DWS Group GmbH & Co. KGaA (“DWS Group”) and its related bodies corporate, including DWS Investments Australia Limited (ABN 52 074 599 401, AFSL 499640) ("DWS", "we" or "us").
At DWS we recognise that one of our fundamental responsibilities is to ensure that we protect the information entrusted to us by our clients, our website visitors and all those with whom we communicate. This is critical not only for the maintenance of DWS’s reputation but also to meet the extensive legal and regulatory requirements which are imposed upon us to safeguard our customers and maintain orderly markets. We also believe it is important that our information handling processes are clear and transparent.
When we handle personal information in Australia or of our Australian customers we are bound by the Australian Privacy Act 1988 (Cth) (the "Privacy Act"), Australian Privacy Principles and the Privacy Amendment (Notifiable Data Breaches) Act 2017. This Privacy Policy ("Policy") details how DWS handles personal information in accordance with those requirements. It sets out the sort of personal information we collect, how that information may be used, and under what circumstances it may be disclosed by DWS. This Policy does not apply to certain types of information which are not covered by the Privacy Act, including employee records in relation to our current or former employees.
We may update this Policy from time to time to reflect DWS’s current information handling practices. When we do so, the updated Policy will be available on this website.
What personal information do we collect?
Personal information is any information (including an opinion) which can be used to identify you. Sensitive information is a subset of personal information which includes (for example) information about an individual’s race or ethnicity, political or religious beliefs, sexual preferences, criminal record and health information.
We only collect personal information that is reasonably necessary for us to conduct our business, including to: enable us to deliver products, services, information or advice to you or to an organisation you work for; maintain a business relationship with you; enable us to assist you in using our products and services; improve, to conduct research and analysis, to provide information, special offers, and promotions to you regarding products and services offered by us, our affiliates, or non-affiliated third parties, and better understand your preferences in respect of our products and services; and, fulfil our legal and regulatory obligations from time to time.
DWS or its service providers may use cookies, web server logs, web beacons, or other electronic tools to collect and compile statistical and other information about your use of the website and the services provided on the website.
The types of personal information we collect includes names, contact details, personal details, business details, personal preferences, employment history, information about the products and services we provide to you and financial information. We generally do not need to collect sensitive information in order to provide our products and services to you, however it may be necessary for us to collect sensitive information from time to time.
As long as it is reasonable and practicable for us to do so, we will only collect personal information about you directly from you. In limited circumstances it may be necessary for us to collect information about you from a third party, for example where we need to verify information you have provided to us or to comply with our regulatory obligations. We only collect sensitive information directly from you with your consent, or where we are required, authorised or otherwise permitted to collect the information by law.
You may choose not to provide your personal information, including sensitive information, to DWS, or you may choose to deal with us on an anonymous basis (including by the use of a pseudonym) if it is practicable for you to do so. However, in most circumstances, it will be illegal and / or impracticable for us to do business with you unless you provide us with your personal information.
Electronic Communications
All emails, instant messages and other electronic communications sent to and from DWS (including via third-party applications and services) may be automatically captured and retained in secure digital storage facilities. These communications may be monitored, accessed, reviewed, audited and otherwise used for a variety of supervisory and compliance-related purposes, including to ensure compliance with applicable laws and regulations, DWS corporate governance and risk management policies, employee codes of conduct, and other business controls. These communications may also be disclosed to third parties (such as enforcement bodies or regulatory authorities) in appropriate circumstances.
Use and disclosure of personal information
The personal information we collect will generally be used or disclosed only for the purposes for which it is collected and for any other purpose which is related to that primary purpose and for which you might reasonably expect us to use it (including as described in this Policy).
Your personal information may be disclosed between related bodies corporate within the DWS group worldwide, and used by those entities for the same purposes for which we are entitled to use it.
We may also disclose and collect your personal information to and from third party service providers and business associates who provide services and financing in connection with our products and services. These third parties may be located locally or overseas.
