Funds Management Advisory | LICENSING & COMPLIANCE | Fund Services | CORPORATE ADVISORY
Privacy Policy


D H Flinders is a specialist funds management advisory business providing a range of services to established, international and start-up investment managers. Fully owned subsidiary, DHF Investment Managers Pty Ltd, provides fund services including acting as general partner of private equity and venture capital companies and trustee of alternative investment funds. As well as funds management advisory services, D H Flinders provides capital markets adviosry services and is the creator and host of the Annual Australian Microcap Investment Conference that provides an opportunity for the chief executives of ASX listed microcap companies across a range of industries to present to an audience of institutional investors.


At D H Flinders we recognise the importance of safeguarding your privacy and are committed to protecting your privacy and safeguarding your personal information. D H Flinders is committed to complying with the Australian Privacy Principles which set the standard for how organizations should deal with personal information. The Australian Privacy Principles (the APPs) are found in amendments to the Privacy Act 1988 which are effective from 12 March 2014.

Australian members of our company are bound by the Privacy Act and the Australian Privacy Principles (APPs), upon which this policy is based.

Effective implementation of this policy and procedure will help ensure that investor confidence in the integrity of D H Flinders is maintained.


This policy is authorised by D H Flinders Pty Ltd (ABN: 161 141 601 596) and its Australian related entities.


Whenever it is reasonable and practicable to do so, we only collect information about individuals directly from individuals.

The type of imformation collected by us will depend upon your relationship with D H Flinders and may include :

  • name and title
  • address
  • contact details
  • detail on entities through which you invest
  • date of birth
  • bank accounts details
  • employment details
  • citizenship
  • detail on your nominated beneficiaries (for friendly society bonds)
  • shareholders details (for shareholders in D H Flinders Pty Ltd)
  • Australian Tax File Number

In most cases, and wherever possible, D H Flinders will try to collect personal information only from you. Information will be collected through various company forms and from you directly, either in writing or verbally.

Personal information is information or an opinion about you from which you can be reasonably identified. D H Flinders collects personal information so that we can provide you with our products and services and comply with our legal obligations such as those under superannuation laws, taxation laws and the Anti-Money Laundering and Counter-Terrorism Financing Act. If D H Flinders does not collect your personal information, we may not be able to provide you with a product or service.

We do not generally collect sensitive information about individuals unless required by applicable laws or rules. Sensitive information includes information relating to:

  • race
  • political or religious beliefs
  • sexual preferences
  • crimimal convictions
  • membership or professional or trade associations or unions
  • health information

We also collect personal information from people who submit applications or register interest for employment with D H Flinders.

In addition, we may collect personal information about individuals who are not customers of D H Flinders (e.g. business contact details of a company representative with whom we deal).

Depending on how you choose to interact with us, we may collect your personal information when you contact us or our service providers by telephone, by email, thorugh our website, complete an application or registration form, or when you meet one of our representatives face to face.

D H Flinders may also collect information about you from third parties. For example, D H Flinders may collect personal information from:

  • your authorised representatives and advisor(s);
  • our service providers;
  • your employer; or
  • our corporate clients, where we are providind services to them.


Your personal information is held in our registry systmes for our investors and shareholders.

Generally personal information is stored electronically with hard copy records retained and archived with an archival service provider.

All internal systems are subject to the security measures detailed in this policy. All external service providers are contractually required to hold personal information in accordance with Privacy Act.


D H Flinders collects personal information about your primarily:

  • to provide you with the products and services you request
  • to provide you with the information you request
  • to verify your identity before transactions are processed, your instructions are carried out to administer your financial product
  • to provide you with information about other products or services offered by D H Flinders or its related entities
  • to respond to your enquiries or complaints
  • to satisfy any legal requirements.

Laws and rules regarding the of personal information may vary by jurisdiction. D H Flinders complies with applicable laws and rules in the related jurisdiction.

