Privacy Policy

Set out below is the Privacy Policy of PAN-Tribal Asset Management Pty Limited (PAN-Tribal, Us, Our or We). Please read the Policy for full details of how we collect, use and process your personal information and other information.

1. Our Commitment

We handle personal information provided by and about people every day. Personal Information, for the purposes of this Policy and the Privacy Act 1988 (Cth) (Privacy Act), means any information or opinion about a person whose identity is apparent or can reasonably be ascertained by that information or opinion.


The aim of PAN-Tribal is both to support and to ensure that we comply with the Privacy Act and the Australian Privacy Principles (APPs) contained in the Privacy Act. PAN-Tribal also seeks to comply with the Spam Act 2003 (Cth) which is aimed at reducing the number of unsolicited electronic commercial messages that you receive.


The information set out below is largely a summary of our obligations under the Privacy Act, in particular, the relevant APPs.


We believe that this Policy will address any potential concerns you may have about how personal information you provide PAN-Tribal is collected, held, used, corrected, disclosed and transferred.


You can obtain more information on request about the way we manage the personal information we hold, via the contact details at the end of this Policy.

2. Collection of Personal Information

In the course of our providing our products and services, we collect, hold, use and process your personal information. Personal Information may also be collected when individuals make enquiries about PAN-Tribal’s products and when individuals provide personal information intended for publication on the PAN-Tribal website, such as in the provision of online blogs and articles (if any).


The main purposes for PAN-Tribal collecting personal information include:


  • to provide our products and services to you whether as a client, shareholder or other interested party;
  • to assess your application for PAN-Tribal’s products and services, which includes assessing whether you are sophisticated or professional investor;
  • to facilitate share distribution payments;
  • to comply with the requirements of regulatory and professional bodies including but not limited to persons inspecting the register, bidders for securities (in the context of takeovers), authorised securities brokers, print service providers, mail houses and the Australian Taxation Office;
  • to disseminate by electronic means or otherwise investor updates;
  • to disseminate by electronic means or otherwise topical information and details of events of interest;
  • to regulate the activities of our clients;
  • to publish articles, blogs and other information received for our online services.


We will only collect personal information from you that is necessary for one or more of our functions and activities.


We will only collect personal information from you by lawful and fair means, without being unreasonably intrusive, such as when you complete an application form or make an enquiry with us. At or before the time we collect personal information from you we will take reasonable steps to inform you why we are collecting that personal information, who else we might disclose that personal information to and what will happen if you do not provide personal information to us.


Where reasonable and practicable, we will only collect personal information about you, from you.


Wherever it is lawful and practicable, we will give you the option of not identifying yourself or not providing personal information when entering transactions with us. However, failure to provide full and complete information we request may mean that we are unable to provide services to you fully and properly.


Once we hold personal information we will take reasonable steps to keep it accurate, complete and up-to-date.


If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Policy.

3. Use and disclosure

We will only use your personal information for the main purpose we told you it was needed for, except where you consent to us using that personal information for another purpose, where the other purpose is related to the main purpose and you would reasonably expect us to use the personal information for that other purpose, or where it is permitted or required by law, or we reasonably believe it is necessary on health or public safety grounds to use the personal information for another purpose.


In order to fulfill the purposes set out above, we may provide access to your personal information to third parties with whom we have a business relationship, for example those who maintain and update our database (including those who manage our products and Funds), persons inspecting the register, bidders for securities (in the context of takeovers), authorised securities brokers, print service providers, mail houses and the Australian Taxation Office.


Your personal information may also be provided to third parties including but not limited to the independent custodian providing administrative services to PAN-Tribal’s Fund, PAN-Tribal’s equity trustees, financial institutions, licensees in relation to the provision of our services.


Where possible (for example, where not otherwise required by law, regulatory standards or as reasonably necessary in the provision of our products), we will take steps to de-identify your personal information, if such information does not require disclosure.


Where possible (for example, where not otherwise required by law or regulatory standards), prior to the online publication of personal information we will ensure the de-identification of personal information is undertaken. This enables the value and utility of information published and provided on online resources to be maximised. PAN-Tribal will de-identify personal information by removing or modifying identifying features such as name, address, or date of birth, remove or modify quasi-identifiers such as general, profession or income and /or by suppressing or modifying data with broader categorisations.


You accept that not all recipients of your information may have privacy policies equivalent to PAN-Tribal’s and you consent to the disclosure of your personal information for those purposes.


There are some circumstances where by law we are required to disclose your personal information, including to Courts, Tribunals or law enforcement agencies.


In relation to direct marketing, where practicable we will seek your consent before we use your personal information for this purpose. You may tell us at any time you do not wish to receive any further direct marketing materials – if you do, we will stop sending you such materials.


In accordance with the Spam Act, should you wish to unsubscribe from commercial electronic messages from PAN-Tribal, all future commercial electronic messages from PAN-Tribal will enable you to unsubscribe from that particular type of electronic message from PAN-Tribal and this can be done at any time. If you do not unsubscribe, PAN-Tribal will continue to send you relevant information of the types described above.