DWS may also use or disclose your personal information (including to overseas recipients):
Disclosure outside Australia
As stated above, in some circumstances DWS may disclose your personal information to entities located outside Australia including our own related bodies corporate, third party service providers and business associates. There are certain safeguards which must be met before we are allowed to transfer your personal information outside Australia, which are set out in the Privacy Act.
DWS is a global company with operations in many countries across the world. The entities to which your personal information may be disclosed by DWS may be located in (without limitation) Germany, Hong Kong, India, the Philippines, Singapore, the United Kingdom, Luxembourg and the United States.
Storage and security
Personal information which we hold may be stored by DWS or by third party service providers on our behalf. We use up-to-date techniques and processes to ensure the personal information which we hold is secure and is protected from misuse, interference, loss or unauthorised access, modification or disclosure. Access is restricted to employees of the DWS group and those who perform services on our behalf, who are authorised to handle personal information.
Stored electronic communications will only be accessed by specific people in defined roles (e.g. supervisors/managers, compliance personnel, legal officers) where it is reasonably necessary for one of the purposes referred to above. Every step of this process is logged in an audit trail, and all copies of electronic communications will be destroyed at the end of the applicable retention period.
Where personal information we hold is no longer necessary for any purpose for which DWS may use or disclose it, we will delete the information or permanently de-identify it, unless we are legally required to keep it.
Accessing and correcting your personal information
DWS takes reasonable steps to ensure that the personal information it holds is accurate, up to date, complete, relevant and not misleading.
You can request access to the personal information that we hold about you at any time. DWS will respond to such a request within a reasonable time, and will try to give you full access to personal information in the manner you have requested, unless there is a legal or administrative reason we cannot do so. In some cases we may charge a reasonable fee for providing access.
You may also request that the personal information we hold about you be corrected to ensure it remains accurate, up to date, complete, relevant and not misleading. There is no charge payable in connection with a request for correction.
Please contact us if your personal information changes or if you believe that the personal information we hold is no longer accurate or complete.
Complaints
You can make a complaint if you believe that DWS has breached its obligations under the Privacy Act or has failed to comply with this Policy. Any complaint should be made in writing and sent to our Head of Compliance using the contact details below. DWS will review and respond to your complaint as soon as possible, and generally within 30 days of receiving it.
If you are not satisfied with outcome of your complaint, you may refer the matter to external dispute resolution or to the Office of the Australian Information Commissioner ("OAIC"). The OAIC will generally only consider your complaint if you have first written to us and given us a reasonable opportunity to resolve your complaint (usually 30 days).
Contact us
If you would like to:
you can contact us by phone, email or by post using the following contact details:
DWS Investments Australia Limited
GPO Box 7033
Sydney NSW 2001
Email: compliance.australia@db.com
Phone: (+61) 2 8258 1234
Attention: Head of Compliance
Use of this Website
DWS may also collect information about you through your use of the DWS Australia site ("Site"). For example, we may log the following details when you use the Site:
Generally the type of information collected through your use of the Site is not personal information unless, for example, you email us with a suggestion, comment or query about the Site.
Any information we collect through your use of this Site may be used to help us improve the Site by tailoring it to better suit your needs and to provide quicker and more effective access to the various components of the Site. If you email us with a suggestion, comment or query we will use the personal information provided to respond to you. We may also use or disclose information gathered via your use of the Site to other persons for these purposes or for related purposes, including to information technology companies, located locally or overseas, who assist us in constructing, designing and maintaining the Site.
Cookies
We may use “cookies” while you are visiting our Site. Cookies are small files which are stored on your hard drive. There are two different types of cookies. Session cookies are temporary and erased when you close your browser. Persistent cookies remain on your hard drive until you erase them or they expire. We may use persistent cookies to recognise previous visitors when they return but only the cookie on your computer is identified. Most web browsers can be set to prevent you from receiving new cookies, notify you before accepting cookies or disable cookies altogether. The instructions for this can often be found via your browser’s Help function. You can delete cookies already on your hard drive at any time. If you choose to disable cookies, this may result in a reduced availability of the services provided by our Site.
Policy last updated: January 2019