• Global Privacy Policy

MetLife Investment Management Privacy Policy (Australia)

Last Updated: July 31, 2026

MetLife Investment Management, which includes MetLife Investment Management, LLC and PineBridge Investments LLC, is MetLife, Inc.'s (“MetLife”) institutional investment management business. MetLife Investment Management ("MIM" or “we”) and its Australian operations strongly believe in the responsible use of personal information we collect and are committed to protecting all information we retain. To further this commitment, we have adopted this MetLife Investment Management Privacy Policy (Australia) ("Privacy Policy") to tell you how MIM and its Australian operations (“we”, “our”, “us”) collect, use, share, and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs").

Besides this Privacy Policy, we may also have other privacy notices that apply to you as a MIM client or potential client. For more information about our privacy notices, please visit us at  at https://investments.metlife.com/privacy-policies/.

Anonymity and Pseudonymity

Where it is lawful and practicable, you have the option of not identifying yourself, or of using a pseudonym, when dealing with us. However, in most cases we will need to verify your identity in order to provide our services to you, including to comply with applicable know-your-customer ("KYC") and anti-money laundering ("AML") obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). If you do not provide us with the personal information we request, we may not be able to provide you with our products or services.

Information Covered by this Privacy Policy

This Privacy Policy applies to all personal information we process about you in connection with our Australian operations, including when you:

a) interact with our websites, product portals, and online applications (“Sites”);

b) download, register, or use our mobile software applications (“Apps”); and

c) interact with us in-person or through telephone, chat, physical mail, email, fax, and social media.

This Privacy Policy has been prepared in accordance with the Privacy Act 1988 (Cth) and the APPs, including APP 1 which requires us to manage personal information in an open and transparent way.

For example, we process personal information about you from the following sources:

  • Applications, subscription agreements, investment management agreements, or other forms;
  • Interaction with you on the telephone, in-person, or through email;
  • Transactions with us, our affiliates, or others, including service providers that are necessary for everyday business purposes, such as to maintain accounts and process transactions;
  • Third parties with whom we deal, such as consumer-reporting agencies, to verify information we receive from you and your creditworthiness; and
  • Through MIM websites, applications, or other online systems.

This Privacy Policy only applies to the services and interactions described herein that support MIM's Australian operations. It does not apply to services and interactions provided by other companies or organisations to which we link or with which you interact. MIM is, therefore, not responsible for the content or activities provided by other companies or organisations. This Privacy Policy does not apply to MIM job applicants, employees, or contractors, or information that does not identify or cannot be reasonably used to identify you.

Personal Information We Collect and Store

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. In practical terms, this means any information that identifies or reasonably can be used to identify you. We may collect from you and third parties your personal information, including but not limited to the following types of personal information:

  • Name, signature, addresses, email address, telephone numbers, dates of birth, tax file number, passport number, or other similar identifiers, employment information, and your preferences
  • Assets, income, account balances and transactions, financial information
  • Internet Protocol (IP) address, Browsing history, search history, interaction with web sites, applications, or advertisements

    • We may store or keep your personal information in Australia or with the our Metlife affiliates or service providers some of whom may be located in Australia or overseas, including but not limited to, in the United States (see also the section later in this policy relating to overseas disclosure). For a full list of countries where MetLife affiliates and service providers are located, please visit #[insert website].

Children

Our Sites are not directed at nor intended for children. We do not knowingly collect personal information from children under the age of 18 without the consent of a parent or guardian

Sensitive Information

Sensitive information is a subset of personal information that is afforded a higher level of protection under the Privacy Act 1988 (Cth). It includes information about your racial or ethnic origin, political opinions, religious beliefs, membership of professional or trade associations, sexual orientation, criminal record, health information, and biometric information. We will only collect sensitive information about you with your consent, or where we are otherwise required or authorised by law to do so (APP 3.3). Where we collect sensitive information, we will only use and disclose it for the purpose for which it was collected, a directly related secondary purpose, or as otherwise permitted by law.

Information We Collect Through Technology

We may collect and process your information through certain MIM and third-party technologies, including artificial intelligence (“AI”), machine learning (“ML”), and generative AI tools, to enhance our ability to deliver products and services to you and improve our customer support, processes, and technologies.

When you come to one of our Sites or Apps, we may collect your IP address. An IP address is often associated with the portal you used to enter the Internet, like your ISP (Internet Service Provider), company, association, or university. At times, we also use IP addresses to study the frequency with which our visitors visit various areas of our websites. We may combine this information with personal information. Finally, our websites do not respond to browser Do Not Track signals. 

Cookies, Web Beacons, and Other Tracking Technologies

Our Sites and Apps may use cookies, web beacons, and other tracking technologies to collect and store information. For detailed information about the types of cookies we use, how we use them, and how you can manage your cookie preferences, please refer to our Cookie Policy available at #[insert website].

