In order for DFA Australia Limited (“Dimensional”, “we”, “us” or “our”) to provide our products and services to you, it is necessary for us (or our appointed agent/s) to collect and often store your personal information. In doing so, we are committed to managing your personal information in a manner that reasonably seeks to ensure its confidentiality, integrity, and ongoing security and complies with the requirements of the Australian Privacy Act 1988 (Cth) and the New Zealand Privacy Act 2020 (“Applicable Privacy Law”).

For the purposes of this Policy we describe “Personal Information” and “Sensitive Information” as:

In the course of providing products and services (primarily the provision of investment products), we may collect non-public Personal Information about you. We may collect this information from sources such as account opening documents and applications or other forms of communications with us. In addition to non-public Personal Information you provide directly to us, our service providers, or our agents, we may receive such information from third parties (such as your financial advisers etc.). We may also collect Personal Information to carry out certain business functions, such as assessing suitable candidates for career opportunities with us. The types of Personal Information we may typically collect is set out below.

Dimensional has converted a number of its Dimensional Wholesale Trusts (“Trusts”) over to a ‘dual access model’ (“Dual Access Funds”) which provides unitholders with the ability to acquire or dispose of units either on-market (‘listed class of units’) on a securities exchange (currently the ASX) in the form of an exchange traded fund (“ETF”), or apply for or withdraw units off-market (‘unlisted class of units’) directly with Dimensional.

1) Direct Investments in the Unlisted Class of Units of the Trusts: If you are directly investing into the unlisted class of units of the Trusts, you will typically be asked to provide Personal Information when completing an account application form or requesting a transaction. This may include your name; address; email address; tax file number; assets; Trust account balance; investment activity; information voluntarily provided by you on Dimensional’s website; date of birth; telephone number; bank account details; residency for tax reporting purposes; relevant authorised signatory lists, which include the relevant names and signatures and where relevant titles of those individuals authorised to act on your account; and identification information collected as part of the anti-money laundering and counter-terrorism financing regulations.

Dimensional has appointed Citi as its agent to perform unlisted registry services which includes the setting-up of all new investor accounts and the processing of associated unlisted class of unit transactions within the Trusts. As our agent, Citi will be responsible for collecting and storing your Personal Information if you directly invest into the Trusts. Citi may appoint third party service providers for data collection and processing. Please refer to Citi’s Privacy Policy for further information, their current contact details can be located in the Product Disclosure Statement for the relevant Trust.

The Investment Portal is an online portal that allows investors in a Trust to apply and make redemption requests for units in the Trust and change certain investor details (such as bank account and address).

Hard copy applications are where you complete an application form and submit it via fax, email or post to our registry provider. 

Please refer to the relevant Trust’s Product Disclosure Statement for more information on how to make investments.

2) ETFs - Investments in the Listed Class of Units of the Dual Access Funds: If you are investing into the listed class units (ETFs) of the Dual Access Funds, you will typically be asked to provide Personal Information when setting up an account with your broker or finalising setup with the CHESS Sponsored Sub-Registry operator. This may include your name, address, email address, telephone number, TFN status, holder unit balance, transaction history, ABN, bank account details and tax residency.

Dimensional has appointed Computershare as its agent to perform the Chess Sponsored Sub-Registry functions for the listed class of units of our Dual Access Funds, which includes the setting-up of all new investor accounts and the processing of associated CHESS transactions. As our agent, Computershare will be responsible for collecting and storing the Personal Information from your broker if you invest in the listed units of the Dual Access Funds. Computershare may appoint third party service providers for data collection and processing. Please refer to Computershare’s Privacy Policy for further information, their current contact details can be located in the Product Disclosure Statement.

3) New Zealand Portfolio Investment Entity (“PIE”): If you are investing directly into a PIE fund where Dimensional is the Investment Manager and FundRock NZ Limited is the Manager and Issuer of the PIE, you will typically be asked to provide Personal Information when completing an account application form or requesting a transaction. This may include your name; address; email address; IRD number; assets; PIE account balance; investment activity; date of birth; telephone number; bank account details; residency for tax reporting purposes; relevant authorised signatory lists, which include the relevant names and signatures and where relevant titles of those individuals authorised to act on your account; and identification information collected as part of the anti-money laundering and counter-terrorism financing regulations.

4) Find an Advisor: If you are using Dimensional’s web-based ‘Find an Advisor’ service, you may provide Personal Information when requesting the service (this is a service Dimensional provides to prospective investors who wish to engage a financial adviser for advice on investing in the Trusts, either directly or indirectly through a wrap service or master fund account). This may include your name; email address; location (country and postcode); and proposed investment amount.

