Privacy Policy

We respect your privacy
1. Manning Asset Management respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the Australian Privacy Principles (APPs) established by the Privacy Act 1988 (Cth) (Privacy Act).This policy sets out how we collect and treat your personal information
2. By visiting our website, engaging with us to provide you with products or services, or otherwise connecting with us, you acknowledge that you understand and agree to the terms of this Privacy Policy.
Types of personal information
1. When used in this Privacy Policy, the term ‘personal information’ has the meaning given to it in the Privacy Act. Under the Privacy Act, personal information means information or an opinion (whether true or not) about an identified individual, or which can be used to reasonably identifythat individual. It does not include anonymised or aggregated data.
2. In the course of providing products and services toyou, or otherwise interacting with you, we may collect, hold, use and discloseyour personal information when it is reasonably necessary for the performanceof our functions and activities, and for legal and regulatory compliancepurposes. This information may include, but is not limited to, your:
  - Name, residential address, email address and othercontact details
  - Date of birth, nationality, and country of birth
  - Financial information (including bank account details)
  - Professional qualifications and experience
  - Government identifiers (such as your drivers’ licence number, your passport number, your Medicare number) for ‘Know Your Customer’ purposes required by the Anti-Money Laundering and Counter-TerrorismFinancing Act 2007 (Cth)
  - Tax File Number (TFN) where relevant andpermitted.
3. Manning Asset Management is unlikely to collectsensitive information from or in relation to you. Sensitive informationincludes information about your race, ethnic origin, political opinions,religious or philosophical beliefs, trade union memberships, or details aboutyour health, and is subject to greater restrictions relevant to its collectionand use. If the collection of sensitive information is required, it will onlybe collected with your express consent and only used for the purpose for whichit was provided.
‍Collection of your personal information
1. Manning Asset Management collectspersonal information from you in a varietyof ways, including when you interact with us electronically or in person, when youaccess our website, when youprovide us with completed forms, when you ask to beplaced on one of our mailing lists, when you respond to surveys or promotions, when you like,follow and/or post to any of our social media pages, when youregister for one of our events, and when you communicate with our customersupport.
2. In limited circumstances we may collect or receive your personal information from third parties, including yourfinancial adviser, identification verification services, and governmentagencies like the Australian Securities and Investments Commission (ASIC).If we do, we will, whenever reasonably possible, make you aware that we havedone this and why, and we will protect this information as set out in thisPrivacy Policy.
3. In the event we collect personal information in circumstances where we have not requested or solicited that information (known as ‘unsolicited information’), and it is determined by us (in our absolute discretion) that the personal information is not required, we will destroy the information or ensure that the information is de-identified.
4. Manning Asset Management willassume that you have consented to us collecting, using and disclosing (inaccordance with this Privacy Policy) the information that you provide to us,unless you tell us otherwise at the time of collection.
5. If you choose not to provide thepersonal information that we request, or provide us with incomplete orinaccurate personal information, we might be prevented from providing you withinformation about, or access to, the products and services we offer.‍‍
‍Use of your personal information
1. Manning Asset Management uses your personal information for the primary purpose of:
  - Performing administrative and operational functions associatedwith providing you withaccess to our products and services;
  - Managing our relationship withyou and responding to your questions, enquiries and complaints; and
  - Complying with our legal and regulatoryobligations.
2. We may also use your personal information for secondary purposes including generating awareness about new and additional products,services and opportunities we make available to our clients from time totime, and improving ourproducts and services by gaining a better understanding of our clients’ needs.If at any time you do not wish to receive these marketing communications, youmay ask us not to send those to you.
3. Manning Asset Management may contact you by a variety of measures including telephone, email, SMS and mail.
4. Manning Asset Management doesnot make decisions or provide products or services based solely on theautomated processing of data, including profiling, which can produce legaleffects that significantly affect the individuals involved.
Disclosure of your personal information‍
1. We do not routinely disclose your personal information to third parties unless:
  - You have provided consent;
  - Disclosure us reasonably expected in the context;
  - Disclosure is required or authorised by law; or
  - A permitted general situation under the APPs applies.
2. We may discloseyour personal information to any of our employees, officers, service providers, insurers, professional advisers, agents,suppliers or subcontractors insofaras it is reasonably necessary for us to be able to provide our products andservices to you.
3. We may from time to time need todisclose your personal information in order to comply with a legal requirement,such as a law, regulation, court order, subpoena, warrant, in the course of alegal proceeding or in response to a law enforcement agency request.
4. In certain cases, we maydisclose your personal information to the ATO and/or ASIC, which may exchangethis data with overseas regulators as required under the Common ReportingStandard (CRS) and the Foreign Account Tax Compliance Act (FATCA).
5. Information that we collect may from time to time be stored, processed in or transferred betweenparties located in countries outside of Australia.
6. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer, to the extent permissible at law, our customer databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
7. By providing us with personal information, consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy is implied. Where we disclose your personal information to third parties, we will take reasonable steps to ensure that the recipient will handle your personal information in a manner consistent with the APPs.
Direct marketing
1. Your personal information will never be added to a general marketing database. We do not sell, rent or trade your personal information to or with third parties for the purpose of allowing them to send marketing material directly to you.‍
‍Security of your personal information
1. Manning Asset Management is committed to ensuring that the personal information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your personal information and protect it from misuse, interference, loss, and unauthorised access, modification or disclosure.
2. For this reason, we must be certain of your identity before we can discuss your account with you. If you contact us to discuss your account, you must be able to prove your identity. This ensures that we are able to protect your personal information by only giving it to you or someone who can prove that they are lawfully authorised to act on your behalf. If you have a general enquiry that does not involve discussing your personal information, you do not have to provide identification. In these situations, you will be able to deal with us without identifying yourself.
3. All personal information is stored electronically on secure systems provided by cloud service providers. Access to these systems is restricted and controlled via passwords, encryption, and firewalls in line with Australian information security standards. We do not store personal information in hardcopy form.
4. Access to personal information is limited to those individuals or entities who require the information to perform a specific task or function.
5. Your personal information is only retainedfor as long as necessaryto fulfil the purpose/s for which it wascollected, unless we are required to retain theinformation for a certain period of time under an Australian law or court or tribunal order. Once no longer required, we take such steps as are reasonable in thecircumstances to destroy or permanently de-identify your personal information.
6. The transmission and exchange of information electronically is carried out at your own risk.Although we take measures tosafeguard against the unauthorised disclosure of information transmittedelectronically, we cannot guarantee the security of any information that youtransmit to us, or receive from us, electronically, unless we have indicatedbeforehand that a particular transaction or transmission of information will beprotected (for example, by encryption).
Access to your personal information
1. You may request details of the personal information that we hold about you in accordance with the provisions of the Privacy Act. A small administrative fee may be payable for the provision of information. If you would like a copy of the information which we hold about you or believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at info@manningam.com. We will assess your request and respond within a reasonable timeframe (typically within 30 days).
2. We reserve our right to refuse your request for access to, or correction or deletion of, your personal information if, for example, we consider your request to be frivolous or vexatious, or if we are legally entitled to do so. If we refuse your request, we will give you our reasons in writing and information about how to make a complaint about the refusal.
Website‍
1. When you visit our website (www.ManningAM.com) we may collectcertain information such as browser type, operating system, websitevisited immediately before coming to our site, etc. This information is used in an aggregated manner to analysehow people use our site, such that we can improve our service.
2. We may from time to time use cookieson our website. Cookies are very small files whicha website uses to identify you when you come back to the site and tostore details about your use of the site. Cookies are not malicious programsthat access or damage your computer. Most web browsers automatically acceptcookies, but you can choose to reject cookies by changing your browsersettings. However, this may prevent you from taking full advantage of ourwebsite.
3. Our website may from time to timeuse cookies to analyse website traffic and help us provide a better websitevisitor experience. In addition, cookies may be used to serve relevant ads towebsite visitors through third party services such as Google Adwords. These adsmay appear on this website or other websites you visit.
4. Our website may from time to timehave links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship orendorsement or approval of these websites. Manning Asset Management is notresponsible for the privacy practices of other such websites. We encourage ourusers to be aware, when they leave our website, to read the privacy statementsof each and every website that collects personal identifiable information.
‍Social networking platforms
1. Whilst we may use social networking platforms, such as LinkedIn, for communications, we won’t ask you to supply personal information publicly over these platforms.
2. Any personal information that you contribute to the publicly accessible sections of social media applications can be read, collected and used by other users of the application. We have little or no control over these other users and cannot guarantee that any information that you contribute to any social media applications will be handled in accordance with our privacy standards.
Data breaches
1. If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which willinclude an assessment of whether the incident is likely to result in seriousharm to any individuals.
2. In the event of an eligible databreach occurring, we are required by the Privacy Act to notify theindividual/s impacted and the Office of the Australian Information Commissioner (OAIC). For example, if a database containing personal information ishacked or personal information is mistakenly provided to the wrong person, andwe have not been able to prevent the likelihood of serious harm because of thebreach.
3. Our notification will be sent as soon as practicable and will contain a description of the data breach, the kinds of information concerned, the steps we have or will take to rectify the data breach, and recommendations about the steps that the impacted individual/s should take in response to the data breach.
4. Please contact us at info@manningam.com if you have reason to believe or suspect that a data breach might have occurred, so that we can investigate and, if necessary, undertake appropriate containment, notificatio and remefiation activites.
Complaints about privacy‍
1. If you are dissatisfied or have a complaint about our privacy practices, we encourage you to contact us.
  
