Your privacy is important to Spectre

• life and general insurance products protecting against risks
• investment products to build wealth
• superannuation and retirement income products to provide for retirement
• banking and other services to provide deposit and credit facilities
• financial planning advice and other services to help individuals understand their financial needs and make financial and investment decisions
• management of investment assets such as shares, property (including shopping centres), fixed interest and cash

SpectreLimited also maintains records of its shareholders and keeps them informed of Spectre's business activities (including Spectre's range of products and services that are available from time to time). Collecting personal information also allows us to meet legal obligations we might have.

What kind of personal information do we ask for?
Because of the nature of the products and services provided, government regulations and taxation laws, we ask for a range of personal information from our customers and shareholders.

The type of personal information we may collect can include (but is not limited to) name, address, date of birth, contact details, income, assets and liabilities, account balances, tax and financial statements and employment details.

We obtain most of the information directly from our customers through application or other forms, and from maintaining records of information provided in the course of ongoing financial planning advice or customer service. We may also obtain information from other sources.

We may ask for other information voluntarily from time to time (for example, through market research, surveys or special offers) to enable us to improve our service or consider the wider needs of our customers or potential customers.

Some of our insurance plans and other contracts also require us to collect sensitive information. For more details, see the section 'Sensitive information is subject to greater restrictions'.

If you choose not to provide the information we need to fulfil your request for a specific product or service, we may not be able to provide you with the requested product or service.

How do we use this information and who may we disclose it to?
While we may send you marketing material from time to time that we think will be useful to you, we are conscious of the need to respect your privacy.

Unless you are informed otherwise, the personal information we hold is used for establishing and managing your financial products or services, reviewing your ongoing needs, enhancing customer service and product options and giving you ongoing information or opportunities that we believe may be relevant to your financial needs and other circumstances.

We use the personal information we collect about Spectre Limited's shareholders to fulfil our legal obligations and to keep our shareholders informed of Spectre's progress and the products and services that we provide to our customers.

Depending on the product or service concerned and particular restrictions on sensitive information, this means that personal information may be disclosed to:

• other areas within the Spectre group who provide financial and other services
• financial planners, brokers and those who are authorised by Spectre to review customers' needs and circumstances from time to time
• service providers and specialist advisers to Spectre who have been contracted to provide Spectre with administrative, financial, insurance, research or other services
• other insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law
• credit reporting or reference agencies or insurance investigators
• anyone authorised by an individual, as specified by that individual or the contract

Generally, we require that organisations outside the Spectre group of companies who handle or obtain personal information as service providers to Spectre acknowledge the confidentiality of this information, undertake to respect any individual's right to privacy and comply with the current UK privacy legislation and this policy.

Sensitive information is subject to greater restrictions
Some personal information we hold is 'sensitive'.

Sensitive information relates to a person's racial or ethnic origin, membership of political bodies, religions or trade unions, sexual preferences or activities, criminal record, state of health and medical history.

The way we use tax file numbers and information received from a credit reporting agency about an individual is also restricted by law.

Sensitive information is usually needed for applications for death, sickness and disability insurance and to manage claims on those products. It may also be relevant to credit and other applications. It is Spectre policy that sensitive information will be used and disclosed only for the purposes for which it was provided, unless the customer agrees otherwise or the use or disclosure of this information is allowed by law. Documents asking for sensitive information will explain this.

Management of personal information
Spectre trains its employees and financial planners who handle personal information to respect the confidentiality of customer information and the privacy of individuals. Spectre regards breaches of your privacy very seriously and will impose appropriate penalties, including dismissal.

Spectre has appointed Privacy Officers to ensure that Spectre's management of personal information is in accordance with this statement and the Privacy Act.

How do we store personal information?
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.

How do we keep personal information accurate and up-to-date?
Spectre endeavours to ensure that the personal information it holds is accurate and up-to-date. We realise that this information changes frequently with changes of address and other personal circumstances. We can generally update your customer information over the telephone or via the AMP website.

You have the right to check what personal information about you is held by us
Under the UK Privacy Act, you have the right to obtain a copy of any personal information which Spectre holds about you and to advise Spectre of any perceived inaccuracy. The Act does set out some exceptions to this.

To make a request, you will need to complete an application form verifying your identity and specifying what information you require.

We will acknowledge your request within 14 days and respond promptly to it. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.

What if you have a complaint?
If you consider that any action of Spectre breaches this Privacy Policy Statement or the current UK privacy legislation or otherwise doesn't respect your privacy, you can make a complaint. This will be acted upon promptly. To make a complaint, please telephone us on +44 20 7888 4201. If you are not satisfied with our response to your complaint, you can telephone the Australian Privacy Commissioner's hotline on 1800 102 311.


Privacy: Web supplement
This statement outlines some privacy issues specific to the www.ampcapital-propertyassist.com website.

Google Analytics
Google Analytics website measurement software is used to assist in tracking traffic patterns to and from MPA Square Investors' websites, anonymously surveying users of the sites. The Google Analytics system is used to collect such information as the number of unique visitors, how long these visitors spend on the website when they do visit, and common entry and exit points into and from the website.

This non-personal information is collected and aggregated by Google and provided to us to assist in our analysis of our websites. You cannot be identified personally from this information and no personal information is stored about you. For further information about Google Analytics, please click here.

PeopleLogic
MPA Square Investors uses third-party email technology provided by PeopleLogic to assist in tracking reading and click-through patterns from e-newsletters that we periodically send to some of our clients via email. This technology is used to collect such information as which emails have been opened, and which web links within the email have been clicked. It also manages an opt-out capability to enable recipients to opt out of future newsletters and emails from AMP capital Investors. To learn more about our third party email technology partner, please click here.

Interactive tools
The MPA Square Investors website provides you with many interactive tools designed to help you make an informed choice with certain financial and other decisions.

MPA Square Investors may collect personal information you enter when using the interactive tools on our website.

What is a Cookie and How does Spectre use cookies?
Cookies are small pieces of text stored on your computer to help us determine the type of browser and settings you are using, where you have been on the website, when you return to the website, where you came from, and to ensure your information is secure. The purpose of this information is to provide you with a more relevant and effective experience on the Spectre website, including presenting web pages according to your needs or preferences.

We use cookies to give you access to certain pages of the website without having to log in each time you visit. Spectre may also use independent external service providers to track the traffic and usage on the website.

Cookies are frequently used on many websites on the Internet and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. You may not be able to access some parts of www.ampcapital.com.au if you choose to disable the cookie acceptance in your browser, particularly the secure parts of the website. We therefore recommend you enable cookie acceptance to benefit from all the services on the website.

Technology improvements
MPA Square Investors are constantly striving to improve functionality on this site through technology changes. This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy, will be notified in this Supplement at the time of the change.

Links to third party websites
The MPA Square Investors website has links to external third party websites that may benefit the user.

External websites such as these should contain their own privacy statements and we recommend you review them when using their websites.

Please note, however, that third party websites are not covered by Spectre's privacy policy and these sites are not subject to Spectre's privacy standards and procedures.

How to contact us:
If you want to:

• make a general enquiry about Spectre's privacy policy
• change your personal information
• obtain an application form for access to your personal information

Please select the relevant region or country from the contact us page.