1. Introduction
At Fox Invest Limited (“Fox Invest”, “the Company”) we are committed to safeguarding your privacy by ensuring personal information about you and other individuals is protected in a way that observes our own corporate values, as well as complying with the requirements of the National Privacy Principles of the Privacy Act 1988 (“Privacy Act”).

The Privacy Statement (“Statement”) sets out the minimum procedures for safeguarding your privacy.

2. Scope of statement
This statement applies to Fox Invest Limited and its associated companies. The objective of the Privacy Act is to set a standard for protecting the privacy of all individuals. The National Privacy Principles and the requirements of them are explained in detail below.

2.1 Privacy and the Company’s corporate relationships
The Company has appointed Freeman Fox Ltd ACN 010 763 041 and Fox Portfolio Management Limited ACN 093 708 457 to provide investment management services and back office managerial services. Link Market Services Limited (“the Registry”) administers the Share Registry. These associated companies are governed by the provisions of this Statement, the National Privacy Principles and the Privacy Act.

3. Definitions

3.1 Personal Information
Your personal information includes details such as name, address, date of birth, and contact details, e.g. phone and fax numbers, email addresses etc.

3.2 Sensitive Information
Sensitive information is a subset of personal information and by its "sensitive" nature may have the potential to be used to discriminate against someone. Examples of sensitive information include but are not limited to personal information or opinions on your health, criminal records, etc. Sensitive information can only be recorded if it is relevant to do so and with your consent.

4. Freeman Fox Privacy Principles

4.1 Collection and Use of Personal Information
The Company and the Registry collect, hold and use your personal information in order to assess your Application (under the Prospectus), service your needs as an investor, provide facilities and services that you request and carry out appropriate administration.

4.2 Your Rights and the Disclosure of Personal Information
You need not give personal information about yourself that may be requested by us. If you do not provide the information requested, we may not be able to provide facilities and services you request efficiently, or at all.

4.3 Disclosure of Information
The Company and the Registry may disclose your personal information for purposes related to your investment to their agents and services providers including those listed below or otherwise authorised by the Privacy Act:

• Freeman Fox as broker and dealer,
• Fox Portfolio as Administration Manager,
• The Registry for ongoing administration of the Register;
• The printers and the mailing house for the purposes of preparation and distribution of statements for handling mail.

The information may also be disclosed to members of the Freeman Fox Group and to their agents and service providers on the basis that they deal with such information in accordance with this Statement.

Although Fox Invest undertakes its best endeavours to ensure your personal information is safeguarded in a manner consistent with this Statement and only used to carry out functions on it's behalf we cannot accept liability for any misuse of your personal information by those organisations or individuals.

4.4 Data Quality
Fox Invest must ensure your personal information collected, used or disclosed is, at all times, accurate, complete and up to date. You should advise us immediately when you become aware that any information we hold about you is incorrect or out of date. Fox Invest undertakes to amend its records as soon as practical after it is advised subject to the validity of the request being confirmed.

4.5 Data Security
Fox Invest will take all reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access modification and disclosure. Your information may be stored in paper or electronic format.

Security measures implemented with respect to the Company’s IT systems will take account of internal and external recommendations, general industry practice and technological development in the provision of IT security services.

The Company’s IT security measures include state of the art firewall technology, encryption of usernames and passwords over the Internet and phone services and provision of unique user identification and password codes to your account(s).

When using our Internet services we may use “cookies” to ascertain product preferences and tailor future visits to the site to suit them. Most web browsers can be configured to not accept cookies, however the site functionality may be restricted as a result. Other than statistical information we do not collect information about you through our website other than where you provide it.

4.6 Openness to Fox Invest Practices
Information in this statement gives you some insight into how we manage your personal information and your rights. For further information on the information handling practices of Fox Invest contact the Customer Service Centre on 1800 003 369 and ask to speak with the Compliance Manager.

4.7 Access
You may request access to your personal information held by (or on behalf of) the Company or Registry. You can request access to your personal information by telephoning or writing to the Company through the Registry. A request to access your personal information must be directed to the Freeman Fox Compliance Manager.

4.8 Identifiers
Identifiers are unique numbers that a Commonwealth Government agency has assigned to you. These include tax file numbers.

Collection of tax file numbers (“TFN”) is authorised and its use and disclosure are strictly regulated by Tax and Privacy Laws. Quotation is not compulsory, however there may be tax implications for individuals who choose not to quote their TFN or claim an exemption. Fox Invest will use and disclose this information only for tax related purposes.

4.9 Anonymity
In complying with the National Privacy Principles Fox Invest will allow its customers to interact anonymously wherever it is lawful and practical to do so.

4.10 Trans Border (overseas) Data Flows
Should you request a transaction or service where your personal information may be transferred to another country, your information may be transferred to a country that does not have the same privacy laws as Australia. This may occur in instances where you request an international telegraphic transfer where your name and account details may be divulged.

4.11 Information required for Statutory Compliance Purposes
In addition to questions that Fox Invest may ask to ensure general statutory compliance there may be special circumstances where the Company or its agents are required to seek additional information about you

4.12 Further Information or Questions
It is the Compliance Manager responsibility to manage, investigate, coordinate, and respond to your inquiries, disputes lodged, information access and correction requests in accordance with the Company’s procedures and the National Privacy Principles.

The Compliance Manager will also provide you with contact details for the Privacy Commissioner if required where the company is unable to resolve a dispute to your satisfaction.

The Compliance Manager can be contacted between 8am and 6pm Monday to Friday (excluding national public holidays) by:

Telephone: 1800 003 369
Post: PO Box 7830 Brisbane Qld 4001
Email: wealth@freemanfox.com.au
Facsimile: 1800 679 796