Privacy Notice for Australia
GQG Partners LLC (“GQG”, “we”, “us”, “our”) is committed to protecting the privacy of our clients, potential clients and other individuals. In keeping with this commitment, this notice discloses the nature and purpose of personal information we collect and handle. It also specifies the privacy options you may exercise with respect to this personal information.
This Privacy Notice applies to you if you are an individual whose personal information we collect or hold in Australia.
We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. These supplemental notices should be read together with this Privacy Notice.
Our collection of personal information
When you send e-mail, order printed materials, submit an application or request our services, you may be asked to provide certain information, including personal information. The types and categories of personal information we collect and maintain about you include:
- Information we collect about you to open an account or provide investment advice to you (such as your home address, telephone number, other contact details, organisation, job title, nationality and financial information);
- Identification details, including your Australian tax file number (which is optional) where permitted by law and your US taxpayer identification number where applicable;
- Login credentials such as usernames and passwords to facilitate your access to restricted information;
- Information that we generate in managing your account (such as trade tickets and account statements);
- Information that we may receive from third parties with respect to your account (such as trade confirmations from brokerage firms);
- Information from public sources (e.g. to verify your identity);
- Records of your communications, transactions and interactions with us;
- Information about your preferences, interests and opinions;
- Other information you provide to us voluntarily.
Some of this information is collected by us in connection with legal requirements such as Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) reporting, the Anti-Money Laundering and Counter-Terrorism Financing Act, the Corporations Act and the Income Tax Assessment Act and other tax laws.
How we use personal information
GQG collects and maintains your personal information so we can provide investment management services to you. The personal information we collect enables us to communicate with you and to provide the service you request accurately and efficiently. It is also used in our marketing efforts to provide you with relevant information about our products and services that may interest you. We also collect personal information in order to limit, where appropriate, access to materials that are not intended or appropriate for certain types of investors. For example, we may, from time to time, post certain communications intended for existing institutional investors which are not appropriate for retail investors, and request identifying information to determine that a given site visitor, in fact, meets such criteria so that it would be appropriate to grant access to such information.
Other circumstances in which we use and handle personal information include:
- to administer and maintain our website and record and monitor your use of our website (which may include analysing your use of our website);
- where we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process; and
- circumstances relating to any actual or possible business sale or restructure we are involved in, including any related transitional, separation and collaboration arrangements.
We may not be able to do the things described in this section if we are unable to collect certain personal information. For example, we may not be able to communicate with you, provide services to you or grant you access to certain parts of our website.
When we might share personal information
We share personal information with some third parties. This includes both collecting it from and disclosing it to third parties.
The types of third parties we share personal information with include:
- other entities within our group, e.g. as part of our regular reporting activities in company performance, in the context of a business reorganisation or group restructuring exercise, for assistance in relation to marketing and business development or in connection with the operation of group-wide functions and services;
- professional advisers, including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services;
- regulators and government bodies;
- IT service providers (such as cloud services providers, IT consultants and software-as-a-service providers);
- any of our service providers where such information is relevant to their performance of such services;
- companies that help us to manage your account (e.g. to brokers and custodians);
- your joint investors, representatives, agents and advisors;
- regulators, lawyers and other parties involved in any legal process, to comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process; and
- other parties involved in any actual or possible business sale or restructure that we are involved in.
Where your personal information may be disclosed
As we are domiciled in the USA, any personal information that we collect about you will be processed in the USA as our website is hosted here and also in order for us to correspond with you or otherwise provide the information you have requested.
The third parties with which we share personal information may be located in countries including the USA.
How we protect your personal information
To fulfill our privacy commitment at GQG, we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:
- Adopting policies and procedures that put in place physical, electronic, and other safeguards to keep your personal information safe.
- Limiting access to personal identifying information to those employees who need it to perform their job duties.
- Requiring third parties that perform services for us to agree by contract to keep your information strictly confidential.
- Protecting information of our former clients to the same extent as our current clients.
Your rights in relation to your information
Where the handling of your personal information is within the scope of Australia’s Privacy Act, you have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances.
These rights include to:
- request access to your personal information (commonly known as a “data subject access request”);
- request correction of your personal information;
- request us not to contact you for direct marketing purposes;
- request us not to disclose your personal information to third parties for direct marketing purposes; and
- request a copy of this Privacy Notice (or you can obtain it via the GQG website).
If you want to exercise one of these rights please use the contact details set out in the ‘Contact Us’ section below.
You also have the right to make a complaint at any time to us or to a regulator such as the Office of the Australian Information Commissioner.
You usually will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for providing access in limited circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We may keep records of your requests and any resolution and may need to consult with relevant third parties to deal with your issue.
Protecting children’s privacy online
Our website is not directed to individuals under the age of thirteen (13). We do not intentionally collect information on the GQG website from those we actually know are under 13, and we request that these individuals do not provide personal information through the sites.
Changes to this Privacy Notice
Our practices with respect to personal information may vary from time to time and we may update this Privacy Notice at any time. The latest version of this Privacy Notice will be made available to you on our website. We encourage you to review this Privacy Notice each time you visit our website to make sure you understand our current policy on collecting and using personal information.
This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal information. If you require any further information, contact us using the following contact details: Compliance Officer, GQG Partners LLC, 450 East Las Olas Boulevard, Suite 750, Fort Lauderdale, FL 33301 USA (+1 754-218-5500).
Last updated: 26 February 2021