Morningstar, Inc., its Affiliates and Group Companies (individually and collectively, “Morningstar”) are committed to safeguarding your privacy.
In this Policy we set out how we use personal information, with whom we might share it, the means by which we keep it secure, and the choices you have about the information you choose to share with us.
Personal Information we collect and what we use it for
We collect limited personal information such as name, email and in some cases your IP address, phone number and physical address from you as an authorised user or contact for our products and services and in some cases where you are paying for a subscription service we will collect credit card or payment details.
What we use it for
We use the personal information to administer and support the contracts we have with you/authorised users of our products and services you are obtaining from us. We use this information for the purpose of providing updates about these products and services, dealing with support, billing and inquiries and providing information about other products and services that may be if interest to you.
If you are accessing a Site to learn more about Morningstar and our products and services inquire about employment with a Morningstar company, subscribe to web services or access our research, the information we collect may include your name, physical and email addresses, and phone number(s) via one or more online registration forms. If you are subscribing to a web service with a subscription fee we also collect credit card or other payment details.
What we use it for
On our websites, we use the personal information (and any preferences indicated by you, where appropriate) to make available to you the investment information, tools and other requested information, free product trial, communication with sales, content or research, or information pertaining to a job posting you have requested. In some cases, we use the personal information to provide you on our Site with targeted third-party advertisements which may be of interest to you based on any preferences you have indicated in your registration form(s).
Links to other websites
Morningstar may provide links to one or more other third-party websites from the Sites. We encourage you to read those website’s individual privacy policies before providing any of Your personal information to them.
We collect limited personal information such as name, email and in some cases your IP address, phone number and postal business address from you as authorised users or contacts for our products and services.
What we use it for
We use the personal information to administer and support the contracts we have with you. We also use this information to contact you for dealing with support, billing and inquiries about your products and services.
If you are accessing a Site to inquire about employment with a Morningstar company, the information may include, but is not limited to: your name, physical and email addresses, and phone number(s) and if you are submitting an employment application and related information through the Site, your user name/password and any additional employment-related information that you choose to provide.
What we use it for
We use this information to process and manage your application for employment with Morningstar.
Personal information uploaded by clients or subscribers to Morningstar online tools or hosted solutions
Some Morningstar tools or hosted solutions allow you to upload personal and other information about your employees, clients or other third parties into your instance of the tool or solution. In such cases you should therefore ensure you are compliant with the relevant local data protection regulations in respect of the personal information you input into the online tool. When you terminate your subscription or request that your personal data is deleted Morningstar will delete your instance of the tool including all of the information contained within it. Morningstar has no access to the personal data you upload into the tools and it is your obligation to ensure you have a backup of the data you have uploaded. Further information on your use of the tool and hosted solutions are set out in the Terms and Conditions and the relevant Product guide.
Personal information, how long do we keep it for?
Morningstar retains personal information only for as long as necessary for the uses we have set out above. Individual jurisdictions have different tax, accounting, regulatory and legal retention requirements and Morningstar is bound to keep certain personal information in accordance with these local requirements.
Personal Information: How we store and process it
All personal information we gather from you may be processed and stored in any one of our Group Company locations and may subsequently be transferred to other countries for further processing, storage, and/or use by Morningstar. Our staff who need to access personal information to perform their roles will have access to it and have agreed to comply with Morningstar’s policies on data protection.
Morningstar uses a small number of third parties to provide systems and software for its administrative functions, such as sales processing, accounting / finance management and procurement. In such cases Morningstar remains controller of the personal information, the third parties only process the data in accordance with our instructions and we are responsible for ensuring such third parties are compliant with all applicable data protection regulations in relation to their processing activities.
Protection of your personal information
We have technical, security and organisational measures in place, (and require our service providers do so as well), to protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction of personal information. The measures we use are appropriate to the nature, scope and purpose for which we use the personal information we collect. These measures include internal reviews of our data collection, storage, and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We have recently updated our processes to ensure we can comply with data subject requests as required under applicable law, to address complaints and comply with breach reporting procedures and incident management plans.
Morningstar operates secure data networks protected by industry-standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized individuals have access to the information provided.
Further information on our security and incident management is available from email@example.com.
How to update your personal information or make a data subject request
If you need to update your preferences or information or make a data subject request, you need only email us at firstname.lastname@example.org or follow the instructions contained in any email we have sent to you to unsubscribe or change your preferences.
