Privacy Policy

Privacy Statement

Paradice Investment Management, LLC (referred to below as Paradice, we, us, our) maintains a policy of strict confidence concerning any Personal Information that you provide to us. The meaning of Personal Information is discussed below.

As part of our commitment and to explain how we collect, store, use and disclose your Personal Information, we have developed our privacy statement (Privacy Statement).

What Personal Information do we collect and hold?

Personal Information is any information relating to an identified or identifiable natural person (someone who can be identified, directly or indirectly, or by reference to an identifier such as name, identification number (for example, passport, driver’s license, social security number, etc.), location or online identifier (such as GPS data, IP or MAC address, username and password), or other signifier related to that natural person.

Related to this Website we may collect and process the following personal data:

Contact Details: Email addresses and other information provided will be captured when you contact us.

Information from Other Sources: We may receive information about you if you use any of our vendor/partner websites, tools, or services offered through our website like our campaign vendors, literature print vendors, advertising networks, analytics providers, etc.

Technical Information: In addition to the online information that you voluntarily provide to us, we may use cookies and retain cookie information separately or with the information you provide to us. A cookie is a small piece of data assigned to the browser on your computer when you visit a website. We may use cookies for various purposes such as maintaining continuity during a session, gathering data about the use of our site, storing preferences, or recognizing return users. Your web browser may alert you or permit you to refuse, disable, or delete cookies. If you refuse cookies, you may not be able to use certain features or services on the site.

We collect Personal Information when you:

• Visit this website;
• Contact Paradice or our employees by telephone or email;
• Make an enquiry about our products or services; or
• Become one of our clients.

How is Personal Information collected and stored?

Depending on how you interact with Paradice, this website, or the products and services you might request from us we may collect Personal Information about you in different ways. We hold the Personal Information in both physical and electronic storage facilities including paper-based files and computer and cloud databases. In addition, if you access this website, this will mean that we will collect Personal Information electronically.

Electronic Recording

In connection with your use of this Website, we may use any form of electronic recording to record and store any communication, electronic or otherwise, between you and Paradice. You acknowledge the recording, retention and use by Paradice (and its employees, representatives and agents) of all information and data that you input during your use of the Website. We are required by US law to maintain our communications and other records involving our interaction with you as an investor or potential investor. Please also note that if you telephone Paradice, calls may be monitored or recorded to maintain and improve services.

IP Address

We may collect information about your computer (including where available your IP address, operating system and browser type) for system administration. This is used as statistical data about our visitors’ browsing actions and patterns.

Cookies

This Website utilizes a variety of technologies, including some provided by third parties, including but not limited to, cookies, web beacons, pixels/tags, and other storage technologies, (collectively, “cookies”), to collect, store, measure and aggregate data about usage and browsing patterns. These technologies help us secure, analyze and tailor the site for all users and better understand how this Website is used.

Cookies help us remember who you are and may collect and store your server address, top level domain name (e.g. .com, .gov, .net etc.), the date and time of your visit, country your service address is located in, the type of browser you used, the pages viewed and any downloads made, the previous site you visited and the site you visited next.

Cookies can make your subsequent visits to the Website simpler and more efficient. We may also use the information to assist in improving the Website, marketing and product development.
You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. However, by not accepting cookies, some pages on the Website may not display properly or you may not be permitted to access certain information. A server cannot find out a name or email address, or anything about you by using cookies.

We do not store or collect cookie information. Once we receive information from you, via email or any other means, the information is stored in a secure environment.

We take reasonable steps to protect the Personal Information we hold from loss, unauthorized access, interference, destruction, misuse, modification or disclosure using both physical and electronic security measures.

By providing us with your Personal Information over the internet you accept that such information will be transmitted at your own risk as the security of such information cannot be guaranteed.

How do we use the Personal Information we collect?

We use Personal Information only for the purposes for which we collect it. These purposes are:

• Providing you with the relevant products or services requested (including verifying your identity);
• Managing our relationship with you;
• Managing and administering your investments;
• Communicating with you about your investments;
• If you have requested it, sending you information about us and our products and services;
• The development of our products and services;
• Marketing and research, including communicating with you about products and services which we believe may be of interest to you;
• Statistical purposes;
• Improving the content of the website;
• General internal purposes;
• General product development; and
• Complying with laws, regulations, rules, directions or requests from regulatory or government agencies.

If it is no longer necessary for us to have your Personal Information, we will take reasonable steps to destroy it in a secure manner or remove identifying features from it. This is subject to any legal or regulatory obligation that we have to keep Personal Information for a specific period of time.

Will we disclose Personal Information?

This Privacy Statement is designed to maintain the confidentiality of all Personal Information we hold and prevent its misuse.

In some circumstances, however, your Personal Information may be disclosed outside Paradice. For example, we may be authorized or required to disclose your Personal Information:

• For legal reasons, disclosures may need to be made to law enforcement agencies, government agencies, courts, tribunals, regulatory bodies or external advisers;
• In the public interest where, for example, a crime, fraud or misdemeanor may be committed or suspected;
• Where disclosure is related to the supply of our products or services;
• To protect the rights, property or personal safety of a Paradice employee, affiliate, or another Paradice client;
• Where some or all of the assets and operations of the business are or may be transferred to another party by way of sale of some or all of Paradice’s business; or
• With your consent – such consent may be implied or express and may be in verbal or written form.

We may disclose Personal Information to third parties to whom we contract out specialized functions, such as mailing houses, printing companies and professional advisers. If we do so, we take steps to ensure that those contractors comply with applicable US rules and regulations and are authorized only to use Personal Information in order to perform the functions required by us.

Some of the third parties noted above may be located outside the United States (for example to comply with foreign trading requirements) in countries where laws in relation to the processing of Personal Information are not consistent with applicable US rules and regulations. While we take steps to try and ensure that these third parties do not breach applicable US rules and regulations in relation to your Personal Information, the overseas recipient may breach applicable US rules and regulations. By providing us with your Personal Information you accept that we may make disclosure to overseas recipients on this basis.

We do not under any circumstance sell your Personal Information for any reason.

How you can access, change or suppress your Personal Information?

If you would like to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, you may do so by reaching out to us via the contact information below.

What about links and references to Third Party Websites?

The Website may contain links and references to third party websites. We encourage you to read the privacy policies or statements on these third-party websites as they may differ from ours.

If you are an investor in a registered managed investment scheme that we manage (Fund), the responsible entity of the Fund, Equity Trustees Limited (Equity Trustees), will also collect Personal Information from you. The Product Disclosure Statement or Reference Guide for the relevant Fund will explain how you can access Equity Trustees’ privacy statement and contact them if you have privacy related concerns.

Can this Privacy Statement Change?

This Privacy Statement is subject to change from time to time, as we consider necessary.

This Privacy Statement was last updated in May 2020.

How do you contact us regarding this Privacy Statement?

If you have any questions, concerns, or would otherwise like to discuss this Privacy Statement or your Personal Information please contact us at:

Phone: +1 720 751.2100
Email: info@paradice.com