Privacy Policy

March 2026

1. INTRODUCTION

Asteri Asset Management Pty Ltd ("Asteri") understands that individuals may be concerned about how we deal with their personal information. Our aim is to deliver the best possible service, and we will only collect the information necessary to enable us to do so.

2. OBJECTIVE

The purpose of this Privacy Statement (Statement) is to ensure that Asteri provides open and transparent advice to individuals about the way in which any personal information that is collected and held by Asteri is appropriately managed, and to ensure that Asteri meets the standards and requirements set by the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APPs).

This Statement is in a format to be distributed to individuals through a website link.

3. OVERVIEW

3.1 What Personal Information is collected?

The types of personal information that are collected and held by Asteri includes information used to identify the client, their financial position and any other related information necessary to provide the client with business services. This may include, but is not limited to:

  • name;
  • contact details;
  • bank account information;
  • tax file number;
  • passport or drivers’ licence;
  • nationality;
  • business structures;
  • employment information;
  • source of wealth; and
  • investment information.

In addition, Asteri is required to collect and hold personal information under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and the Foreign Account Tax Compliance Act 2010 (USA), which may include sensitive information in certain circumstances.

As part of our recruitment process, we may collect personal information from potential employees and their referees. We may also collect sensitive information about potential employees as part of a background checking process. With consent, this information may be disclosed to and obtained from third party agencies that we engage to conduct probity checks on our behalf.

Unless otherwise advised by a potential candidate, we may keep information on file for any future vacancies.  Candidates can request at any time, in writing to the Head of Human Resources, for us to destroy their personal information.

3.2 Consent

Asteri will collect, use, and disclose personal information in accordance with the Privacy Act and the APPs. This will include obtaining consent where required by law. If a relevant individual does not provide some or all of the personal information requested by Asteri, or does not consent to the use, holding or disclosure of personal information where consent is required, Asteri may not be able to provide the products or services required.

3.3 Collection of Personal Information

Asteri can only collect personal information that is reasonably necessary to provide the services it offers and what is required by law. Collection of information that is not reasonably necessary can increase risks in relation to data breaches. 

The way in which Asteri will collect personal information provided by the client includes, the following:

  • face to face or online meetings with clients;
  • the recording of telephone calls;
  • collection of document copies; and
  • Asteri’s website and systems.

Identity Verification

To comply with our legal obligations under the AML/CTF Act 2006, we verify an individual’s identity using electronic matching services.

Electronic Matching: We disclose an individual’s personal and document details (such as name, date of birth, and ID numbers) to our service provider, FrankieOne. FrankieOne facilitates a match against official government records via the Document Verification Service (DVS). This is a "match/no-match" service that confirms whether the details provided match the records held by the government agency that issued the document. We provide a manual review process for any identity matching decisions that may adversely affect access to services.

Consent and Use: We only conduct these checks with an individual’s express consent. The results are used strictly for identity verification and fraud prevention; we do not use this information for marketing or profiling.

Declining Consent: If an individual does not wish to provide express consent for an electronic check, they can contact us to discuss alternative manual verification methods. Note that declining consent may delay or prevent us from providing a client with services.

In some circumstances, Asteri may gather personal information about the client from a third party or from publicly available information. The third parties from whom the business may acquire personal information include, but are not limited to;

  • information service providers;
  • credit agencies;
  • lawyers;
  • accountants and financial advisers;
  • fund managers; and/ or
  • intermediaries and spouses.

Should a third party provide Asteri with a client’s personal information, it is assumed that the client has provided consent for that third party to do so, unless Asteri is notified otherwise.

3.4 Use and Disclosure of Personal Information

Generally, Asteri can only use or disclose personal information that is in context of carrying out the originally intended functions or services.

3.4.1 Use of Personal Information

The purposes for which clients’ personal information will be used depends on the relationship with the client and the nature of the products and services the client requires. For example, personal information may be used to:

  • provide clients with products and services in accordance with Asteri’s obligations;
  • administer and improve the products and services provided to Asteri’s clients;
  • offer the client further products and services (which may include using client’s information for marketing purposes, unless told otherwise); and
  • comply with legal and regulatory obligations under the Corporations Act 2001 and the Proceeds of Crime Act 2002, the AML/CTF Act, the Foreign Tax Compliance Act, the rules of relevant stock exchanges and ASIC or any other relevant legislation or regulation.

