given to anyone else?

Priomha will not sell, rent or trade personal information about you to or with others without your consent. Personal information collected by Priomha may be disclosed to related bodies corporate of Priomha and third parties to whom we outsource specialised functions (such as mailing houses or printing companies), and if so, we take steps to ensure that those parties:

  • comply with the NPPs when they handle personal information about you (regardless of whether they are a small business, and would otherwise be exempt from the NPPs); and
  • are authorised only to use personal information in order to provide the services or to perform the functions required by Priomha.

The only other time Priomha would make disclosures of personal information is if we are required to do so by law, or if the disclosure is permitted under the Privacy Act.

3. How is your personal information stored?

Priomha takes physical, electronic and managerial steps to ensure that the personal information it holds is secure from unauthorised access, destruction, use, modification or disclosure. Priomha only permits your details to be accessed by authorised personnel, and we educate our staff about their responsibilities under the NPPs.

4. Your right of access and correction

Under the Privacy Act, you have the right to seek access to information which Priomha holds about you (although there are some exceptions to this). You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date.

If you wish to exercise your right under the Privacy Act to seek access to the personal information that Priomha holds about you, or if you believe that personal information about you is not accurate, complete or up to date, you should contact Priomha, including the details of your request for correction. The contact details can be found at the end of this Privacy Policy.

Please note that the personal information we hold about you will be information that you have provided.

If you request, Priomha shall provide access to personal information to which you have a right of access under the Privacy Act. It will assist Priomha to process your request if you can specify the personal information you are seeking access to (e.g. by providing details of when you provided personal information to us, and in what context).  Priomha may ask you to pay its reasonable costs of responding to your request. Priomha’s policy is to consider requests for access or correction within a reasonable time.

5. Online collection of personal and non-personal information

Our website automatically collects other information when you visit our website. For example, for each visitor to our website, our server automatically recognises and stores the visitor’s domain name, but not their email address.  Our website also uses cookies. Most web browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt or refuse cookies, but this may mean you cannot access all the features of the website. We use cookies for tracking the statistics about the use of our website. This allows us to improve the layout and functionality of our website. This tracking is conducted in such a way to ensure the anonymity of visitors. The cookie may identify your computer, but it should not identify you.  Our website contains links to other websites, for your convenience and information. When you access a website other than our website, please understand that Priomha is not responsible for the privacy practices of that site. We suggest that you review the privacy policies of each site you visit.

6. Additional privacy information & How to contact Priomha

Priomha may change this Privacy Policy at any time. We will make this Privacy Policy available to anyone who requests it, either at our offices or through our website.

For further information about privacy issues, see the Australian Federal Privacy Commissioner’s website at www.privacy.gov.au.

If you have a privacy concern or query, please contact info@priomha.com.