External Privacy Policy

External Privacy Policy


Reminiscent Capital Pty Limited (Reminiscent, We) understands and appreciates that you are concerned about the confidentiality and security of information that Reminiscent collects about you. Reminiscent recognises each individual’s right to privacy and is committed to the protection and confidentiality of your personal information.

Reminiscent is bound by the Privacy Act 1988 (Cth) and must protect your personal information in accordance with that Act and other applicable laws, such as the Spam Act 2007 (Cth).


We collect personal information so that we can provide you with our products and services and comply with our legal and regulatory obligations.

We will not collect any information that identifies you as an individual unless you knowingly provide it to us.  We primarily collect this information when you complete an application form or subscribe for information or notifications from us or our affiliates. In addition, when you browse our website, read or download information, our system will record the date and time of your visit and the pages viewed and information downloaded.

In most cases, we will collect your personal information directly from you. However, we can also collect your personal information from other sources, such as our affiliates or from third parties such as your authorised representatives and advisers.


Any information that identifies you is deemed to be personal information. The personal information we collect about you will depend on the circumstances of collection.

We collect information that is reasonably necessary to be able to provide you with our products or services. For instance, we can ask for identification information such as your name, date of birth, residential address, email address, telephone number, financial and investment information, bank account details, citizenship, social security number and/or tax file/identification number.

Sensitive information

The Privacy Act protects your sensitive information — such as information about your religion, ethnicity, health or biometrics. We will not collect your sensitive information.


Any information we collect from you, can be used by any entity carrying out functions on behalf of Reminiscent and its related entities for:

•        the purpose of enabling Reminiscent to provide services or information to you in accordance with your requests or reasonable expectations;

•        the purpose of enabling Reminiscent to undertake research, planning, product development, risk assessment, risk modelling and marketing; and

•        any other purpose required by or to the extent permitted by law.


We may use the information we gather to provide you with targeted communications about products and services we think will be of interest to you. We may also send you details of offers or services provided by Reminiscent’s related entities.

You may at any time choose not to receive these communications. Doing so will not cost you anything, and we commit to ensuring that you stop receiving any unwanted communications as soon as possible. If you do not want to receive such communications, please contact us.


We will only disclose personal information to third party entities carrying out functions on behalf of Reminiscent and its related entities on a confidential basis. You should note that information we collect from you can also be disclosed to third parties if that disclosure is required, or to the extent permitted, by law.


We may disclose your personal information to external service providers in the following offshore locations: Canada, Malaysia, Luxembourg, Hong Kong and the United Kingdom.

We take steps to ensure that our external service providers keep your personal information confidential and use it only for the purposes for which they are authorised.


Reminiscent regards the security of your personal information as a priority and takes all reasonable steps to protect your information from loss and unauthorised access, destruction, use, modification or disclosure.

Reminiscent stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our secure premises and systems as well as offsite using trusted third parties. We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure.

Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.

Reminiscent cannot ensure or warrant the security of any information you transmit to us or receive from our products or services and you do so at your own risk. Once we receive your information, we take reasonable steps to preserve the security of information on our own system. From time to time the website contains links to other websites. Reminiscent is not responsible for the privacy practices or the content of these websites.


A cookie is a small data file placed on your computer by Reminiscent’s server. A cookie contains information about your visit to the website. When you visit the website again, our server will look for the cookie and structure itself based on the information provided. A cookie identifies your computer to our web server when you visit the website. We do not use the cookie to store personal information about you. Reminiscent uses browser cookies to improve the speed and reliability of our security system. It is recommended that you turn off any cookie warnings in your browser before using this website, otherwise you may not be able to use the full functionality of this website.


You acknowledge and accept that your use of the website indicates your acceptance of the website’s terms and conditions of use and this Privacy Policy. This Privacy Policy may change from time to time. Any information collected after an amended Privacy Policy has been posted on the website will be subject to that amended Privacy Policy.


You are able to access and update the personal information that we hold about you at any time. To amend personal information that Reminiscent holds, please contact us.


At Reminiscent, we value our customers. We will always aim to be fair and responsive. If you have a privacy complaint, you have the right to expect that we will handle it in a friendly and professional way. When we receive a complaint, we receive this as valuable feedback that may help us improve our services and to ensure your needs are met in a satisfactory and appropriate manner.

If you wish to complain, at any time, about the handling, use or disclosure of your personal information, you can provide your written complaint by email, letter or by personal delivery to any one of our contact details noted below or verbally by telephone.

We will make all efforts possible to investigate your complaint, and advise you of the outcome as soon as possible. Your complaint can also be taken to the Office of the Australian Information Commissioner, who can be contacted at:

Office of the Australian Information Commissioner (OAIC)
Level 3
175 Pitt Street
Sydney NSW 2000
Visit oaic.gov.au

If the matter is not resolved to your satisfaction, you can then refer your complaint to the Australian Financial Complaints Authority (AFCA), who can be contacted at:

Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001
Phone 1800 931 678 (free call)
Visit afca.org.au


You can contact us about this Privacy Policy or about your personal information by:

By mail:        PO Box R1313, Royal Exchange NSW 1225

By email:       Risk.Compliance@pinnacleinvestment.com

By phone:     1300 360 306