NJR Partners is the trading name of N. J. Renton & Partners Capital Pty Limited (ABN 44 092 545 714, AFSL 337724), acting in its own capacity and as trustee of the NJR Partners Master Trust (ABN 50 445 597 741). This policy states what personal information we collect, why, how we handle it, and your rights. It applies to clients, investors, the people connected to them, and anyone who deals with us.
We handle personal information under the Australian Privacy Principles in the Privacy Act 1988 (Cth). The Principles bind us for the personal information we handle in meeting our anti-money laundering obligations; we apply them to all personal information we hold.
What we collect
Only what we need to act for you and to meet our legal obligations. For a client or investor, and for the people who own, control or act for one, this is: name, date of birth, residential address and contact details; identity documents or the result of an identity check; information about financial position, source of wealth and investment objectives; tax residency and, for investors in the Master Trust, tax file number; bank account details for payments; and the correspondence and records of our work for you.
We do not collect health information or other sensitive information.
Why we collect it, and how
To confirm who you are and that you are a wholesale client; to advise you and manage investments for you; to operate the Master Trust and keep its register; to make and receive payments; to meet our obligations under the Corporations Act, the Anti-Money Laundering and Counter-Terrorism Financing Act, the Taxation Administration Act and the Privacy Act; and to keep the records those laws require.
We collect information from you or from the person acting for you, and, where the law requires, from independent sources such as identity-verification and screening services and public registers.
Who we share it with
We share personal information only where we need to in order to act for you or to meet the law:
- the platforms, brokers, custodians and banks that hold your assets or make your payments;
- the managers and administrators of funds the Master Trust invests in;
- identity-verification and sanctions-screening services;
- our lawyers, auditors and tax advisers;
- regulators and government agencies where the law requires;
- the providers of the electronic systems described below.
Some recipients are located outside Australia. We take reasonable steps to ensure that an overseas recipient handles your information consistently with the Australian Privacy Principles. We will tell you, on request, which recipients hold your information and the countries in which they are located.
We do not sell personal information and we do not use it for direct marketing.
The electronic systems we use
We run the firm on electronic systems: email, calendar and document storage; secure file storage and transfer; electronic signature services; and analysis and drafting tools, including artificial-intelligence tools, that help us prepare documents, keep records and check our own compliance. Some record-keeping, filing and compliance checks are performed automatically by these systems and are reviewed by a person. Each system is approved by us before use, is recorded in our register of approved systems with its data-handling terms, and holds only the information the task requires.
Where an AI tool processes personal information, it does so under terms that do not permit the provider to use your information to train its models. A person at NJR Partners reviews and is responsible for every decision that affects you; we do not use automated systems to make decisions about you without human involvement.
We will tell you, on request, which systems hold your information.
Our website does not use analytics, advertising or tracking cookies.
Identifiers we hold but do not use
Some identifiers we are required to collect and keep — tax file numbers, driver licence numbers, passport numbers and similar — are not needed for our day-to-day work. We hold these in encrypted form, separately from working records, and access them only for the purpose for which the law requires us to hold them.
As trustee of the Master Trust we are entitled to ask for your tax file number. You are not required to give it to us; if you do not, tax may be withheld from distributions at the highest rate. We use tax file numbers only for tax reporting and withholding and never to identify you.
Recording of meetings
We may record a meeting to prepare our written notes. We record only with your agreement, asked for at the start of the meeting or before recording begins during it; where a meeting is arranged by us and we intend to record, the invitation says so. You are free to decline, and to ask us to stop at any time. Recordings are held on our own systems, are not shared outside the firm, and are deleted once our notes are written.
How we protect it
Personal information is held in access-controlled systems protected by multi-factor authentication and encryption, with access limited to the people whose role requires it. We keep personal information for as long as we need it to act for you and to meet our record-keeping obligations — generally seven years after our relationship ends — and then destroy or de-identify it.
Your rights
You may ask us what personal information we hold about you, ask us to correct it, or withdraw a consent you have given. We respond within 30 days.
If you have a concern about how we have handled your information, contact us at privacy@njrpartners.com. We acknowledge a complaint within one business day and reply in writing within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at www.oaic.gov.au.
If something goes wrong
If personal information is lost, or accessed or disclosed without authority, we assess it promptly and, where the law requires, tell you and the Information Commissioner.
Contact
Privacy Officer, NJR Partners, 6/72 Pitt Street, Sydney NSW 2000. Privacy matters: privacy@njrpartners.com. Complaints of any kind: complaints@njrpartners.com.
This policy took effect on 7 September 2026 and is reviewed at least annually.
N. J. Renton & Partners Capital Pty Limited (AFSL 337724, ABN 44 092 545 714), trading as NJR Partners. 6/72 Pitt Street, Sydney NSW 2000.