Clients / Suppliers
If you need to update your information or make a data subject request, please email us either at the local contact details set out in the supplemental local policies on your local website or at email@example.com in the first instance and we will direct your enquiries to the appropriate team within Morningstar to action.
Questions related to your personal information submitted as an application for employment inquiries you’ve made or job applications you’ve submitted should be sent to: AskHR@morningstar.com.
What About children’s privacy?
Morningstar does not separately identify, or collect, any information that is specific to children.
Data Subject Requests
Certain local regulations grant individuals in those locations certain rights in respect of their personal information held by companies. If you wish to make a Data Subject Request, You should contact firstname.lastname@example.org in the first instance and your email will be directed to the correct Morningstar team to take action with respect to your request.
Your consent to collection and use of personal data
Your privacy is important
"Morningstar", “us” or “we” refer to Morningstar Australasia Pty Limited, Morningstar Investment Management Australia Limited (“Morningstar Investment Management”), and Morningstar Research Limited, subsidiaries of Morningstar, Inc.; and “you” refers to any person or client about whom we collect or hold Personal Information.
We recognise that maintaining the privacy of your Personal Information matters to you, and we are committed to protecting your Personal Information.
Australian Privacy Principles ("APPs") under the Privacy Act 1988 (Australia) and Information Privacy Principles ("IPPs") under the Privacy Act 1993 (New Zealand) regulate the way in which agencies and organisations may collect, store, use, or disclose an individual's Personal Information in the relevant country.
Under Australian Law
“Personal Information” means information or an opinion (whether or not true, and whether or not recorded in a material form) about an identified individual, or about an individual who is reasonably identifiable.
“Sensitive Information” is personal information that is:
(a) information or an opinion about an individual’s:
▪︎ racial or ethnic origin; or
▪︎ political opinions; or
▪︎ membership of a political association; or
▪︎ religious beliefs or affiliations; or
▪︎ philosophical beliefs; or
▪︎ membership of a professional or trade association; or
▪︎ membership of a trade union; or
▪︎ sexual orientation or practices; or
▪︎ criminal record
(b) health information about an individual
(c) genetic information about an individual that is not otherwise health information
Under New Zealand Law
“Personal Information” means information about an identifiable individual (whether or not recorded in a documentary form).
Personal Information we collect
The types of Personal Information we collect from you will depend on the product or service you receive from us. We provide investment information, investment management and consulting services, research, ratings, data, and tools to both individuals and businesses.
The Personal Information we may collect from you includes, but is not limited to:
▪︎ Your name, phone number, street address and/or email address
▪︎ Your credit card number or bank account details
▪︎ If you are acting on behalf of your employer, your job title, employer's name and contact information
▪︎ Demographic information, such age bracket, investor type, and how you heard about us
▪︎ Password (when you establish an online subscription)
▪︎ Information regarding your security holdings (for example, when you use certain tools)
▪︎ If you are a Morningstar Investment Management Investor or a Morningstar Next Investor, your TFN and depending on your legal structure, Personal Information about trustees/beneficial owners or other information required by anti-money laundering legislation.
▪︎ Personal website usage information, including cookies and other information about your computer, device, and browser.
Where our clients are corporations, we may collect Personal Information from that corporation about different contact persons within the corporation including name, job title, and contact information. We do not adopt Commonwealth Government identifiers, such as a tax file number, a Medicare number, or a New Zealand IRD number, as a means of identifying individuals.
Job Applicants and Contractors
When applying for a position or a contract with us, we also collect Personal Information necessary for us to perform functions related to recruitment, hiring, and contract management. The Personal Information we collect may include that information already listed above as well as education history, qualifications, previous employers, citizenship status, membership of professional organisations, and referee contact details.
Depending on your advancement in the recruitment process we may also collect Personal Information (which might include sensitive information) from you in job interviews or telephone conversations and from your referees or from our own suppliers, including to verify your citizenship status, visa details, qualifications, references, and other Personal Information that you give us. Where you are being engaged as a consultant or contractor to Morningstar, we may also collect additional Personal Information such as your Australian or New Zealand Business Number and professional and/or public liability insurance details.
Where the consultant or contractor is a corporation we may also collect additional Personal Information about its directors, managers, or contact persons which could include names, job titles, business and personal addresses, and phone numbers.
