Lighthouse Investment Services

Privacy Policy

This Policy applies to Lighthouse Investment Group Pty Ltd (ACN 609 738 132) (referred to as "Lighthouse", "we", "our", "us"). The word "individual" refers to an employee, an authorised representative, a client, a prospective client or any other person with whom we come into contact.

This Policy outlines Lighthouse's obligation to manage and protect the personal information we hold about individuals.

Lighthouse is bound by the Australian Privacy Principles ('APPs') contained in the Privacy Act 1988 (C'th) ('Privacy Act').

'Personal information' is information or an opinion relating to an individual, which can be used to identify that individual. Some personal information which we collect is 'sensitive information'. Sensitive information includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, that is also personal information, and also includes health information about an individual.

How we collect personal information

We generally collect personal information directly from the individual. For example, an individual may deal with us on the phone, send us correspondence (by letter, fax or email) or contact us in person. Also, Lighthouse will collect personal information from forms filled out by individuals, interviews, business documents and from other people. Typically, the type of personal information we collect about the individual includes name, age, date of birth, occupation, mailing address, phone numbers, email address, financial information and other information that is relevant to the services we provide.

In some circumstances Lighthouse may be provided with personal information about an individual from somebody else, for example, from one of Lighthouse's authorised representatives, or a referral from another person. Where this happens, Lighthouse will take reasonable steps to ensure that the individual is or has been made aware of the matters set out in this Privacy Policy.

If the personal information we request is not provided, we may not be able to process an individual's request to receive our services, or provide individuals with the benefit of our services, or prepare financial plans and financial product advice for clients, or meet an individual's needs appropriately.

About whom do we collect personal information?

The type of information we may collect and hold includes (but is not limited to) personal information about:

• a client;
• a client's dependants, spouse, partner or other associate;
• prospective employees, employees and contractors; and
• other people with whom we come into contact.

Why does Lighthouse collect personal information?

Lighthouse collects personal information for the following purposes:

• to provide financial services including financial product advice to individuals in accordance with the terms and obligations contained in our Australian Financial Services Licence;
• to supervise our Authorised Representatives in accordance with the terms of the Authorised Representative Agreement and also in accordance with the Corporations Act 2001 or other appropriate legislation;
• to conduct our business;
• to comply with our legal obligations; and
• to help us manage and enhance our services.

How might we use and disclose personal information?

When we refer to "use" of personal information, we mean use within Lighthouse, for the purposes outlined above. When we use the word "disclose", we mean providing the information to persons outside Lighthouse.

Lighthouse may use and disclose personal information for the primary purposes for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (eg, where required by law).

We use and disclose personal information for the following purposes:

• to provide financial services and financial product advice to individuals in accordance with the terms and obligations contained in our Australian Financial Services Licence;
• to supervise our Authorised Representatives in accordance with the terms of the Authorised Representative Agreement and also in accordance with the Corporations Act 2001 or other appropriate legislation;
• to conduct our business;
• to comply with our legal obligations; and
• to help us manage and enhance our services.

We do not disclose personal information we collect to others for the purpose of allowing them to direct market their products and services. We do not use or disclose sensitive information for direct marketing purposes.

We engage other people to perform services for us, which may involve that person handling personal information we hold. In these situations, we prohibit that person from using personal information about you except for the specific purpose for which we supply it.

In relation to sensitive information held by us, wherever possible, Lighthouse will attempt to de-identify the information. We also undertake to delete all personal information about an individual when it is no longer needed or relevant, or unless we are required by law to retain the personal information.

To whom might we disclose personal information?

We may disclose personal information to:

• financial services product providers (for example, insurance companies and fund managers);
• our authorised representatives;
• consultants we engage;
• organisations involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables);
• organisations involved in managing our funding functions;
• regulatory authorities, if required by law, including the Australian Securities and Investment Commission (ASIC); and
• anyone else to whom the individual authorises us to disclose it.

We also collect personal information from these organisations and individuals, and deal with that information in accordance with this Policy.

Sending information overseas

We will not send personal information to recipients outside of Australia without:

• obtaining the individual's consent (in some cases this consent will be implied); or
• otherwise complying with the APPs.

Management of personal information

The APPs require us to take all reasonable steps to protect the security of personal information. Lighthouse personnel are bound by a confidentiality agreement to respect the confidentiality of personal information and the privacy of individuals.

Lighthouse takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. All personal information contained in hard copy documents held by Lighthouse are stored in locked cabinets. All personal information stored on Lighthouse's computer system is backed up daily and monthly, and back-up copies are held in a secure location.

Where we no longer require the personal information for a permitted purpose under the APPs, we will take reasonable steps to destroy it.

Identifiers

We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes.

How do we keep personal information accurate and up-to-date?

Lighthouse takes reasonable steps to ensure that the personal information it holds is accurate, complete and up-to-date. We encourage individuals to contact us in order to update any personal information we hold about them. Our contact details are set out below.

You have the ability to gain access to your personal information

Subject to the exceptions set out in the Privacy Act, individuals may gain access to the personal information which Lighthouse holds about them by contacting the Lighthouse Privacy Officer. If we refuse to provide the information, we will provide reasons for the refusal and inform the individual of any exceptions relied upon under the Privacy Act.

When an individual requests access to personal information, which includes evaluative information created by Lighthouse, a representative of Lighthouse will meet the individual personally (where this is possible), and explain the evaluative information to the individual, without giving them a copy of it.

An individual's request for access to his/her personal information will be dealt with by allowing the individual to look at his/her personal information at the offices of Lighthouse. We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access. We will advise the likely cost in advance whenever practicable.

Updates to this Policy

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.

Enquiries

If you have any questions about privacy-related issues please contact the relevant Lighthouse Privacy Officer: Richard Whan or email Lighthouse via the website.