Third-Party Advertising 

Advertisements managed by third parties may be placed on our websites. These third-party advertisers placing advertisements on our websites may also use cookies, web beacons, and other tracking technologies to collect information when you click on or move your cursor over one of their banner advertisements. You may not realise this information is being collected. In some cases, we may have access to information from web beacons, cookies, and other tracking technologies used by third-party advertisers on our sites, and this information may permit us to identify other sites that you have visited that are also associated with the third-party advertiser.  For more information about our ad service provider and its tracking technologies, including information about how to opt out of these technologies, please visit  https://www.google.com/intl/en/policies/privacy/ and https://www.aboutads.info/consumers. Once you have clicked on an advertisement and left our websites, this Privacy Policy no longer applies, and you must read the privacy policy or statement of the advertiser to see how your personal information will be handled on their website. 

How We Use Your Personal Information

We collect, use and process your personal information for the primary purpose for which it was collected, or for related secondary purposes where you would reasonably expect us to do so, in accordance with APP 6. We may also use your personal information where you have consented, or where we are otherwise required or authorised by law.

For example, we collect, use and process your personal information to:

  • Authenticate your identity;
  • Provide you with online planning tools;
  • Provide you with information, services, features and/or functionalities that may be available through our Sites and/or Apps, including but not limited to processing an application for our products and administering your account information;
  • Manage and administer your holdings in our funds and any related accounts on an ongoing basis in accordance with the contract between you and us;
  • Respond to your product or service information requests;
  • Investigate into and respond to your enquiries, feedback, complaints or claims;
  • Send you customer newsletters and updates;
  • Provide you with additional materials that may be of interest, including marketing materials;
  • For other everyday business and/or customer service purposes, such as product development and website administration;
  • Maintain, analyze and/or improve our and our affiliates’ business, products and/or services including managing and developing relationships with existing and prospective clients, investors, and their representatives, and conducting business development and marketing activities
  • Carry out statistical analysis and market research which are in our or our affiliates’ legitimate business interests; and
  • Comply with legal and regulatory obligations applicable to you, us and our affiliates from time to time, including applicable anti-money laundering and counter-terrorism financing, know-your-customer (KYC), customer due diligence, sanctions compliance and other regulatory requirements, including where we act as investment manager, sub-adviser or service provider.
  • Transfer, disclose and otherwise make available personal data to our affiliates, whether within or outside your jurisdiction (please also refer to the section “Cross Border Disclosure” below), for the purposes described in this MIM Privacy Statement.

We may also use and disclose any information not considered to be personal information, including aggregated and anonymized data, for any legal purposes, including analytics and assessments of business relationships and opportunities

How We Share Your Personal Information

Subject to legal, regulatory, or other governmental requirements, it is our policy not to disclose any of an individual’s personal information to third parties without their consent, unless those parties are providing services or support to us and have agreed to keep such personal information confidential, or disclosure is otherwise required or authorised by law. We may disclose your personal information to:

a) our related bodies corporate, including MetLife affiliates;

b) service providers who assist us in operating our business, such as fund administrators, custodians, auditors, attorneys, and accountants;

c) regulators and government authorities, including but not limited to the Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA), the Australian Taxation Office (ATO), and the Australian Transaction Reports and Analysis Centre (AUSTRAC); and

d) professional advisers, including legal, financial, and accounting advisers.

We may distribute certain personal financial information, such as the schedule of investors to the fund agreement and capital account information, to all investors in each specific fund, to any regulatory authority having jurisdiction over us or any of our funds, or in connection with any litigation or other dispute or otherwise as necessary or appropriate to enforce the terms of our agreements with you or investigate, defend, or assert legal rights.

Additionally, we may use an individual’s personal information for our own direct marketing purposes in accordance with APP 7. You may opt out of receiving direct marketing communications from us at any time by contacting us using the details set out below or by using the unsubscribe facility in our electronic communications. We will process your opt-out request as soon as practicable.

Purchase or Sale of Businesses

From time to time, we may purchase a business or sell one or more of our businesses, and your personal information may be transferred as a part of that purchase or sale. If we purchase a business, the personal information received with that business would be treated in accordance with the APPs and all our privacy policies, including this Privacy Policy, if it is practicable and permissible to do so. If we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your personal information in the same way required by the APPs and our privacy policies. The provisions of this paragraph will also apply if we are sold as part of bankruptcy proceedings.

Other Disclosures

We may disclose personal information as permitted or required by law, including where we reasonably believe it is necessary for the prevention, detection, or investigation of unlawful activity, where required for legal reporting, or to protect our legal rights or enforce our Terms of Use. We may also disclose information about you to our auditors, regulators, legal advisers, or in response to a lawful request, subpoena, or court order.

Third-Party Terms and Conditions for Site and App Users

If you are using one of our Sites or Apps, please note that your access to and use of the Site or App may be subject to certain third-party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, and third parties whose services you access through the Site or App. You recognize and agree that MetLife is not liable for any such third-party terms and conditions and their use of your personal information.  MetLife may, in its discretion, make available links through advertisements or otherwise enable you to access third-party products or services. Please note that while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by MetLife. MetLife is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that MIM is linked to those products or services does not constitute our sponsorship of or affiliation with those people or companies.

Your Privacy Choice and Your Rights 

We do not share personal information with unaffiliated third parties for their own direct marketing purposes. If you have signed up to receive newsletters or other e-mail messages from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message.