Personal Information: Why we collect it
We may collect, store, use, and process Personal Information where necessary to provide you with our products and services or the products we distribute, to supply other administrative services (e.g. administering your account, to fulfilling our obligations under anti-money laundering legislation), to perform functions related to our recruitment process, to respond to inquiries, and – unless you have let us know that you do not want us to do this – to provide information about other products and services that we, our related companies, or our advertisers/marketing partners offer from time to time (direct marketing), including via third party websites (remarketing).
Personal Information: How we collect it
We will collect Personal Information directly from you, unless it is unreasonable or impracticable to do so, or is otherwise permitted by law. The Personal Information we collect may be captured from a variety of sources including, but not limited to:
▪︎ direct contact with us or use of our website
▪︎ voluntary submissions (e.g. responses to surveys, requests for information on our products or those of our advertisers/marketing partners)
▪︎ registrations/applications to receive our products or services or the products we distribute
▪︎ public registers (e.g. where we need to check Personal Information independently of you for anti-money laundering purposes)
▪︎ if you apply for a position or contract with us, via our application website or from a recruiter that refers you to us
While some contacts with us such as general enquiries may be made anonymously or by using a pseudonym, if the relationship is to progress any further (by you becoming our client or having a business relationship with us) it will be necessary for us to know who you are to enable us to deliver our services to you. Similarly, we cannot deal with complaints made anonymously or by pseudonym.
Where a third party gives us information about you
Should a third party give us unsolicited Personal Information about you, we will within a reasonable period determine whether or not we could have collected the information directly from you or if it is in a public record and, if not, we will take reasonable steps to destroy or de-identify that information unless the law otherwise permits or requires.
Use of and access to your Personal Information by others
Generally, we will not make the Personal Information gathered using our products and services or during our recruitment process available to anyone outside Morningstar or its related companies - except as agreed or instructed by you or where required by or permitted by law. Where we distribute a third party’s product, we will provide any Personal Information you provide as part of the application process for the third-party product to that third party.
Morningstar's related companies include our parent company Morningstar, Inc. in the United States and related companies worldwide. These related companies are located in: Belgium, Brazil, Canada, Chile, China, Denmark, Finland, France, Germany, Hong Kong, India, Italy, Japan, Luxembourg, Mexico, The Netherlands, New Zealand, Norway, Singapore, South Africa, South Korea, Spain, Sweden, Switzerland, Taiwan, Thailand, and the United Kingdom.
It may be necessary for our third-party service providers to access your Personal Information in order to perform contractually specified services on our behalf. We will do everything reasonably within our power to prevent unauthorised use or disclosure of your Personal Information in such circumstances. Generally, Morningstar contractually requires that all Personal Information accessed by such providers be kept confidential and in accordance with the APPs or IPPs, where relevant.
A cookie is a small file which can be downloaded on a device when you access our website and is then sent back to our website each time you access our website. Cookies may collect and store your information. Cookies are useful because they allow us to recognise your device and your user preferences.
We also use analytical cookies, which allow us to recognise and count the number of users on our website and how users move around the site. This helps us make sure users can easily find what they need.
Tracking cookies are used to provide content that is relevant to your interests. Advertisers on our website may also deploy cookies and web beacon technology to measure and improve advertising for their clients.
We may use your Personal Information for marketing and promotional purposes including to provide you with information about other products and services that we, or other Morningstar related companies, or our advertisers/marketing partners, offer from time to time (direct marketing). We will not use Personal Information we have collected about you via our recruitment process for Direct Marketing.
You may ask us to let you know the source of your Personal Information used by us for direct marketing. So long as a response is not impracticable or unreasonable, then unless non-disclosure is permitted or required by law, we will endeavor to reply to you within a reasonable period without cost to you.
If you do not want your Personal Information used for direct marketing purposes by us or our related companies or our advertisers/marketing partners, please contact us on the details provided below.
Links to other websites
Our website may contain links to other websites for you to access. You should be aware that the privacy policies of the operators of those other sites may not be the same as ours and you should refer to their own privacy policies.
Protection of your Personal Information
We will take all reasonable steps to ensure that any Personal Information about you which we hold is:
▪︎ Secure: protected from misuse, interference and loss, and from unauthorised access, modification or disclosure; and
▪︎ Appropriate: accurate, complete, up-to-date, relevant, and not misleading having regard to the purpose for which it is held and may be used.
