Privacy Policy

Lazard Asset Management Pacific Co. Privacy Policy

In this Privacy Policy the expressions "Lazard Pacific", “Lazard Pacific entity”, "we", "us" and "our" are references to Lazard Asset Management Pacific Co. ABN 13 064 523 619 AFS Licence 238432 and those Australian registered bodies corporate related to it.

We are subject to the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth).

This Privacy Policy explains how we protect the privacy of any personal information we collect about you, whether you provide it to us via our website or other method or under any agreement or arrangement with us and to information which we might collect about you from other sources.

This Privacy Policy does not apply to acts and practices of Lazard Pacific which relate directly to the employee records of Lazard Pacific’s current and former employees.

How we collect and hold personal information

We generally collect your personal information directly from you. The types of personal information we collect depends on who you are and our dealings with you. For example, we may collect personal information about you when you deal with us over the telephone, (including recordings of those telephone conversations of which we have made you aware), send us correspondence (whether by letter, fax or email), attend a seminar or conference we arrange either by ourselves or in conjunction with others, contact us through our Australian website at www.lazardassetmanagement.com.au, submit a completed product application form or other form to us, submit identification documents, make a payment, subscribe electronically to our website/publications if available, or when you have contact with us in person. We also collect personal information about you when you apply for a position with us.

Generally, the type of personal information we collect about you includes your name, date of birth, mailing address, telephone number and e-mail address and any other personal information required to identify you for the purposes of Australian anti-money laundering and counter terrorism financing legislation. We may also collect your username and password to log in to our website and the organisation for which you work, your position in the organisation and the dealings we have had with you during your employment with that organisation. We may need to collect your bank account details, details about the type of investor you are, your directorships and if you are a trust beneficiary. In certain circumstances, we may also collect sensitive information about you such as information about membership of a professional or trade association, or membership of a trade union or police records of prospective employees. We may also collect your tax file number and other details in relation to your taxation position, when you make an application for one of our products.

There may be occasions when we need to source personal information about you from a third party. For example, we may collect personal information from a customer who provides your details in a product application form, a company for whom you work, other organisations with whom you have any dealings, a recruitment agency, a credit-reporting agency in relation to employment checks, including criminal checks and police records, an information service provider or from a publicly maintained record.

We may also collect website visitors' contact information (like their e-mail addresses). We utilise "cookies" which enable us to monitor traffic patterns and to serve you more efficiently if you revisit the website. Please refer to our Cookie Policy here.

You may choose not to identify yourself, or to use a pseudonym when you deal with us. However we will need to identify you if we are required or authorised by Australian law (such as anti-money laundering and counter terrorism financing legislation), or a court/tribunal order to do so or if it is impracticable for us to deal with you if you are not identified.

Purposes of collection

Lazard Pacific collects personal information for any one or some of the following purposes:

• to provide you or your organisation with information about our product offerings;
• process payments to us or credits to you;
• to service our relationship with you, including managing your investments, responding to complaints or disputes you may have about our services and providing you with information from time to time about your investments;
• to consider making offers of employment or for employment purposes;
• to receive services from you or the organisation which employs you;
• to advise you of new investment developments and to undertake other marketing activities such as informing you about any of our products and services or events that we think may be of interest to you, or
• to comply with our legal obligations including under our financial services licence.

If you do not provide some or all of the information requested, we may not be able either to provide you with an appropriate level of service or to fulfil another applicable purpose of collection.

If we receive personal information about you that we have not solicited, we will determine within a reasonable time if we could have collected it for any of the purposes listed above (which may require us to use or disclose it to do so). If we decide we could not have collected the information and it is not in a Commonwealth record, we will destroy or de-identify the information as soon as possible. Otherwise we will handle the information in accordance with this policy.

How we use or disclose your personal information including overseas.

We will use and disclose personal information for the primary purpose for which it was collected or for any purpose for which you have consented. We may also use and disclose personal information for related purposes, such as dealing with any complaints or disputes you may have about our services and also to provide to you of information concerning investment developments and other services offered by us.

To enable us to verify your identity, we may disclose personal information such as your name, date of birth, and address to a credit reporting agency (CRA) to obtain an assessment of whether that personal information matches information held by the CRA or accessed by the CRA (including as your agent) from its third party data sources to which your personal information may also be disclosed. The CRA may give us, and may retain for its own use, a report on that assessment and to do so the CRA and third-party data sources may use personal information about you and other individuals in their files. Alternative means of verifying you are available on request. If we are unable to verify your identity using information held by a CRA we will provide you with a notice to this effect and give you the opportunity to contact the CRA to update your information held by them or verify your identity using an alternative method acceptable to us.

We may disclose your personal information to our related bodies corporate, your consultant, custodian, asset consultant, broker, or financial adviser on your behalf or to your external professional service providers such as auditors, accountants or lawyers. We do not disclose personal information we collect to third parties for the purpose of allowing them to direct market their products and services to you. We engage third party contractors to perform services for us which involves the contractor handling personal information we hold. For example, we engage third party contractors such as Lazard Asset Management LLC, our parent company, to provide investment management services. In these situations, we prohibit the third party contractor from using personal information about you except for the specific purpose for which we supply it.

We may disclose your personal information to entities located outside Australia as part of the management of our business, for example, for the purpose of aggregating our information databases internationally to Lazard Asset Management LLC located in the United States.

Requesting access to information we hold about you

We will, on request, provide you with access to the personal information we hold about you unless there is an exception that applies under APP12 such as where we have a legal duty of confidentiality. To make a request please contact us using the details in the contact section below. We will need to verify your identity before we give you access.

Your request to obtain access will be dealt with in a reasonable time. Lazard Pacific may recover from you its reasonable cost of providing you with access.

If we refuse to provide you with access to the information, we will provide you with written reasons for the refusal and inform you of any exceptions relied upon under APP12 and explain how you can complain if you are not satisfied with our decision.

Correcting your personal information

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect it, and also when we use or disclose it, that it is relevant.

If you believe that any of the personal information we hold about you is inaccurate, incomplete, out-of-date, irrelevant or misleading please contact us immediately using the details in the contact section below and we will take reasonable steps to correct this information or, if necessary, we will discuss alternative options with you. If we refuse to correct the information, we will provide you with written reasons for the refusal and how you can complain if you are not satisfied with our decision.

We will also correct your personal information if we are otherwise satisfied it is inaccurate, incomplete, out-of-date, irrelevant or misleading having regard to the purposes for which it is held by us.

Security of your personal information

We take reasonable steps to protect the personal information that we hold from misuse and loss and from unauthorised access, modification and disclosure.

Your personal information may be stored either in hard copy documents or as electronic data in Lazard Pacific's software or systems or transferred to outside contractors for storage purposes.

We maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer system.

Privacy complaints

If you believe that we may have breached the APPs in relation to our handling of your personal information, you may complain to us and we will take steps to respond and resolve your complaint as soon as possible. We may need to request further information from you to do this. To make a complaint please email or write to us at the contact details below and include sufficient details about your complaint. If we cannot resolve your complaint to your satisfaction you may make a complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to do this are available at www.oaic.gov.au.