Portfolio Manager

Thomas Charles Dobson Millner, B.Des (Industrial), GDipAppFin, F Fin, GAICD

We are subject to the operation of the Privacy Act 1988 (Cth) (Privacy Act). This policy explains how we handle personal information relating to individuals, whether or not they are customers, so as to ensure we meet our obligations under the Act.

In this policy the expressions “we”, “us” and “our” are a reference to BKI Investment Company Limited.

The expressions “you” and “your” refer to each and every individual whose personal information we may handle from time to time.

The expression “personal information” is used in this policy to refer to information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Types of information collected
We only collect personal information to the extent that this is reasonably necessary for one or more of our functions or activities.
This includes the following kinds of information:
(a) Names;
(b) addresses, email addresses, and other contact details;
(c) date of birth, age, employment status and history, general financial information;
(d) financial information relating to your investment in BKI Investment Company.

We note that shareholder information such as bank account details and tax file number (TFN) are collected by our share registry, and we do not have access to this information. Please refer to the Privacy Policy of Advanced Share Registry Limited for details on how they manage the privacy of this information.


Method of Collection
Our preference is to collect personal information about an individual direct from that individual unless it is unreasonable or impracticable for us to do so.

Information will generally be collected from the following sources:
(a) the subscription page of our website;
(b) your telephone, email, or written correspondence to us;
(c) telephone, email, or written correspondence to us by your broker, accountant, or other financial or legal advisor;
(d) face to face investor meetings or presentations you attend;
(e) your application for work experience or employment with us; and
(f) your investment in BKI Investment Company Limited.

We may also collect personal information from other organisations and people (third parties) where it is not reasonable or practical to collect the information directly from you. Such third parties include, but are not limited to, our share registry, Advanced Share Registries Limited; investor communication and voting service providers who assist us in capital raising and shareholder communication activities; independent financial planners and stock brokers.

Purposes of collection
Purposes for which we may collect personal information include, but are not limited to:
(a) establishing your identity;
(b) managing your investment;
(c) providing you with updates in relation to your investment;
(d) engaging with investors, potential investors, investment advisors and other investment professionals;
(e) complying with our legal obligations, and assisting government and law enforcement agencies and/or regulators;
(f) suppliers and consultants, paying compensation for services provided; and
(g) any other activity consistent with our business.

Use and disclosure
We will not use or disclose personal information for the purposes other than those connected with the primary purpose of collection.

Direct marketing
We will not use or disclose personal information for the purposes of direct marketing to you unless:
(a) you have consented to receive direct marketing materials; or
(b) you would reasonably expect us to use your personal details for this purpose; or
(c) we believe you may be interested in the material but it is impractical for us to obtain your consent.

In every instance, we will ensure that our direct marketing material incorporates an option for you to elect to receive no further such communications.
Please note also that even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of information. This form of communication is not regarded as “direct marketing” under the Privacy Act.

Storage of data
Typically, we will store personal information in a variety of formats including on databases, on personal devices such as laptops and mobile phones, and in hard copy files.
In addition, it is possible that we will utilise cloud technology in connection with the storage of personal information, and it is possible that this may result in off-shore storage. It is not practicable for us to specify in advance which country will have jurisdiction over such off-shore activities.

Employee records
In accordance with the Privacy Act, this policy does not apply to our acts and practices directly related to a current or former employment relationship between us and an employee, and an employee record held by us relating to the employee.

Data security
We will take reasonable steps to protect the personal information which we hold from misuse or loss and from unauthorised access, modification or disclosure. We will destroy or de-identify personal information once we no longer require it for our business purposes.

When using our website you should be aware that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you transmit to us over the Internet and you do so at your own risk.

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.
You may obtain a copy of our current policy from our website or by contacting us on the details below. It is your responsibility to check the website from time to time in order to determine whether there have been any changes.

Access, correction and further information
We will take such steps as are reasonable to ensure that the personal information which we collect remains accurate, up to date and complete.
We will provide you with access to your personal information held by us unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us via the details below if you:
(a) wish to have access to the personal information which we hold about you;
(b) consider that the personal information which we hold about you is not accurate, complete or up to date; or
(c) require further information on our personal information handling practices.

Contact Details:
Amanda Wong
Company Secretary
BKI Investment Company Limited
Suite 302, Level 3
1 Castlereagh Street

Tel: 61-2-7251-6242
Fax: 61-2-8355-1617
Email: info@bkilimited.com.au

There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in actually providing you with access.
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Act, to correct that information if you so request.
We will respond to all requests for access and/or correction within a reasonable time.

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should advise us via the above contact details.
If you remain unsatisfied with the way in which we have handled a privacy issue, we suggest you approach an independent advisor or contact the Office of the Australian Information Commissioner for guidance on alternative courses of action which may be available. We will provide our full cooperation in the event that you elect to pursue this course of action.