This privacy policy (‘Policy’) is effective as of 19 September 2025, and relates to GCI Funds Pty Ltd and its related bodies corporate (‘GCI’, ‘we’, ‘us’, and ‘our’). We may make changes to this Policy from time to time for any reason and will make concerted efforts to update the website in a timely manner.
Any information that identifies individuals is deemed to be personal information (‘information’).
We respect an individual’s right to privacy and acknowledge that the protection and confidentiality of your information is important. This Policy outlines the type of information we collect, as well as how and why it is collected, used, stored and protected. When we don’t need your information we will delete, destroy or de-identify it.
The Policy will be updated by us when our information handling practices change, and any amendments will apply to the information we hold as at the time of the update. Any update will be communicated to you by posting the updated policy on our website.
Why do we collect information?
We collect information so that we can provide you with our products and services and also comply with our regulatory obligations in the delivery of these products and services.
If you do not provide information to us, we may not be able to provide you with the products, services or assistance you require.
What information do we collect?
The information we may collect about you will depend on the reason for its collection.
The type of information we collect from you in order to provide you with our products and services includes (but is not limited to) your name, contact details (including residential address, email address, and telephone number), and other sensitive information where required by law (eg. to verify your identity).
We will collect information including your name, contact details, date of birth, citizenship, criminal records, academic and regulatory accreditations, director identification, passport/driver’s licence information, employment history and references if you apply for a job with us.
In addition, we may collect business contact details of a company representative with whom we deal.
How do we collect information?
We mostly collect your information directly from you (and/or your advisers/brokers), and we hold this information in secure computer storage facilities, on paper-based files, as well as in other formats.
For example, we collect information when you lodge an application form, when you transact with us or with funds managed by us, when you access our website(s), and/or when you communicate with our staff, service providers or our other appointed representatives.
In addition, we may collect information about individuals who are not customers of ours in our dealings with them. For example, we may also collect information if you apply for a job with us.
Your information can also be collected from other sources, such as (but not limited to) your representatives and advisers, our corporate clients when we are providing services to them, referees in the case of prospective employees, and/or our service providers.
We may also collect data through ‘cookies’. This generally relates to the device used to access online content, such as an IP address, browser type and operating system and does not identify, or relate, to a particular individual. Cookies may also obtain data about the user behaviours (for example access times, referring sites and pages viewed etc). Whilst some cookies are essential to run the website, some cookies may be voluntary and can be managed/disabled by you. These voluntary cookies may include:
- marketing cookies which allow us and our social media providers to tailor our advertising to you;
- functional cookies which store your region, country, language, accessibility options and settings; and
- performance cookies which tell us how you use our website.
Some cookies may stay in one of your browser subfolders until you delete them manually or your browser deletes them.
How do we use your information?
We use your information to manage and administer the products and services provided by us, to comply with relevant laws, regulations, codes or practice or court orders and to communicate with you on an ongoing basis about your investments and the market in general.
This information may also be used as a part of analysis to improve our products and services, to verify your identity and/or to minimise the risk of fraud, crime or other activity that may cause harm to either you or us in relation to our products or services.
Unless you ask to opt-out, we may also send you educational and insight material about other products and services we offer.
Do we share your information with external parties?
We may disclose your information to external parties, including (for example) to:
- our agents, contractors, and service providers who help us to provide products and services to you. This includes (but is not limited to) our external distributors, administrators and registry providers, printing and mailing companies, IT service providers, etc);
- our auditors, insurers and professional advisors and Officers;
- courts, tribunals and other dispute resolution bodies in the course of a dispute;
- anyone to whom we are required or authorised by law to disclose your information to. For example, bodies such as the ATO, ASIC, and AUSTRAC;
- other financial services institutions in order to detect, investigate or prevent fraud in connection with our products or services; and/or
- anyone authorised by you or in respect of whom you have provided your consent (either expressly or impliedly), including but not limited to other financial services providers that we may need to deal with on your behalf.
Can we send information offshore?
We may disclose your information to our agents, contractors and/or external service providers (including data/cloud storage providers) in the various offshore locations. We take steps to ensure that these parties keep the information confidential and only it for the authorised purpose.
Protecting your information
The security of your information held by us is of critical importance. We take reasonable steps to protect your information from loss and unauthorised access, destruction, use, modification or disclosure. We ensure that our staff are trained on the importance of maintaining the confidentiality of information, and the privacy of our clients.
Should a data breach occur, we have measures in place to manage and respond, which include the notification to impacted individuals and regulatory authorities, as required.
Third party websites
Our websites may have links to external third-party websites that may benefit you. Third party websites are not covered by this Policy or our privacy standards and procedures.
Complaints
If you wish to make a complaint about how we have handled your information, you can call us on +61 (2) 9230 0850, or you can send an email to contact@GCIfunds.com.
The complaint may also be taken to the Office of the Australian Information Commissioner (OAIC). For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email enquiries@oaic.gov.au.
Can you access, and correct, your information we hold?
In most circumstances you can request access to the information that we hold about you. We will take reasonable steps to correct information held about you where we are satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading or, you request us to correct the information.