About this Privacy Policy

At Apac Investment Management Pty Ltd (“Apac”) we value the privacy of your personal information.

Personal Information refers to information or an opinion about an individual whose identity is apparent from the information stored. It includes your name and contact details.

Apac is bound by, and committed to supporting, the 13 Australian Privacy Principles (“APPs”) set out in the Privacy Act 1988 (Cth). The following statement outlines how we collect, maintain and handle your personal information according to the APPs.

Collecting Personal Information

Why do we collect your personal information?

We collect your personal information in order to undertake investments, on your behalf, in Invesco funds as well as to provide you with information about other products and services that may be of interest to you.

What kind of personal information do we collect?

We may collect some or all of the following personal information for the purposes set out in this Privacy Policy:

  • Name
  • Date of Birth
  • Contact details, such as telephone number, address and email address
  • Tax File Number, exemption reason or country of residence
  • Bank account details
  • Authorised Representative information
  • Investment Instructions
  • Feedback queries
  • Website usage details

If you do not provide the personal information requested Apac may not be able to accept or process your application, undertake investments on your behalf or provide you with information about our products and services.

How do we collect and hold personal information?

Apac collects personal information via application forms, telephone, fax, email, feedback forms and online (including via its website). Where practicable, Invesco will collect personal information directly from you via one of these methods.

We may receive personal information from third parties that you have authorised us to deal with. This could be a financial adviser, broker or other representative, such as an executor or administrator. If you provide us with personal information of another person (such as your authorised representative), you should let that person know that their information has been provided to Invesco and will be handled by us in accordance with this policy.

We may hold the information that we have collected in both physical and electronic storage facilities, including paper based files or computer databases.

Use and Disclosure of Personal Information

For what purposes do we use personal information?

Generally, Apac will only use and disclose personal information for the purpose it was collected for. The main reason for collecting personal information is to enable Apac to provide investment products and services to you.

We may also use and disclose personal information for other related purposes which we consider an individual would reasonably expect. These purposes include administration and providing services to you in relation to investment products. Administration includes monitoring, auditing, evaluating, modelling data, dealing with complaints, answering queries and providing services in relation to investment products.

Who may we disclose information to?

Apac may share your personal information with its employees, contractors or agents for the purposes of operating our investment business, responding to and fulfilling requests made by you and to otherwise provide our products and services to you.

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you.  These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).  If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.  In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.

We do not provide your personal information to other organisations for the purposes of direct marketing.

If you have nominated an Authorised Representative and/or a broker on your application form, Apac may also share your personal information (other than tax file number information) with your Authorised Representative and/or broker.

Apac may also share your information with service providers who provide outsourced services to Apac or another member of the Apac Group. Those members of the Apac Group and Apac’s service providers may be located outside Australia (where privacy obligations may differ). The types of outsourced service providers that may be provided with your personal information and the circumstances in which your personal information may be shared include:

  • administrators which provide fund accounting, unit registry and other services to Invesco;
  • printers and other companies for the purposes of preparation and distribution of statements and for handling mail;
  • legal and accounting firms, auditors, contractors, consultants, agencies and other advisers for the purpose of administering, and advising on, the product and for any associated actions; or
  • in certain circumstances and with safeguards to respect your privacy, Apac may also disclose your personal information to any person to use in relation to a proposed or actual purchase of an interest in Apac or any part of Apac’s business.

Invesco may also disclose your personal information to other entities or persons as required by law. For example, information may be provided to government regulators or as required by a court order.

We may also disclose your personal information where you have consented.

Security of personal information

Apac takes reasonable steps to protect the personal information that it holds from misuse or loss and from unauthorised access, modification, and disclosure.  Apac and its service providers have implemented security measures to protect the personal information that it holds, including requiring use of passwords, user logins, and other security procedures. Developments in security and encryption technology are reviewed regularly.

Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it (whichever is the later).

Quality of personal information

It is important to us that the personal information which we hold is accurate, complete and up to date. If any of the details you provide change or you believe that the personal information we hold about you may be inaccurate or incomplete then please contact our fund administrator on 61 3 9670 8563.

Access to and correction of personal information

You may request access to any personal information Apac holds about you. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). In normal circumstances we will give you full access to your information. However, there may at times be a legal reason to deny access. If access is denied we will tell you why.

If you believe that any personal information we hold about you is incorrect, incomplete or inaccurate, then you may request that we correct it. We will consider if the information requires correction.

 Contact us

If you have any further questions relating to this privacy statement, or concerns about the way in which we have handled your personal information collected by us, please contact our Privacy Officer, via our fund administrator on 61 3 9670 8563.


Apac treats any complaints about our handling of personal information seriously. If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will treat your complaint confidentially. We will fully investigate any complaint you lodge with us and seek to provide a response within a reasonable time (and in any event within the time required by the Privacy Act, if applicable).

If you are not satisfied with the outcome of the complaint you may lodge a formal complaint with the Office of the Australian Information Commissioner.

Changes to our privacy policy

We may change this policy from time to time. Any updated versions of this privacy policy will be posted on our website and will be effective from the date of posting.