Privacy Policy

Hastings is committed to respecting the privacy of your personal information. This Privacy Policy sets out our personal information management practices.

Throughout this Privacy Policy, we refer to your personal information which means information which identifies you as an individual or from which your identity can be reasonably ascertained. Your name and credit card details are examples of personal information. Personal information does not include information about corporate entities.

References to Hastings, us, we and our are references to Hastings Funds Management Limited ABN 27 058 693 388 and its related bodies corporate.

Application of privacy laws

Hastings is bound by the National Privacy Principles under the Privacy Act 1988 and other laws which protect your privacy. Hastings sometimes handles personal information relying on exemptions under these laws, for example in relation to:

-      employee records;

-      related bodies corporate;

-      provision of services to State or Territory authorities; and

-      operations outside Australia relating to personal information of non-Australians.

Any permitted handling of personal information under such exemptions will take priority over this Privacy Policy to the extent of any inconsistency.

Personal information collected

We must only collect personal information that is necessary for our functions and activities. There are certain situations in which we may collect personal information about you from someone other than you. For example, we may collect personal information about job applicants from recruitment agencies and referees. In either case, we will take any steps required by law to ensure that you are aware of the purposes for which the information is collected.

In certain circumstances we may collect sensitive information such as health information or membership of professional associations. We will only collect this information when you provide it voluntarily, consent to us collecting it or as otherwise authorised by law.

Use and disclosure of personal information

We use and disclose your personal information for purposes related to the main purpose for which the information was collected, where you have consented to the use or disclosure, or where otherwise authorised by law.

These purposes may include carrying out or responding to your requests, improving our services, communicating with you, assessing your suitability for positions with Hastings, purposes relating to any third party acquisition or potential acquisition of an interest in Hastings, or assets of Hastings or its managed funds, or any other purposes outlined at the time you provide the information. We may not be able to do these things without your personal information. For example, we may not be able to contact you or offer employment to you.

We may provide personal information about you to:

-      service providers who assist us in providing our services and operating our business, including, but not limited to, organisations that assist us with fund registry, archival, research, mail and delivery, auditing, recruitment, payroll, superannuation, insurance, management consulting, financial and legal advisory, banking, security and technology services in their capacity as service providers to Hastings;

-      where relevant, prospective employers and recruitment agencies who request verbal or written references in relation to current or former Hastings personnel;

-      if you are an investor, your custodian, investment advisers, brokers and asset consultants; and

-      other third parties where required or authorised by law, which may include emergency situations and assisting government agencies.

Accessing and updating your personal information

To make a request to access or correct any personal information we hold about you, please contact us using the details set out in Further information below. We ask that you provide us with as much detail as you can about the particular information you seek, in order to help us retrieve it. An access fee may be charged where permitted by law. In certain circumstances, we may not be required by law to provide you with access or to correct your personal information. If that is the case, we will give you our reasons for that decision.

We take reasonable steps to make sure that the personal information we collect, use and disclose is accurate, complete and up-to-date.

Security of personal information

Irrespective of whether personal information is stored electronically or in hard copy form, we must take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure.

Additional information for users of our Website

If you visit www.hfm.com.au (the Website) to read, browse or download information, our system may record information such as the date and time of your visit to the Website, the pages accessed and any information downloaded. This information is used for statistical, reporting and website administration and maintenance purposes only.

Like many websites, our Website may use cookies from time to time. Cookies are small text files that we transfer to your computer's hard drive through your web browser to enable our systems to recognise your browser. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes. Any such information will be aggregated and not linked to particular individuals unless required by law. The default settings of browsers like Internet Explorer always allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the Website may not function fully for users that disallow cookies.

While we take great care to protect your personal information on our Website, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. 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 protecting that information until it reaches us. Once we receive your transmission, we make our best effort to ensure its security in our possession.

The Website may contains links to other sites. We are not responsible for the privacy practices or policies of those sites.

Further information

If you have any questions, concerns or feedback about privacy, please contact the Company Secretary and Head of Compliance, Hastings Funds Management Limited.

Level 15, 90 Collins Street,
Melbourne  Victoria  3000, Australia

Telephone         +613 9654 4477
Facsimile          +613 9650 6555
Email                  CompanySecretary@hfm.com.au

For information about privacy generally, or if your concerns are not resolved to your satisfaction, you can contact the Office of the Federal Privacy Commissioner on 1300 363 992 or via http://www.privacy.gov.au.

29 November 2007