▪︎ Your Personal Information may be kept in various formats by us, our related companies, and relevant third party providers.
The Morningstar Group operates secure data networks protected by industry standard firewalls and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised individuals have access to the information provided. We restrict access to Personal Information to our employees, and contracted third party providers who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations. We may need to maintain records for a significant period of time but will destroy or de-identify Personal Information if we no longer need it for any authorised purpose and are not required by law to retain it.
Access to your Personal Information
We will handle all requests for access in accordance with the APPs and, where relevant, the IPPs. In most cases, we will confirm whether or not we hold Personal Information about you and give you access to any such Personal Information within a reasonable period of time and in the manner you request, provided that request is reasonable.
In some cases, we may refuse access where refusal is required or permitted by law. Without limitation, we may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, information that is only available on older back up tapes, or would involve developing a new system or significantly changing an existing practice), or which risk the privacy of others. We will provide you with reasons for any refusal.
We will respond to your request within a reasonable period of time and in accordance with legal requirements.
We may charge a reasonable fee for giving you access to your Personal Information, however at present we do not propose to make any such charge.
To request access to your Personal Information please contact our Privacy Officer – contact details are below.
Accuracy of your Personal Information
We appreciate any assistance you might give us to keep any Personal Information that we hold about you up-to-date, complete, and accurate. If you want to update your Personal Information, you may do so by accessing the personal account information on the relevant website or by contacting us:
Tel: 1800 03 44 55
Tel: +61 2 9276 4446
Fax: +61 2 9276 4545
Morningstar Investment Management Clients and Investors
Tel: +61 2 9276 4550
Morningstar Next Investors
Tel: 1800 316 544
Job Applicants and Contractors
Tel: +61 2 9276 4415
We will, on request, normally amend any of your Personal Information which is inaccurate, incomplete, out-of-date, irrelevant or misleading where:
▪︎ we are satisfied that the information needs to be corrected; and/or
▪︎ we agree with your request that the information be corrected.
If we disagree with your request, we will write to inform you of our concerns about making the change you have requested, giving reasons for our refusal and notifying you of available complaint mechanisms. If you wish, we will then, take reasonable steps to associate with the appropriate records of your Personal Information, in such a manner that it will always be read with your Personal Information, a statement that you claim the information is inaccurate, incomplete or out-of-date (whichever is relevant) and that you have requested a particular change. For New Zealand Personal Information this may include a statement that you have provided the correction sought.
We will respond to your request within a reasonable period of time and in accordance with legal requirements. We will inform you of any action taken as a result of your request.
Where permitted by law we may charge a reasonable fee for dealing with requests, but do not propose to do so at present.
If you have a complaint about how we handle your Personal Information, please contact our Privacy Officer as described below.
The Privacy Officer will acknowledge your complaint within three business days of receipt and will seek to resolve your complaint within 30 days of receipt.
Morningstar Privacy Officer Contact Details
International Tower 1
100 Barangaroo Avenue
Barangaroo, NSW 2000, Australia
Tel: +61 2 9276 4532
For Australian clients, if your complaint is not resolved to your satisfaction or we have not responded to you within 30 days you have the right to contact the Australian Information Commissioner.
Office of the Australian Information Commissioner
GPO Box 5218
GPO Box 5218
Phone: 1300 363 992
Facsimile: +61 2 9284 9666
For New Zealand clients, if your complaint is not resolved to your satisfaction you have the right to contact the New Zealand Privacy Commissioner.
The Office of the Privacy Commissioner
PO Box 10094
Phone: 0800 803 909
Facsimile: +64 4 474 7595
Copies of this policy and further information
As the Australian and New Zealand Governments introduce new privacy legislation, this Policy will be reviewed and updated accordingly. We will also regularly review this Policy and may change it from time to time. We encourage you to review this Policy on a regular basis so that you will be aware of any changes to it. The date at which this Policy was most recently updated is given above.
For Australian clients, further information on privacy legislation is available from the Office of the Australian Information Commissioner at www.oaic.gov.au
For New Zealand clients, further information on privacy legislation is available from the Office of the Privacy Commissioner at www.privacy.org.nz
Legal Contact Information
Morningstar Australasia Pty Limited
Level 36, Australia Square
264 George Street
Sydney, NSW 2000,
Locked Bag 25,
Sydney, NSW 1225
Tel: +61 2 9276 4532
Fax: +61 2 9276 4545
ABN: 95 090 665 544
Australian Financial Services License Number: 240892
We recognize that maintaining the privacy of your Personal Information matters to you, and we are committed to protecting your Personal Information.