5) Contact/Connect with Us Forms: If you are using Dimensional’s web-based ‘Contact Us’ or ‘Connect With Us’ forms, you may provide Personal Information when submitting these forms. This may include your name; firm name; work email address; work phone number and any information you include in your message.

6) Conferences, Events & Webcasts: If you are registering for a Dimensional conference, event or webcast through our website, you may provide Personal Information for registration purposes. This may include your name; address; email address; telephone number; company details and any dietary requirements. Where relevant, your name may be shared with your financial adviser to confirm conference, event or webcast attendance.

7) Meetings with Prospects/Clients: Personal Information may be taken during meetings with prospects and clients. This may include any Personal Information voluntarily provided by you, for example your name; email address and telephone number.

8) Recruitment: If you are applying for a role through our recruitment process, you may provide Personal Information. This may include your name; address; email address; telephone number; information contained on your resume; covering letter; academic transcripts and certificates; personal identification documents, such as a copy of your passport; birth certificate; drivers licence; salary information or information otherwise provided by you.

9) Rights to Work: During the recruitment process, we may provide your name; date of birth; passport details; and/or identity card number to the Australian Department of Immigration to confirm your work rights. The results of these checks will be provided directly to Dimensional.

There may be instances where you provide Sensitive Information to Dimensional, or consent to it being collected. For example:

• Conferences & Events: You may provide health or dietary requirements relating to your attendance at Dimensional events.
  
  

• Police/Background Checks: During the recruitment process your name; phone number; and email address may be provided to Dimensional’s external police/background checking providers so they can contact you regarding the commencement of the checks. The types of checks that Dimensional may conduct through external providers includes but is not limited to: employment; education; police; criminal; credit; bankruptcy; global sanctions and anti-money laundering checks; World-Check searches; and any other appropriate checks as required. The results of these checks will be provided directly to Dimensional.

We (or our agents) generally collect Personal Information only where you have consented to its collection, where it is collected for a lawful purpose connected with our functions and it is necessary for us to collect the information for that purpose, or where you would reasonably expect us to collect it in the normal course of providing our services or throughout the recruitment process. This includes both information you deliberately provide, as set out above, plus any session information captured through the use of cookies.¹

Typically, it is our practice to collect Personal Information directly from you or, subject to your authorisation, via your financial adviser if applicable. If it is necessary to store your Personal Information, Dimensional (or its agents) will store it in an appropriately secure physical or electronic facility, including paper-based files and/or computer databases.

Dimensional utilises “cloud” based services for several ancillary business services. Examples include Customer Relationship Management, Human Resource Management, Compliance Reporting, and Public Website Hosting. Dimensional has deployed an internal private “cloud” computing platform. Also, certain external service providers and applications used by Dimensional may utilise “cloud” capabilities.

We will take all reasonable steps to protect the Personal Information we hold relating to you from misuse, interference and loss, unauthorised modification or disclosure. Access to your Personal Information will be restricted to our employees and agents who need that information for the primary purpose of providing our products and services to you.

Dimensional will undertake reasonable steps to destroy or permanently de-identify your Personal Information if it is no longer needed for any of the purposes set out in this Policy.

If you invest directly into our Trusts, we will collect Personal Information for the primary purposes of setting up your account(s), processing your transactions, and managing your account(s) generally, including sending you related correspondence such as transaction confirmations and year-end tax statements. Personal Information will also be used to communicate with you and inform you about important changes or updates to our products and services.  We are unable to undertake these activities without this information. If you do not provide us with certain Personal Information on request, we may not be able to provide you with the products and services you have requested.

If you invest into the listed units (ETFs) of the Dual Access Funds the appointed Chess Sponsored Sub-Registry Operator will collect your Personal Information for the primary purpose of providing registry related services such as managing your account, processing distributions and sending you related correspondence such as transaction confirmations and year-end tax statements. If you do not provide certain Personal Information on request, the appointed Chess Sponsored Sub-Registry Operator may not be able to provide you with the products and services you have requested.

If you invest in the listed class of units of the Dual Access Funds, directly into a PIE fund or directly into the Unlisted Class of Units of the Trusts, a limited amount of Personal Information will be collected for the purposes of statistical and research purposes for the primary purpose of managing your relationship with Dimensional and management reporting. This may include name, address, HIN and associated adviser or ASX settlement participant.

