SL Group Management Pty Ltd ACN 622 879 805 (‘Secured Lending’) is acting as Trust Manager for the SL Premium Income Fund. The trustee of the unregistered managed investment scheme is SL Premium Income Fund Pty Limited ACN 664 382 076 (Australian Financial Services Licence Number: 549857).

This privacy policy sets out how Secured Lending and our related businesses (we/us/our) collect, use and disclose the personal information we hold about you.

Our commitment to protect your privacy

We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law.  It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

We are committed to protecting your personal information by abiding by the Australian Privacy Principles (APPs), the Privacy Act 1988 (Cth) (Privacy Act) and any other relevant law.

Personal information

When we refer to personal information, we mean information from which your identity is reasonably apparent, which may include information or an opinion about you.  The kinds of personal information we may collect about you include your name, date of birth, address, account details, occupation, and any other information we made need to identify you.  When you use our website or mobile applications, we may collect information about your location or activity, including IP address, telephone number and whether you have accessed third party sites, the date and time of visits, the pages that are viewed, information about the device used, and other user location information. 

Why we collect your personal information

We collect personal information for the purposes of assessing your application for investment and managing that investment, establishing your identity, contacting you, managing our risk, and to comply with our legal obligations.  We may also collect your personal information for the purposes of direct marketing and managing our relationship with you.  Improvements in technology also enable organisations like ours to collect and use information to get a more integrated view of our customers.  We may offer you other products and services from time to time.

How we collect your personal information

Where reasonable and practical, we will collect your personal information directly from you.  We may collect information about you that is publicly available, such as from public registers or social media, or made available by third parties.  We may also collect your personal information from third parties including credit reporting bodies, finance brokers, employers, and other people such as accountants and lawyers.

Disclosing your personal information

We may disclose your personal information:

• to other intermediaries in relation to your investment requirements;
• to other organisations that are involved in managing or administering your investment, such as third party suppliers, printing and postal services, call centres, insurers and credit reporting bodies;
• to associated businesses that may want to market products to you;
• to companies that provide information and infrastructure systems to us;
• to our agents, contractors or external service providers to outsource certain functions, for example, information technology support;
• to any person who represents you, such as finance brokers, lawyers, guardians, persons holding power of attorney and accountants;
• to anyone where you have provided us consent;
• to other joint-investors (if more than one);
• to our auditors, insurers and re-insurers;
• where we are authorised to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), or by government and law enforcement agencies or regulators;
• to investors, agents or advisers, trustees, rating agencies or any entity that has an interest in your investments or our business;
• to other financial institutions, for example to process a claim for mistaken payment;
• organisations that provide products or services used or marketed by us; or
• to your employer, former employer, referees or identity verification services.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

1. the person or organisation has a commitment to protecting your personal information at least equal to our commitment; or
2. you have consented to us making the disclosure.

Direct marketing

We may use your personal information from time to time to provide you with current information about investments, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with which we are associated.

You may at any time opt out of receiving marketing information by phoning us on 1300 795 175 or by writing to us at privacy@securedlending.com.au.  If we are sending you direct marketing by email, you may also use the unsubscribe function.  We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

Updating your personal information

It is important to us that the personal information we hold about you is accurate and up-to-date.  During the course of our relationship with you, we may ask you to inform us if any of your personal information has changed. 

If you wish to make any changes to your personal information, you may contact us.  We will generally rely on you to ensure that the information we hold about you is accurate or complete.

Accessing and correcting your personal information

We will provide you with access to the personal information we hold about you.  You may request access to any of the personal information we hold about you at any time.  We may charge a fee for our costs of retrieving and supplying the information to you.

Depending on the type of request that you make, we may respond to your request immediately.  Otherwise, we usually respond to you within seven days of receiving your request.  We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, if your request is vexatious, or if the information is commercially sensitive.

If we deny you access to the personal information we hold about you, we will explain why.

If any of the personal information we hold about you is incorrect, inaccurate or out-of-date, you may request that we correct the information by phoning us on 1300 795 175 or by writing to us at privacy@securedlending.com.au.

If appropriate, we will correct the personal information at the time of your request.  Otherwise, we will provide an initial response to you within seven days of receiving your request.  Where reasonable, and after our investigation, we will provide you with details about whether we have corrected your personal information within 30 days.

We may need to consult with other financial services providers or entities as part of our investigation.

If we refuse to correct personal information, we will provide you with our reasons for not correcting the information. 

Business without identifying you

In most circumstances, it will be necessary for us to identify you in order to successfully do business with you.  However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information (for example, if you make general inquiries about interest rates or current promotional offers).

Sensitive information

We will only collect sensitive information about you with your consent.  Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.

Safety and security of your personal information

We will take a range of measures and reasonable steps to protect your personal information.  Your personal information will always be stored in a secure environment.  We may store your personal information in paper and electronic form.  We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure. 

Complaints

If you are not satisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact our complaints officer on 1300 795 175 or by writing to us at privacy@securedlending.com.au.

We will acknowledge your complaint within seven days and aim to resolve the complaint as quickly as possible.  We will provide you with a decision on your complaint within 30 days.

If you are not satisfied  with the response of our complaints officer, you may make a complaint to the AFCA scheme, which can be contacted by phone on 1800 931 678, by email at info@afca.org.au, or in writing to GPO Box 3, Melbourne VIC 3001, or the Privacy Commissioner which can be contacted at either www.oaic.gov.au or by phone on 1300 363 992.

Further information

You may request further information about the way we manage your personal information by contacting us on 1300 795 175 or by writing to us at privacy@securedlending.com.au.

Changes to our privacy policy

We may change this policy from time to time or as the need arises.  We will post any changes to this policy on our website.

You may request this policy in an alternative form by phoning us on 1300 795 175 or by writing to us at privacy@securedlending.com.au.

This policy was last updated in February 2024.