  The Complaints Officer
  
  Manning Asset Management Pty Ltd
  Level 17, Tower 3, 300 Barangaroo Avenue, Barangaroo NSW 2000 Australia
  Email: info@manningam.com‍
2. We’ll acknowledge your complaint within one business day of its receipt, and aim to resolve your complaint within five business days.
3. If we’re unable to resolve your complaint within five business days, we’ll consider and provide a response to your complaint with 30 calendar days of its receipt.
4. If you’re not satisfied with our response or you have not received a response within the required timeframe, you may be able to refer your complaint to the Australian Financial Complaints Authority (AFCA), an independent dispute resolution service established by the Government.
  
  Australian Financial Complaints Authority
  
  GPO Box 3 MELBOURNE VIC 3001
  Phone: 1800 931 678
  Email: info@afca.org.au
  Website: www.afca.org.au‍
5. Time limits may apply, and we encourage you to act promptly or otherwise consult the AFCA website to find out if or when the time limit relevant to your circumstances expires. Complainants are encouraged to pursue internal dispute resolution before making a complaint to AFCA.
More information about your privacy rights
1. If you would like more information about your privacy rights, you can contact the Office of the Australian Information Commissioner (OAIC). Australian Financial Complaints Authority
  
  Attention: Director of Compliance
  GPO Box 5218 Sydney NSW 2001
  Phone: 1300 363 992
  Email: enquiries@oaic.gov.au

Changes to our policy
1. We may revise or update this Policy at any time, in our sole discretion, by posting it on our website. The current version at the time we collect or use your personal information is the version that will apply. Please check back from time to time to review our Privacy Policy.

‍

Version 5.0‍

Updated March 2026

DOwnload terms