Privacy Policy

Celeste Funds Management Limited treats the privacy of your personal information with the utmost importance.  We are bound by the Privacy Act 1988 (Cth), the Australian Privacy Principles which came into force on 12 March 2014. the Privacy Amendment (Notifiable Data Breaches) Act 2017 and the Privacy and Other Legislation Amendment Bill 2024.  The Responsible Entity (RE) of the Celeste Australian Small Companies Fund is The Trust Company (RE Services) Limited who collects, and is required to collect under Anti Money Laundering and Counter Terrorism legislation, personal information when you invest in our products and services.  At times, we may be privy to some of the information collected by the RE.  Due to the nature of our products and services we are unable to deal with you anonymously or by pseudonym.

What personal information do we collect

The RE uses MUFG Corporate Markets (MUFG) to perform unit registry services for the Celeste Australian Small Companies Fund.  MUFG collects, holds and uses unit holder’s personal information.  This includes name, address, bank account details, tax file number, contact details, application and redemption history, and is collected directly from the unitholder.  A copy of MUFG’s privacy policy can be accessed through their website at www.mpms.mufg.com.

Your name and email address may also be used by us for secondary purposes such as for the provision of monthly fund reports.  You can notify us at any time if you do not wish to receive such material or information.

Why do we collect and hold personal information and how do we use it

Personal information for each unitholder is held and used to deliver our products and services to you.  We do not use any automated decision-making technology in the collection or use of your personal information.

In the course of doing business, a unitholder’s information may be disclosed to third parties including the custodian, auditors, lawyers and other contractors and, where expressly authorised by law or by court order, to government agencies such as the Australian Taxation Office (ATO), the Australian Securities and Investments Commission (ASIC) and the Australian Transaction Reports and Analysis Centre (AUSTRAC).  The Fund also needs to comply with the requirements of the Foreign Accounts Tax Compliance Act (FATCA), a piece of United States of America legislation and the requirements of Common Reporting Standards (CRS).  If you are an overseas citizen or resident, this may require the Fund to provide your personal information to the ATO.

At times, we will also contract external experts to assist in enhancing our products, services and systems.  These third parties are bound by confidentiality arrangements when handling your personal information.

If you used a financial adviser who recommended your investment in our products and services (as indicated on your application form), then details of your investments will also be provided to that financial adviser.

We will not sell, rent, trade or otherwise disclose to third parties any personal information about you without your consent, or unless we are required to do so by law or under a court or tribunal order, or a permitted general situation exists within the meaning of the Privacy Act 1988 (Cth), or we reasonably believe disclosure is necessary for an enforcement related activity.  We do not use your personal information for marketing purposes, nor do we make it available for others to use for marketing.

All collection, use and disclosure of unitholder information is lawfully authorised, required or permitted.  Otherwise, unitholder information is kept confidential and only disclosed to the unitholder or an authorised representative.  Unitholders have certain rights including access to and correction of information, and the right to complain about any breaches of the Privacy Act.

Accuracy of personal information

We take every reasonable step to ensure that the personal information we collect, use or disclose is accurate, complete, relevant and up to date.  If you wish to view the personal information we hold about you please contact the Company Secretary in writing with your request at the following address:

Company Secretary
Celeste Funds Management Limited
Level 9, 50 Pitt Street
SYDNEY NSW 2000

or by email at contact@celestefunds.com.au.  In some very limited circumstances we may not be able to meet your request.

Please contact us immediately on 02 9216 1800 or email us on contact@celestefunds.com.au if your details change or you become aware that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading.   We may ask for certain proofs in regard to your information in some circumstances before we update the information.  If we decide that amending the information we hold is not appropriate we will advise you accordingly.  If you believe our decision is wrong you can complain about that decision using the process described below.

If you have a complaint about a privacy issue

If you have a query or complaint about a privacy matter relating to the personal information we hold or how we have used it please contact the Company Secretary in writing or email at the above address. We will acknowledge your concern promptly, investigate the concern, and reply to you advising of any decision and informing you of any remedies available.  We will endeavour to do this within 30 days but this may not be feasible depending on the nature of your complaint.

Security of personal information

We take all reasonable precautions to ensure the security of your personal information.  This includes physical and technological procedures to protect this information.

Access is restricted to only those employees, directors and third party contractors who require your personal information to perform their services.

We will tell you if we incur a data breach involving your personal information that will cause you serious harm.  This may be in an email, text message or phone call and will advise what personal information was involved in the breach as well as recommendations about the steps you should take in response to the breach.

Where your personal information we collect is no longer required, we ensure that records are permanently destroyed.

Internet services

We receive information when you visit our website such as the date and time of your visit, server address and domain name.  This information is used for statistical purposes only.  No personal information is collected, held or disclosed on our website.

When you leave our website via a link, you will be going to websites that are beyond our control.  These other websites may collect personal information or other information of users.  This Privacy Policy does not apply to any external links or other websites.  We encourage you to read the privacy policies of any website you link to from our site, especially if you share any personal information.