PAN-Tribal may also use messaging methods other than email.

4. Access and correction

If you ask, we will tell you what personal information we hold about you, and what we do with it. We will facilitate access to you by allowing an inspection of your personal information in person, or by providing copies or a summary of relevant documents, depending on what is most appropriate in the circumstances, following receipt of your request. Any charge we make for providing access will be reasonable.


If you can show us that the personal information is inaccurate, we will take reasonable steps to correct it. Note that we need not provide access to personal information in several types of situation, for example where a request is frivolous, or where to provide access would pose a threat to health or public safety, unreasonably interfere with another person’s privacy, or be a breach of the law. If we refuse access we will advise you of our reasons for doing so.

5. Security

We will protect personal information from misuse and loss, and destroy or permanently de-identify personal information we no longer need.

6. Online Publications

This part specifically relates to articles, blogs and any other information published online by PAN-Tribal and/or guest contributors to the PAN-Tribal website and PAN-Tribal publications. PAN-Tribal, and Individuals (including you) must adhere to this Policy, PAN-Tribal online Terms and Conditions and any other relevant policy or document, when making use of online publications and resources. Where possible, PAN-Tribal will make use of pseudonyms when publishing articles, blogs and any other online material (save for the records of any disciplinary proceedings against members), unless consent is expressly provided.

7. Cookies

When you visit our website, details may be collected and recorded about your visit, such as the time and date of your visit, your server or IP address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually.


For the same reason, we may use cookies to identify your browser so that next time you visit our website we remember your website and search preferences. A cookie is a small file which remains on your computer’s hard drive and contains information enabling our website to recognise your browser and your browser preferences. If you do not wish to use cookies, you can adjust the settings on your browser to reject cookies or notify you when they are being used.


Please note that third party websites that are accessed from our website may also use cookies, however we are not liable or responsible for this.

8. Identifiers

We will not adopt as our own any identifiers that you may provide to us including but not limited to tax file numbers, Medicare numbers etc.

9. Third party websites

Our website may contain a number of links to other websites, including the websites of our commercial partners. When this occurs we recommend you read the privacy policy of those third party websites as we are not responsible for privacy practices, or privacy policies of those other websites or parties.

10. Overseas disclosure of Personal Information

We may from time to time transfer and/or store your personal information we collect outside Australia in accordance with the Privacy Act, to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws.


For example, we may transfer and/or store your personal information to United States of America. We may also use cloud storage and IT servers that are located offshore.


By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so on the basis that we are not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.

11. Mandatory data breach notification

The Notifiable Data Breaches scheme (NDB scheme) came into effect on 22 February 2018 following an amendment to the Privacy Act. The scheme requires entities with obligations under the Privacy Act to notify you, as well as the Office of the Australian Information Commissioner, should your personal information be involved in a data breach that is likely to result in serious harm to you.

If we believe there has been a data breach that impacts your personal information, we will notify you as soon as possible and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.

You can find more information about the NDB scheme on the Office of the Australian Information Commissioner website the details of which are further below.

12. Complaints resolution

We are committed to providing clients, and other parties whose personal information we hold, a fair and responsible system for the handling of their complaints.


If at any time you have any complaints in relation to privacy, please contact our Privacy Officer at one of the points referred to below. We will seek to address any concerns that you have through our complaints handling processes, but if you wish to take matters further you may refer your concerns to the Office of the Australian Information Commissioner the details of which are further below.

13. Changes to this Policy

We are constantly reviewing our statements and policies in an attempt to keep up to date with market expectations and legal developments. Subsequently, we may change this Policy from time to time as the need arises.


A copy of this Privacy Policy will be available on our website and will also be available on request. Clients, consumers and other parties whom which personal information is collected from, acknowledge and agree to comply with this Privacy Policy as amended from time to time.

14. Contact us

If you seek any further information from PAN-Tribal about this Policy or how we deal with privacy generally, please contact our Privacy Officer at one of the following reference points:


Sarah Angliss 

Level 17, 90 Collins Street, Melbourne, Victoria 3000

(03) 9654 3015


Further information on privacy in Australia and the NDB scheme may be obtained by visiting the website of the Office of the Australian Information Commissioner.

Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner at


Prepared July 2018


The following information has been prepared by PAN-Tribal Asset Management for use by Sophisticated Investors / Wholesale Clients and Investment Professionals only. No account has been taken of the investment objectives, financial situation or particular needs of any particular person. Information is provided for general information purposes only and does not contain investment recommendations nor provide investment advice, nor is it intended to take the place of professional advice. Investors should not take action in reliance on information contained on this website.


Past performance information provided on this website is given for illustrative purposes only and should not be relied upon as (and is not) an indication of future performance. None of PAN-Tribal, its related bodies or associates, nor any other person, guarantees the repayment of capital or the performance of the Fund(s) or any particular returns from the Fund(s). No representation or warranty is made concerning the accuracy of any data contained on this website.


I have read the important information above and confirm that I am a Sophisticated Investor / Wholesale Client (as defined under the Corporations Act) and/or Investment Professional and that I wish to proceed.