Collection of personal information

Middleton Associates collects the personal information that we believe is necessary to deliver our services or products, or otherwise for our business functions or activities. Most of this information we are required to obtain in order to satisfy Government requirements. For instance, we are required to confirm your identity for the purposes of the Anti-Money Laundering and Counter Terrorism Financing Act. In addition, since one of the services Middleton Associates provides is personal advice, Middleton Associates is required to collect important "know your client" information, which assists Middleton Associates in tailoring its services to you. Depending on your relationship with your Middleton Associates adviser, this may cover a large range of material.

Generally speaking, the types of personal information we collect include your name, date of birth, address, telephone number, email address, financial information, other contact or identification details and, in some cases, information necessary to make or receive payments to or from you or necessary to effect transactions in financial products on your behalf.

There may be occasions where we receive or need to source personal information about you from third parties such as:
• Credit reporting (for instance, when we obtain a credit report);
• Banks (for example, opinions about your creditworthiness);
• Publicly available sources of information (e.g. financial product registries);
• Your representative or agent; or
• Government agencies.

In certain limited situations, Middleton Associates may collect from you sensitive information. Sensitive information includes race, political or religious beliefs, sexual preferences, criminal convictions, membership of professional or trade associations or unions and health information. Middleton Associates generally only collects sensitive information if it is required by laws or rules. In the event that you provide Middleton Associates with any unsolicited personal information of a kind which we would not normally collect and would not be entitled to collect, Middleton Associates will destroy this information.

Personal information about third parties

If at any time you supply us with personal information about another person, you should ensure that you are authorised to do so and you must agree to inform that person who we are, that we will use and disclose that personal information and that they may gain access to it should we hold that information. You acknowledge that we may be required to, or wish to, contact the person whose personal information was provided in order to confirm its accuracy.

How do we collect personal information?

Personal information about you will usually be collected by your Adviser, during face to face interviews and meetings, during telephone discussions, during discussions relating to service arrangements or our requirements or by means of our client account opening procedures.

You acknowledge that we may also collect personal information from your agent where they have introduced you to us or have arranged for Middleton Associates to provide certain services to you, subject to the terms of this Policy.

Use and disclosure of personal information

Middleton Associates will generally only use your personal information in relation to the provision of financial products or services to you. If considered appropriate we may also use your personal information for internal communication purposes such as sending you research and notifying you of new products and services that may be suitable in meeting your financial objectives, unless you have notified us that you do not wish to receive such communications.

You authorise Middleton Associates to disclose necessary information to related companies, affiliates and any agents or contractors who provide services to us in connection with the provision of the products or services. Middleton Associates will only enter these types of arrangements or disclose such information where we reasonably believe that the relevant party will only use your personal information for the specific purpose for which we supply it to them.

Subject to what is permitted at law, the types of third parties we may disclose your personal information may include:
• Our agents, contractors, insurers, auditors and external advisers we engage from time to time to carry out, or advise on, our functions and activities;
• Any person or organisation that introduces you to us;
• Regulatory bodies, governmental agencies, law enforcement bodies and courts;
• Debt collection agencies and credit reference agencies;
• Underwriters, corporate advisers or issue managers where you are applying for financial products in an initial public offering or new issue;
• Other product providers and financial institutions;
• Insurers and reinsurers and their claims agents and assessors; and
• Any person to the extent necessary, in our view, in order to carry out the instructions you give to us.

Keeping information secure

Middleton Associates stores your information in a combination of computer storage facilities, paper based files and other records. Middleton Associates will take all reasonable steps to protect your information from loss, misuse, unauthorised access or unapproved disclosure. Access to and use of personal information within Middleton Associates is appropriately limited to prevent misuse or unlawful disclosure of the information.

If other organisations provide support services, to the extent reasonable practicable, we require them to appropriately safeguard the privacy of the information provided to them.

How you can access your information

You can contact us to request access to your information. In normal circumstances we will give you full access to your information. However, there may be some legal or administrative reasons to deny access. If access is denied, we will provide a reason why. The obligation to provide you access only extends to information supplied to us by you, and does not extend to Middleton Associates 's own records created by Middleton Associates in our dealings with you.

How you can correct your information

If you believe the personal information that Middleton Associates holds is inaccurate, incomplete or out of date and Middleton Associates agrees, the information will be amended. We will also take such steps (if any) as are reasonable in the circumstances to give notification of this correction to any third parties to whom it has be previously disclosed by Middleton Associates. If we disagree with you about the accuracy, completeness or currency of the information, then we will inform you in writing of our reasons for this refusal (except to the extent it would be unreasonable to do so) and inform you of any appropriate complaint avenues. You should keep Middleton Associates informed of any changes to your personal information by notifying your adviser in writing. We also ask that you promptly advise us of changes to the personal information you have supplied.

Visiting Middleton Associates and Partners online

If you visit the Middleton Associates Website to browse, read or download information, our system will log these movements. These website logs are not personally identifiable and Middleton Associates makes no attempt to link them with the individuals who browse the website.

If you visit the Middleton Associates Website to log into our secure areas, such as our Middleton Associates Online client website, any personal information you access will be subject to password protection and we recommend you do not divulge your password to anyone. You should ensure that you change your password regularly. You should not access your Middleton Associates online account from a shared PC. You should also avoid using a public domain email address (such as Gmail) when communicating with Middleton Associates and further ensure that no ‘mail rules’ have been set up on your account by hackers seeking to divert legitimate Middleton Associates correspondence. To further protect your personal information, your login time will automatically expire after a certain period.