Privacy Policy


The Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and related rules require that we, as an APP entity, establish and maintain an APP Privacy Policy.

We are committed to respecting the privacy of personal information of our clients, investors and staff. This document sets out our personal information management practices. It aims to promote the protection of the privacy of individuals and to promote responsible and transparent handling of personal information held.

We may vary this policy from time to time.

Consideration of personal information privacy

We manage personal information in an open and transparent way that complies with the Australian Privacy Principles.

General enquiries about our products and services can be handled anonymously if requested. However, failure to provide the personal information required means that we cannot provide our services or we may be forced to withdraw our services.

Collection of personal information

We only collect personal information (other than sensitive information) that is reasonably necessary and collect this information by lawful and fair means within the requirements of the legislation.

We do not collect sensitive information about an individual unless the individual consents to the collection of the information and the information is reasonably necessary for one or more of our functions or activities.

Dealing with personal information

We use personal information about an individual for the purpose for which it was collected (primary purpose) and do not use or disclose the information for another purpose (secondary purpose) without the individuals consent or unless required by law. In most circumstances, personal information is used to:

  • provide financial services
  • establish and manage investments and accounts, including implementing investment instructions, processing applications, withdrawals and distributions
  • report the investment performance
  • keep the individual up to date on other products or services we offer
  • monitor and improve the services we provide
  • process an application for employment with Ubique
  • comply with regulatory or legal requirements

We may disclose personal information to external parties including (but not limited to):

  • service providers in Australia and overseas that assist us with unit registry, audit and tax, marketing and fund-raising, recruitment, payroll, superannuation, insurance, management consulting, financial and legal advisory, banking, security and technology services
  • organisations that you have consented disclosing your personal information to, including your financial advisor/planner, asset consultant, legal advisor, broker or other agents and their service providers
  • where relevant, to prospective employers and recruitment agencies who request verbal or written references in relation to current or former personnel
  • other third parties where required or authorised by law

Integrity of personal information

We take reasonable steps to ensure that the personal information that we collect is accurate, up to date, complete and protected from misuse, interference, loss, unauthorised access, modification or disclosure (collectively unauthorised access or disclosure).

We have established procedures to respond to any eligible data breaches, including notifying affected individuals as soon as practical after detection.

Access to and correction of personal information

We may provide individuals with access to the information held on them upon receipt of a written request and within the requirements of the law. We will respond to a request for access to the personal information in writing within 30 days.

Website Users

If you visit our Company website, our system may record information such as the date and time of your visit, the pages accessed and any information downloaded. We use this information for statistical, reporting and maintenance purposes only.

Our website may use “cookies”. A cookie is an electronic way to trace your access to our website and use of information contained in the website. By using our website, you are consenting to the use of cookies by the Company. Browsers such as Internet Explorer allow cookies, but users can easily erase cookies from their hard-drive or block all cookies. Please note that some parts of the website may not function fully for users that disallow cookies.

The Company takes great care to protect personal information on our website, unfortunately no data transmission over the Internet can be guaranteed secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online.

The website may contain links to other sites. The Company is not responsible for the privacy practices or policies of those sites.

Further Information

For any questions or concerns about this APP Privacy Policy, please contact our Privacy Officer: Mr. John Harbot

For information about privacy generally, or if your concerns are not resolved to your satisfaction, you can contact the Office of the Australian Information Commissioner (OAIC) on 1300 363 992 or via