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This Privacy Policy applies to iTrust Investment Fund (Itrust Invest) (ARSN 625 636 231) and it’s responsible entity, Stapleton Asset Management Limited (AFSL 341 990) and its affiliates (“we”, “us”, “our”) and explains how we handle personal information and comply with the requirements of applicable privacy laws (“Privacy Laws”). If you have further questions relating to this policy please contact us using the contact information below.

We recognise the importance of your privacy, and that you have a right to control how your personal information is collected and used. This policy outlines how we handle your information, and how you can contact us in relation to the personal information about you that we hold.

  • Collection of personal information
    • We collect personal information from existing and potential customers, prospective employees and other individuals and use that information for the purposes identified in this privacy policy.
    • The types of personal information we will collect from you will depend on the circumstances in which that information is collected. It may include:
      • contact details (eg. your name, address, email, phone number);
      • information required for you to open an account with us or receive services from or do business with us. This information may include bank account details, credit or debit card numbers that you link to your account, financial information, and details about your investment activities and financial history;
      • personal information about you that allows us to tailor the services and product offerings we make available to you;
      • information required as part of a recruitment process;
      • statistical information regarding the use of the Itrust Invest websites or Apps, including website users’ IP addresses and the dates and times of visits; and
      • information about investments that you make by cards linked to your account.
    • We usually collect personal information when you:
      • submit information to us (including via the Itrust Invest website), eg. when you register a user account, retrieve log-in information, or request a new password;
      • request a product provided by Itrust Invest;
      • submit information through the Itrust Invest website;
      • register for email subscriptions, or publications through the Itrust Invest website;
      • receive services from us. This may include us accessing information held by your financial institution or other third parties that we have relationships with;
      • use the Itrust Invest website;
      • contact us (through the website, or by email or phone) or request that we contact you;
      • make investments using cards or accounts linked to your Itrust Invest account; or
      • participate in promotions or competitions run by or with the support of Itrust Invest.
    • You may choose to provide us with access to certain personal information stored by third parties such as social media sites. The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your Itrust Invest account and authorising Itrust Invest to have access to this information, you agree that Itrust Invest may collect, store and use this information in accordance with this Privacy Policy.

If you do not provide us with the information we request, our ability to supply you with products or services, or to otherwise fulfil the purpose for which you have provided your information may be limited.

We will collect personal information directly from you, but may also collect information about you from third parties. If we receive information about you from someone else, we will take reasonable steps to make you aware of the fact and circumstances of the collection.

