AIL PRIVACY POLICY

Last Updated: January 2008

Almond Investors Limited (AIL) will always respect the privacy of those persons that invest in our Projects.  

Type of Information Gathered

The information that is gathered from Investors is of a general nature and is used for administering and managing their investments and for complying with Australian laws.   It is usually collected directly from Investors or their Advisers via application forms, email messages, letters and telephone calls.  Such information includes names of and contact details for Investors and their Advisers, and investor details relating to date of birth, tax file numbers, copies of Power of Attorneys and correspondence between Investors, Advisors and AIL.  

Almond Investors Finance Pty Ltd, a wholly owned subsidiary of AIL, may also collect information from investors that apply for a loan to finance their investment in an AIL Project.  Such information would include a potential investor’s annual income and other financial details, place of work, credit history etc. 

We do not collect any sensitive information such as an Investors’ racial or ethnic origin, religious or philosophical beliefs or sexual orientation. 

There may be some situations where we need to source personal information from an external party e.g. credit reporting agency or a government agency.

Anti-money laundering
AIL is required to collect certain customer identification information and verify that information in compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 ("AML/CTF Act") and AML/CTF Rules before it can issue Units or Allotments to the applicant.
Customer identification information may include detailed know your customer ("KYC") information in relation to the applicant such as:

• for an individual applicant: name, address, and date of birth;

• for an applicant that is a business entity: details of directors and beneficial owners; and

• for an applicant that is a trustee: details of the trust and beneficiaries.

AIL may require further KYC information such as information concerning business activities, structure and source of funds of applicants and from time to time may require an investor to provide updated or additional information.
The information that must be collected and the material must be provided to verify that information is set out in the Project’s Application Form.
AIL may refuse an application or decline to issue Units or Allotments to an application until it has satisfactorily concluded a customer identification procedure in relation to the applicant.  Further, AIL may delay or refuse any request or transaction, including suspending the issue or redemption of Units or Allotments in the Project if AIL is concerned that the request or transaction may cause AIL to contravene the AML/CTF Act.  AIL will incur no liability to the applicant if it does so.

Security of Information

The electronic and hard copy information that we have gathered is confidential and secure. Our electronic files are protected by personal User IDs and passwords and our hard copy files are stored in lockable filing cabinets.  No one can enter our office premises after business hours without a security pass.   

Destruction of Information

We will destroy personal information if it is no longer needed for the purpose for which we collected it or for the purposes of meeting legal requirements.  All hard copy information will be shredded and all electronic information will be deleted from our systems.    

Disclosure of Information

In certain circumstances we may disclose Investor information to other organisations or persons e.g. the Australian Taxation Office or other regulatory bodies as required by law.  We may also disclose information to an Investor’s Adviser or Dealer Group (with consent).  In some instances, we may need to disclose information to third parties such as our Auditors, Accountants and Lawyers. AIL will always take appropriate steps to ensure that Investor information is protected.

Direct Marketing

AIL does not currently engage in direct marketing campaigns.  However, if our current policy were to change, Investors would have the chance to “opt out” of receiving direct marketing material.   Those that do would have their names removed from the mailing list.   AIL would never disclose its mailing list to any other organisation. 

AIL Contact Details

Almond Investors Limited
Suite 7, Level 3, 470 Collins Street, Melbourne VIC 3000
Tel: (03) 9629 2777
Fax: (03) 9629 1944
Email: Melbourne@ailfunds.com.au