Under the Privacy Act 1988 (Cth) and the APPs, you have the following rights in relation to your personal information:

  • Access: You have the right to request access to the personal information we hold about you (APP 12). We will respond to your request within a reasonable period and provide access in the manner you request, where it is reasonable and practicable to do so. In certain circumstances, we may refuse access in accordance with the APPs, in which case we will provide you with written reasons for the refusal.
  • Correction: You have the right to request that we correct any personal information we hold about you that is inaccurate, out-of-date, incomplete, irrelevant, or misleading (APP 13). We will take reasonable steps to correct the information and, if we refuse to correct it, we will provide you with written reasons and include a statement with the information noting your request for correction.
  • Direct Marketing Opt-Out: You have the right to opt out of receiving direct marketing communications from us at any time (APP 7). If you have signed up to receive newsletters or other electronic messages from us, you can opt out at any time by clicking the unsubscribe link at the bottom of the message or by contacting us using the details below.
  • Complaints: You have the right to make a complaint about how we have handled your personal information. Please see the "Complaints" section below for further details.

Retention of Personal Information

MIM will retain personal information only for as long as is necessary for the purpose for which it was collected, for as long as an account or relationship with MIM is active, as needed to provide services to our clients, or to the extent necessary to comply with our legal and regulatory obligations under Australian law, including record-keeping requirements under the Corporations Act 2001 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and other applicable legislation. Where we hold personal information and no longer need it for any purpose for which it may be used or disclosed under the Australian Privacy Principles, and we are not required by or under an Australian law, or a court or tribunal order, to retain it, we will take reasonable steps to destroy or de-identify the information.

Security of Your Personal Information

The security and confidentiality of your personal information is extremely important to us. In accordance with APP 11, we take reasonable steps to protect your personal information from misuse, interference, loss, and from unauthorised access, modification, or disclosure. We have technical, administrative, and physical security measures and safeguards in place, including encryption on areas of our website that enable or require you to submit personal information online. We also review our security procedures periodically to consider appropriate new technology and updated methods. However, despite our reasonable efforts, no security measure is ever perfect or impenetrable. To further protect personal information, we restrict access to such information to only employees who need the information to provide products or services to you and have been trained on the proper handling of such information.

Updating Your Personal Information

We take reasonable steps to ensure that the personal information we collect, use, and disclose is accurate, up-to-date, complete, and relevant (APP 10). From time to time, and only when necessary, we may request confirmation of information that reasonably appears to be inaccurate or outdated.

Individuals, including current, former, and prospective clients and investors, may exercise their rights under the APPs to request access to personal information held by us (APP 12) and to request correction of any such information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading (APP 13).

Any requests to access or correct personal information should be made in writing and sent to our Privacy team at MIMprivacy@metlife.com. We will respond to all requests within a reasonable timeframe. If we are unable to provide access or make a correction, we will provide you with written reasons for the refusal.

You can also contact your Relationship Manager directly to update your personal information.

Withdrawal of Consent

Where we rely on your consent to collect, use, or disclose your personal information, you may withdraw that consent at any time by providing reasonable written notice to our Privacy team at MIMprivacy@metlife.com. Upon receipt of your request, we will inform you of the likely consequences of the withdrawal of consent and will cease to collect, use, or disclose the relevant personal information, unless otherwise permitted or required by applicable laws and regulations.

Cross-Border Disclosure

In order to use and disclose personal information as described in this Privacy Policy, your personal information may be disclosed to overseas recipients, including to the United States and other countries where MetLife affiliates and service providers operate. For a full list of jurisdictions in which MetLife affiliates and service providers are located, please visit #[insert website]. Before disclosing personal information to an overseas recipient, we will take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to that information (APP 8), or we will ensure that an exception under the Privacy Act 1988 (Cth) applies. You acknowledge that by providing your consent to such disclosure, we may not be required to take reasonable steps to ensure the overseas recipient handles your personal information in accordance with the APPs, and the overseas recipient may not be subject to any privacy obligations equivalent to the APPs. You may not be able to seek redress under the Privacy Act 1988 (Cth) against the overseas recipient.

If, at any time in the future, it is necessary to disclose any individual’s personal information in a way that is inconsistent with this Privacy Policy, we will give such individual written notice of the change and, where required under applicable law, obtain consent to such change.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When we do, we will post the revised Privacy Policy with a new “Last Updated” date. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise.

Complaints

If you believe that we have breached the APPs or otherwise mishandled your personal information, you may lodge a complaint with our Privacy team by contacting us at MIMprivacy@metlife.com. We will acknowledge receipt of your complaint and endeavour to respond within 30 days. If you are not satisfied with our response, or if you believe we have not adequately addressed your concern, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted at: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001, or online at www.oaic.gov.au.

Contact Us for More Information

For any privacy issues, questions, or complaints concerning the application of this Privacy Policy or to exercise your rights as described above, you may contact our Privacy team via email: MIMprivacy@metlife.com or by writing to: PO Box 3319, Sydney NSW 2001.