  • Use and disclosure of personal information
    • We will only use and disclose your personal information in accordance with Privacy Laws and this Privacy Policy.
    • We may share your Personal Information with:
      • our affiliates and related companies;
      • the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification, marketing, and technology services;
      • financial institutions that we use to provide you with services, or that we may partner with to create and offer a product or service;
      • companies who may invest in us;
      • law enforcement, government agencies or officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Itrust Invest; when we need to do so to comply with law or credit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent financial loss, to report suspected illegal activity or to investigate suspected violations of our terms of use.
    • Our main purposes for collecting, holding, using and disclosing personal information are the following:
      • to supply products or services to our customers;
      • to obtain products and services from our suppliers;
      • to respond to enquiries from existing or prospective customers seeking information about our products or services;
      • to improve the products and services that we supply to you;
      • to carry out processes associated with the services we provide, including fraud screening, identity verification, electronic funds transfers and account monitoring;
      • to process and assess employment applications;
      • to enforce agreements between you and Itrust Invest;
      • to conduct competitions and trade promotions;
      • to comply with legislative and our policy requirements;
      • for the purposes of conducting analysis about the deployment and use of our products and services and the technology that supports our products and services, in Australia or elsewhere;
      • to provide information to, and respond to queries from, shareholders or suppliers.
    • We generally explain at the time we collect personal information how we will use or disclose that information. We will only use or disclose personal information for a purpose other than for which it was collected if you have consented to such different use or disclosure or such use or disclosure is otherwise allowed by the Privacy Laws.
    • In carrying out our business, it may be necessary to share information about you with and between our related entities and organisations that provide services to us, including to third party retailers from whom you have made purchases as part of a promotion linked to your Itrust Invest.
    • We may aggregate information that we collect and use it for purposes outside the scope of this Privacy Policy. Any aggregated data used for those purposes will have all personally identifiable information removed.
  • Service providers
    • We use service providers to help us provide our products and services, and to carry out our business operations. This includes independent contractors and consultants, off-site security storage providers, and providers of electronic fund transfer services, account monitoring, account aggregation and identity verification services. You agree that we may provide your personal information to these service providers to use in connection with the supply of services to you and that they may provide us with your personal information to enable us to provide services to you.
    • We may also provide your personal information to third parties who offer goods or services that you may be interested in.
  • Disclosure of information outside the jurisdiction of collection
    • We may disclose personal information outside Australia but only to the extent it is necessary to perform our business functions or activities. In the conduct of our business we may transfer and disclose personal information to contracted service providers and organisations with whom we partner to provide services and whose data warehouses may be located outside Australia including the United States of America, Japan and Singapore. The privacy laws of those countries may not provide the same level of protection as the laws of Australia but this does not change our commitments to safeguard your privacy and we will comply with all applicable laws relating to the cross-border data disclosure.
    • Itrust Invest requires any overseas organisation which receives personal information held by iTrust to enter into a contractual arrangement protecting your personal information.
  • Direct marketing
    • We may use personal information you have provided to us to send you information about your account and our services or other items or material that you may be interested in. We will only contact you if you have consented to receive such messages.
    • If you receive promotional information from us and do not wish to receive this information any longer, please contact us directly, or use the unsubscribe facilities included in our marketing communications.
    • If you have an account with Itrust Invest, we will use your personal information to send you messages containing important information about your account. These messages are an important part of the service that we provide to you and will be sent to you as long as you hold an account with us. Customers with an account cannot opt-out of receiving these messages.
    • We may provide your personal information to third parties who offer goods or services that you may be interested in. These third parties may contact you directly in relation to those goods or services.
  • Digital technologies
    • We may use digital technologies such as cookies, location services, web server logs and web beacons in connection with the Itrust Invest website, social media pages and other digital portals. Some of these technologies may operate without collecting or using any personal information.
    • We sometimes use cookie technology on our websites to provide information and services to web site visitors. Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes and are a necessary part of facilitating online transactions. Most web browsers are set to accept cookies. Cookies are useful to estimate our number of members and determine overall traffic patterns through our websites.
    • If you do not wish to receive any cookies you may set your browser to refuse cookies. This may mean you will not be able to take full advantage of the services on the website.
  • Links to other websites
    • Our websites may contain links to third party websites. These linked sites are not under our control and we are not responsible for the content of those sites nor are those sites subject to our Privacy Policy. Before disclosing your personal information on any other website we recommend that you examine the terms and conditions and Privacy Policy of the relevant site. Itrust Invest is not responsible for any practices on linked websites that might breach your privacy.
  • Employee information
    • This Privacy Policy does not apply to the handling of information about employees by us. For information about our practices relating to employee information please contact support@itrustinvest.com
  • Recruitment
    • If you send us an application for a position, this information will be used to assess your application. This information may be disclosed to related bodies corporate and service providers for purposes such as:
      • aptitude, psychological and medical testing; and
      • other human resources management activities.
    • As part of the application process you may be asked for your specific consent to the use and disclosure of certain personal information about any pre-employment medical examination or any aptitude or psychological testing. We may also ask you to consent to the disclosure of your personal information to those people who you nominated to provide references.
    • A refusal to provide any of this information, or to consent to its proposed disclosure may affect the success of the application.
  • Accessing and correcting the information we keep about you
    • If at any time you want to know exactly what personal information we hold about you, you are welcome to request access to your record by contacting us at support@itrustinvest.com. Our file of your information will usually be made available to you within 21 days.
    • If at any time you wish to change personal information that we hold about you because it is inaccurate or out of date, please either update your account information directly or contact us at support@itrustinvest.com and we will amend this record. If you wish to have your personal information deleted, please let us know in the same manner as referred to above and we will take all reasonable steps to delete it unless we need to keep it for legal reasons.
  • Storage and security of your personal information
    • We take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate, up to date and complete. Your information is stored on secure servers that are protected in controlled facilities. We require our employees and data processors to respect the confidentiality of any personal information held by us.
    • If we become aware of unauthorised access to or disclosure of your personal information we will take appropriate steps to rectify the data breach and will notify you in accordance with the requirements of the Privacy Laws.
  • Retention of information
    • When we no longer need to use your information, or are no longer required to retain it by law, regulation or policies, we will take steps to properly de-identify or destroy it.
  • Contacting Us
    • If you have any concerns or complaints about how we handle your personal information, or if you have any questions about this policy (see also our Complaints Handling Policy), please contact us in writing at:

Stapleton Asset Management Limited as responsible entity for
iTrust Investment Fund (ARSN 625 636 231)
290 Victoria Street,
Darlinghurst NSW 2010
Australia; or:



  • Future changes
    • We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version of the policy on the Itrust Invest website. If at any point we decide to use personal information in a manner materially different from that stated at the time it was collected we will notify users by email or via a prominent notice on our website, and where necessary we will seek the prior consent of our users.