Privacy Policy

Ascent Funds Management Limited (“Ascent”) as the responsible entity of the Ascent First Mortgage Fund (“Fund”) is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your personal information.

Your Privacy

Your privacy is important to us and we are committed to managing your personal information responsibly and in accordance with our legal obligations including the requirements of the Commonwealth of Australia and State of Victoria laws and regulations and with the Australian Privacy Principles. These laws and principles regulate, among other things, the way we collect, use, disclose, keep secure, and give you access to your personal information.

This Privacy Policy sets out the type of information we collect and how we collect, store, use and disclose your personal information. We recommend that you read it carefully.

You are not required to provide us with your personal information, but if you do not do so we may not be able to provide you with our products or services.

If you apply for or accept any of our products or otherwise provide us with your personal information, you agree to your information being collected, held, used and disclosed as set out in this Privacy Policy. We may revise this Privacy Policy from time to time in order to reflect, for example changes to our practices for other operational, legal or regulatory reasons by placing the revised Privacy Policy on our website.

Collection of your personal information

We collect personal information when we provide our products and services to you, and only collect personal information that is reasonably necessary for us to perform our functions The type of personal information we collect from you or about you depend on the nature of your transaction with us (ie, whether you are an investor in, or a borrower under, our product and service offerings).

Personal information that we will commonly collect and hold from you or about you include:

full name, date of birth, gender and contact details including telephone, postal and residential address, e-mail and facsimile;
a copy of your driver licence and/or passport or other identification documentation for the purpose of verifying identity and to ensure compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act) and/or other legislation and regulations regarding identification verification, and tax reporting and withholding;
copies of any relevant trust deeds, partnership agreements or constitutions, which may be relevant to comply with Anti-Money Laundering and Counter-Terrorism Financing Act.

For investors, this will include your tax file number (TFN); bank account details for the purpose of administering investor accounts and tax reporting and withholding; investor contribution details and investment choice including the source and the purpose of your investment funds; details about authorised signatories on your investments or accounts with us; detailed contact information about your financial advisor.

For borrowers, in relation to applications for loans or other financial accommodation, details of your assets and liabilities, your financial affairs and credit history; bank account details for the purpose of collecting the interest; detailed contact information about your finance broker and / or financial advisor and / or solicitor and all the necessary information to assess your suitability and your creditworthiness for a loan as well as for us to properly manage your loan with us.

It may, on occasion also be necessary to obtain other details, including information relating to powers of attorney or for probate and estate administration and in relation to beneficial owners or controlling persons.

How we collect and hold personal information

We may collect your personal information in various ways including by telephone, our website, from documents or correspondence and by email. Wherever practicable, we will collect information about you and in relation to beneficial owners or controlling persons from you personally.

However, it may be necessary in many instances to collect information about you from other external sources, such as:

a financial advisor or broker;
authorised representatives, such as solicitors, executors or administrators; and
identification verification service providers.

All personal information we collect will be held securely and in accordance with this Privacy Policy.

Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business operations and activities with you. These may include;

to establish and administer your investment or loan account and your relationship with us;
for communication purposes;
to comply with our record-keeping, reporting, and tax obligations;
to protect legal rights and comply with legal obligations;
to prevent fraud and abuse;
for quality assurance and training purposes;
to handle any relevant enquiries or complaints.

We may be required by law to disclose personal information to Australian Government regulators such as the Australian Securities and Investments Commission, the Australian Tax Office, Australian Financial Complaints Authority, any other regulatory or government entities; and as required by a court order or response to a subpoena.

In order to meet our investors’ needs and to administer investor services or if you are a borrower, to meet the our obligations to properly administer your loan with us, it may be necessary to release information or provide access to external service providers, for instance:

to any organisations involved in providing, managing or administering our products systems or services such as custodians, registries, administrators, mail houses and software and information technology providers;
to auditors, consultants and other professional advisors;
to your financial advisor or broker;
to a legal personal representative, attorney or any other person who may
be entitled to receive the proceeds from your investment or account with us;
to a legal personal representative, attorney or any other person who has been instructed by you to assist with the settlement, enforcement or discharge of borrower loan account.
to other financial institutions who hold an account in an investor’s or borrowers name, for example, where amounts have been transferred to or from that account;
to authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to an investment or borrower loan account.

Sensitive Information

Sensitive information is defined in Australian legislation to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

For the primary purpose for which it was obtained
For a secondary purpose that is directly related to the primary purpose
With your consent; or where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Policy Updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at:

Ascent Funds Management Limited
Level 18, 350 Queen Street
Melbourne Victoria 3000
Tel: (03) 8676-0244
Email: enquiries@ascentfin.com.au