We also use personal information when recruiting staff or contractors.

3.4.2 Disclosure of Personal Information

When a client provides Asteri with their personal information, they are acknowledging and agreeing that their personal information may be disclosed to any of the following third parties to provide investor and financial services:

  • any person for the purposes described in any of Asteri agreements with the client;
  • the issuer or seller of a financial product or its registry provider (or to both), if the client has instructed Asteri to acquire the financial product and its terms require Asteri to provide the client’s personal information;
  • any regulatory, governmental organisation or industry or legal body which governs the conduct of any part of the Asteri business in any jurisdiction or as required by law or regulation. Whilst not exhaustive, Asteri may need to disclose personal information to regulatory bodies such as ASIC and relevant stock exchanges;
  • any other third party provided that Asteri obtains the client’s prior written consent; and
  • as otherwise permitted or required by law.

3.4.2.1 Disclosure of Personal Information to Related Bodies and Other Countries

When an individual provides their personal information to Asteri, they are acknowledging and agreeing that this personal information may be transferred between related bodies corporate or to third parties who supply products and services to Asteri. Asteri will only disclose the personal information for the primary purpose for which it was collected.

These related body corporates and third parties to whom Personal Information may be transferred, may be located throughout the world and may be registered and governed by laws outside the Australian jurisdictions. As such, the laws regulating a related body corporate may differ to Australian laws and may apply a greater or lesser standard of protection for personal information.

Should an individual’s personal information be transferred to a jurisdiction with inadequate privacy protection (i.e. such protection does not provide a level of protection equivalent to that provided by Australian privacy regulation), Asteri will take reasonable steps to ensure that the relevant overseas recipient does not breach the Privacy Act or APPs in relation to such personal information. Alternatively, Asteri may seek the individual’s consent to the transfer.

3.4.2.1 Use of Artificial Intelligence

Asteri may utilise Artificial Intelligence (AI) in providing its services.

AI tools used by Asteri are required to be approved by Responsible Managers and Chief Technology Officer before they are permitted for use within Asteri. If personal data is required to be used within Asteri AI tools, it will be used within the protective guidelines of the Electronic Communications Policy. Asteri does not input sensitive information into publicly available generative AI tools.

3.5 Storage of Personal Information

Personal information is held in a secure environment either in writing, electronically or both. Security measures are in place at Asteri that are intended to protect personal information held from misuse, interference and loss, and from unauthorised access, modification or disclosure.

An individual is entitled to request details on the exact nature of where and how their personal information is held by contacting Asteri.

Personal information will only be available to Asteri employees on a need-to-know basis to perform their duties.

3.6 Deletion of Personal Information

An individual can request the destruction or de-identification of their personal information within a reasonable time.

Asteri must destroy or de-identify personal information that is no longer required for a specified purpose.

3.7 Access to Personal Information and Complaints

Should an individual wish to know what personal information Asteri holds, they may request to view this personal information by contacting Asteri’s Privacy Officer:

Asteri Privacy Officer
Address: 29/60 Margaret Street, Sydney NSW 2000
Email: [email protected]

3.8 Asteri Websites

Asteri’s website utilises "cookies". A cookie is an electronic mechanism which can trace access and use of Personal Information contained within websites. By using any Asteri website, the individual is consenting to the use of cookies. Any personal information obtained through the use of cookies may be used to enhance the products and services that we provide.

3.9 Sensitive Information

Asteri may be required to collect sensitive information about clients in order to provide advice, products or services. Asteri will only collect sensitive information with client consent or as otherwise permitted by law.

3.10 Government Related Identifiers

Asteri may be required to collect government related identifiers of a client in order to provide a product or service. In particular, Asteri may collect government related identifiers to verify a client’s identity in accordance with the AML/CTF Act.

4. NOTIFIABLE DATA BREACHES

As a regulated entity, Asteri is required to comply with the Notifiable Data Breaches scheme under the Privacy Act. The scheme requires Asteri to notify affected individuals and OAIC when a data breach involving personal information is likely to result in serious harm.

For more information about notifiable data breaches please visit oaic.gov.au or via telephone on 1300 363 992.