Under the current laws of India, ‘Personal Information’ consists of information relating to your passwords; financial information, such as your bank account, credit card, debit card or other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; and biometric information.
PERSONAL INFORMATION WE COLLECT
The types of information, including Personal Information, that we collect from you will depend on the product or service you receive from us. We offer Portfolio Managed Services (“PMS”) and other products/services to individuals and non-individual entities. We may ask you for, or obtain with regard to you, the following categories of information:
▪︎ Your name, phone number, physical and e-mail address;
▪︎ Demographic information, such as your age, gender, occupation, income range, investment preferences, etc.;
▪︎ Your bank account details;
▪︎ Password (if/when an online subscription is established with you).
PERSONAL INFORMATION – WHY WE COLLECT IT
Morningstar may collect, store and process certain Personal Information pertaining to you, to provide you with our products and services, to supply other administrative services (e.g., setting up new accounts), to respond to inquiries, to provide information about other products and services that we or our related companies offer from time to time, etc. In addition, we may, from time to time, review your usage of our website in order to assess how we can improve our products and services.
PERSONAL INFORMATION – HOW WE COLLECT IT
We will collect Personal Information directly from you, unless it is unreasonable or impracticable to do so. The Personal Information we collect may be captured from a variety of sources including, but not limited to:
▪︎ Direct contact with us or use of our website;
▪︎ Registration/application to receive our PMS or any other product or service that we offer;
▪︎ From third parties, such as mutual fund distributors, registered investment advisers, and third-party service providers;
▪︎ Voluntary submissions (e.g. requests for information on our products);
▪︎ Reviews of website usage patterns.
USE OF AND ACCESS TO YOUR PERSONAL INFORMATION BY OTHERS
As a general rule, we will not make the Personal Information gathered using our products and services available to anyone outside of the Morningstar group of companies, except as instructed by you, or where required or permitted by law. Please note, however, that there are some exceptions to this policy. For example, if we use third-party service providers, these service providers may have access to your Personal Information to perform contractually specified services on our behalf. Secondly, if you indicate that you are interested in receiving information about a particular third-party's products/services, or you opt to receive certain products or services through us, we may provide your Personal Information to that third party for purposes of fulfilling your request(s). With respect to service providers, Morningstar contractually requires that all Personal Information be kept confidential. Additionally, Morningstar takes reasonable steps to ensure that third parties receiving information about you at your request maintain the confidentiality of that information.
We collect, store, and process your Personal Information, so we can administer and support the products and services we make available to you. We may also use your Personal Information to send you information about other products and services offered by Morningstar and our related companies. Your Personal Information may, if required for reasons such as backup, be also stored outside India, subject to applicable laws in this regard.
A cookie is a small file which can be downloaded on a device when you access our website and is then sent back to our website each time you access it again. Cookies may collect and store your information.
We also use analytical cookies, which allow us to recognize and count the number of users on our website and how users move around the site. This helps us make sure users can easily find what they need.
PROTECTION OF YOUR PERSONAL INFORMATION
We take all reasonable steps to ensure that any Personal Information about you which we hold is:
▪︎ Secure: protected from misuse, interference and loss, and from unauthorized access, modification or disclosure; and
▪︎ Appropriate: accurate, complete, up-to-date, relevant, and not misleading having regard to the purpose for which it is held and may be used.
Your Personal Information may be kept in various formats by us, our related companies, and/or relevant thirdparty providers.
The Morningstar group operates secure data networks protected by industry standard firewalls and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided. We restrict access to Personal Information to our employees, and contracted third party providers, who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated, if they fail to meet these obligations. We may need to maintain records for a significant period of time but will destroy or de-identify Personal Information if we no longer need it for any authorized purpose and are not required by law to retain it.
ACCURACY OF YOUR PERSONAL INFORMATION
You are responsible for checking to ensure that any Personal Information is updated and correct.
HOW TO UPDATE OR REVIEW PERSONAL INFORMATION
If you want to update any Personal Information, you may do so by contacting your distributor/adviser, or by emailing to email@example.com.
If you have any questions or concerns about the privacy practices of Morningstar, please send an email to firstname.lastname@example.org, and your questions will be directed to the appropriate team to deal with your enquiry.