We may also collectm use and exchange your information on other ways where permitted by law.

D H Flinders does not sell, rent or trade personal information to or with third parties.


The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) is aimed at addressing money laundering in Australia and the threat to national security caused by terrorism. This legislation requires us collect identification information from investors into our investments products and reverse mortgage borrowers and to verify your identity from original or certified copies of specified documents. Details of what identification information and documentation you are required to provide are set out in transactional based forms. We may also contact you to follow up and clarify certain information.

Under this legislation we are also required to monitor transactions to identify any suspicious activity within any of our investments products.

As required under the AML/CTF Act, we may, in our absolute discretion, without notice to you, disclose or otherwise report details of any transaction or activity, or proposed transaction or activity (including any personal information) to the relevant reporting body.


D H Flinders does not sell, rent or trade personal information to, or with, third parties.

In some circumstances your information may be disclosed to D H Flinders' related entities or service providers that perform a range of services on our behalf, such as:

  • outsourced service providers, including administration, custodial and registry service providers; printers and mailing houses, information technology systems
  • software providers, actuaries, professional advisers and research organisations
  • business partners, including insurance underwriters
  • government agencies including APRA, ASIC, AUSTRAC, Centrelink or the ATO
  • related companies
  • financial intermediaries such as financial planners and taxation or accounting advisers.

Where D H Flinders contracts with an outsourced service provider or business partner we take reasonable steps to protect the privacy of any information disclosed to them. This includes inserting confidentiality provisions and a requirement to comply with the Privacy Act in our contractual arrangements.


From time to time D H Flinders may wish to use your information to tell you about other products, services or special offers that we think may be of interest to you. Please let us know if you do not want to receive these offers by contacting us using the contact details noted below.


D H Flinders aims to ensure that the personal information we retain about you is accurate, complete and up to date. Please provide us with complete and accurate information and keep us informed of any changes in your details such as change of address.

If you do not provide all otr part of the personal information that we request we may not be able to contact you or to administer your investment properly.

If you believe that the information we hold about you is inaccurate please contact us directly using the contact details provide below, so that we can update our records.


D H Flinders will at all times take reasonable steps to protect your personal information from misuse, loss, unauthorised accedd, modification or disclosure. Your personal information is treated as confidential.

Employees and contractors of D H Flinders are bound by confidentiality obligations. Password controls, firewalls and virus protection are used by D H Flinders with a view to ensuring the security and integrity of the information technology systems that hold your information.

All premises housing our systems and other copies of your information are monitored and protected by security alarms and access card or key lock entry.

Service providers who hold personal information are contractually required to hold information in accordance with the Privacy Act and D H Flinders obtaind periodic confirmation od adequate information security management.


You are entitled to obtain access to your personal information suject to some exceptions allowed by law. You may also request D H Flinders correct or update information that we hold on you. We encourage our customers to ensure that their personal information is accurate and up to date, particularly mailing address and contact details. We include regular reminders in correspondence with our customers.

If you wish to make a request for access to your personal information please contact us using the details below.


If you have any questions about this privacy policy, if you wish to complain about how we handled personal information about you, or if you wish to access or correct your personal information, please contact D H Flinders' Privacy Officer:

by telephone: 03 8352 7100; or

by email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it ; or

by letter: The Privacy Officer, D H Flinders Pty Ltd, Level 4, 99 William Street, Melbourne VIC 3000


If you have a complaint related to how D H Flinders has managed your personal information, please contact us using the contact informationa below. We may ask you to place your concerns in writing in order for us to fully understand and investigate the issues you have raised. We will acknowledge any complaint in writing within five business days and make every effort to resolve your issue within a reasonable time of us being notified.

If a complaint remains unresolved, you may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. The Commissioner may be contacted on the privacy hotline: 1300 363 992.

When we write to you about our decision, we will explain how you may access an external dispute resolution scheme or make a complaint to the OAIC.

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