Some Personal Information is collected for the purpose of compliance with relevant laws (laws, regulations, rules, directions or requests from regulatory or government agencies in both Australia and New Zealand), including the Financial Transaction Reports Act, the Anti-Money Laundering & Counter-Terrorism Financing Act (Australia), the Anti-Money Laundering and Counter Financing of Terrorism Act (New Zealand) and global information reporting regimes such as the United States Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standards (CRS). We may also be required to provide certain information in relation to your investments to regulatory authorities or use it in order to resolve disputes.

In addition, we may collect Personal Information to consider the suitability of prospective employees.

In order to provide our products and services to you, there may be occasions when we need to provide some of your Personal Information (including, in certain limited circumstances, your Sensitive Information) to our related entities, agents, or external service providers. In such circumstances, Dimensional will impose the necessary restrictions and standards within our contractual arrangements with such entities in order to reasonably seek to ensure that your Personal and/or Sensitive Information is kept secure, used only in accordance with our instructions and for the primary purpose it was entrusted to them.

As mentioned, Dimensional has appointed Citi as its agent to perform registry services for the Trusts (unlisted units) and Computershare as its agent to perform registry services for the Dual Access Funds (listed units). As our agents, Citi and Computershare will be primarily responsible for collecting and storing your Personal Information if you directly invest into the Trusts/Dual Access Funds.

Citi and Computershare may appoint third party service providers for data collection and processing. Please refer to Citi’s and Computershare’s Privacy Policies for further information.

There may be occasions where Dimensional or our agents need to provide Personal and/or Sensitive Information to our parent company, another affiliated company, or third party located outside of Australia or New Zealand (including, but not limited to, the United States, the United Kingdom, Tokyo, Singapore, Hong Kong and Malaysia). Where Personal and/or Sensitive Information is required to be sent outside of Australia, Dimensional and its agents will take such steps as are reasonable in the circumstances to seek to ensure that the overseas recipient does not breach Australian privacy laws or their local equivalent laws where applicable. Where Personal Information is required to be disclosed to a foreign entity outside of New Zealand, and that entity will use or disclose the information for their own purposes, Dimensional and its agents will take reasonable steps to ensure that those foreign entities are required to protect the information in a way that, overall, provides comparable safeguards to those in the New Zealand Privacy Act 2020.

Where relevant, your name may be shared with your financial adviser to confirm conference, event or webcast attendance.

Subject to the exceptions set out in the Applicable Privacy Law, you may contact us to request access to or correction of your Personal Information that we or our agents hold, or if you have any questions or concerns about your Personal Information held by us. We will endeavour to respond to your requests as soon as reasonably practicable and in any case no later than 20 working days after the date we received your request and, where applicable, provide you with access to your Personal Information in the manner requested. We ask that you promptly notify us if you become aware that any of your Personal Information we hold is inaccurate out of date or incomplete.

Dimensional will assess any suspected data breaches to determine whether it is likely to result in serious harm to any of the individuals to whom the information relates. In which case, Dimensional will notify the individual(s) at risk of serious harm and the Office of the Australian Information Commissioner and/or the New Zealand Privacy Commissioner (as applicable) as soon as practicable.

If you have concerns about whether we have complied with this Privacy Policy or Applicable Privacy Law, you can contact our Compliance Manager whose details are below. We are committed to handling any complaints quickly and fairly and will provide you with all reasonable assistance and information you may require to seek to resolve your complaint to your satisfaction.

Dimensional is a member of the Australian Financial Complaints Authority (“AFCA”), an external and independent dispute resolution service. In the unlikely event that you are not satisfied with our response to your complaint in respect of a Trust, you can contact AFCA directly on +61 1800 931 678.  

The Office of the Australian Information Commissioner (“OAIC”) can investigate privacy complaints from individuals. Complaints to the OAIC must be made in writing, typically using their online Privacy Complaint Form. You can contact OAIC directly on +61 1300 363 992. The New Zealand Privacy Commissioner can also investigate privacy complaints from individuals residing in New Zealand. Complaints can be made via their website at https://www.privacy.org.nz/about-us/contact/ or you can contact them directly on +64 0800 803 909.

Dimensional's Contact Details:
Telephone Number: +61 2 8336 7100
Fax: +61 2 8336 7197
[email protected]

The Compliance Manager
DFA Australia Limited
PO Box R1830
Royal Exchange NSW 1225, Australia

If you would like to know more about your rights to privacy, we recommend that you click on this link to the Office of the Australian Information Commissioner, or the New Zealand Privacy Commissioner’s website if you reside in New Zealand.