2. Our Commitment to Privacy
We recognise an individual’s right to privacy and understand that the protection and confidentiality of your personal information is important to you.
3. What is Personal Information
Personal information is any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether the information or opinion is recorded in a material form or not.
Sensitive information is a form of personal information and it includes information about your race or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. We will not generally collect sensitive information from you.
4. The Types of Personal Information We Collect
The types of personal information that we may collect about you can include your name, contact details (such as your address and telephone number), date of birth, identification, location, IP address, date and time of access, referral information, individual investment details, bank account information and tax file number.
Throughout the life of your investment product, we may collect and hold additional personal information about you. This may include transaction information or recording your queries and/or complaints. We may also collect personal information about individuals who are not clients of the Sentient Impact Group (e.g. business contact details of a company representative with whom we deal) but who represent or act as intermediaries on behalf of Sentient Impact Group clients.
The Corporations Act 2001 (Cth) requires and authorises us to collect personal information in certain circumstances, and this may include name, address and date of birth. Pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) we are also required to collect additional personal information from you to verify your identity, including, for example, your primary identification documents.
5. Personal Information Security
We regard the security of your personal information as a priority and we have a number of physical and electronic protection measures in place. Depending on the circumstances, this may include system access controls, building security, network firewalls and steps to ensure that our agents and third parties (e.g.: consultants and advisors) keep your personal information confidential and use it only for the purposes for which they, and the Sentient Impact Group are authorised.
6. How Do We Collect Your Personal Information?
We collect most personal information directly from you. For example, we will collect your personal information when you apply to invest in one of our managed investment schemes or when we communicate with you either in writing, by phone or in person.
Sometimes we collect personal information about you from other people or organisations, including for purposes related to verifying your identity or otherwise complying with our obligations under the AML/CTF Act. For example, we may collect personal information about you from:
- your representatives (including your legal or financial adviser, administrator, trustee, or attorney) who you have nominated on your application form as the appropriate contact persons in relation to your investment(s);
- financial intermediary organisations;
- other organisations, who jointly with us, provide products to you;
- trusted third party service providers that assist us to meet our statutory obligations
- publicly available sources;
- the parties to whom we disclose personal information as set out below;
- our mailing lists;
- when you visit our website; and
- make an enquiry about our services.
7. Online Privacy
When you visit our website, ‘cookies’ allow us to identify movements around our site. A cookie is a small amount of information sent to and stored in your web browser by a website.
Cookies used in our website include an anonymous unique identifier that allows our website to recognise you and give you access to your account when you’re signed in. The only personal information a cookie can contain is information you supply yourself.
8. For What Purposes Do we Collect, Hold, Use and Disclose Your Personal Information?
We collect, use, hold and disclose your personal information for the purpose of providing you with our products and services. Our purposes for handling personal information include to help us:
- Determine whether you are eligible for the product or service; Verifying your identity and information;
- Identify you and assess your application for investment in our managed investment schemes;
- Promote and market our services to you including advising you of updates or changes to our products and services;
- Communicate with you about available products or services;
- Maintain and update our records;
- Manage our relationship with you;
- Provide you with information about our products, services, and business development over time;
- Facilitate our internal business operations, including fulfilment of our legal and compliance obligations; and
- Facilitate any sale or potential sale of our business.
- We reserve the right to contact you directly pursuant to our statutory obligations under the AML/CTF Act.
- We may not be able to do the things described above without your personal information. For example, we may not be able to communicate with you or consider your application.
- We take all reasonable steps to ensure the information held is accurate, up-to-date, complete, relevant and not misleading.
- The Internet is not secure and personal information you send to us via the Internet is done so at your own risk.
- Where we no longer require your personal information for a permitted purpose and it is not required to be retained by law, we will take reasonable steps to destroy or permanently de-identify it.
9. Secondary Purpose
Sometimes we might use the personal information we collect for a secondary purpose that is, for use in a way that is different from the primary purpose. We will only do this where:
- You have consented (in some cases your consent will be implied);
- The secondary purpose is related to the primary purpose and you would reasonably expect us to use the information is such a way; or
We are required or permitted by law to use the information in such away, or it is in the interests of public safety to do so.
When you provide your email address you agree to receive direct marketing material from our related entities and us.
If you wish to opt out of receiving any direct marketing you may unsubscribe from these emails by clicking on the link within the email or by advising us by sending an email to firstname.lastname@example.org.
11. Disclosure of Your Personal Information
We may disclose personal information to:
- our staff and other companies within the Sentient Impact Group;
- our professional advisors including financial advisors, legal advisors, auditors and consultants;
- our agents, contractors and external service providers; authorised representatives who sell products on our behalf;
- responsible managers of our products and services for compliance purposes;
- other organisations, who jointly with us, provide products or services to you;
- your representatives (including your legal or financial adviser, accountant, trustee, or attorney);
- fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;
- regulatory and other government agencies as required by law; and a court, if required by a court order or other legally enforceable request such as injunction or subpoena.
We may also disclose your personal information to service providers, such as providers of IT, payment, delivery, data analysis, research, investigation and insurance services.
From time to time some of our service providers or contractors may be based in other countries such as in the United States.
12. Accessing Or Correcting Your Personal Information
You may request access to the personal information we hold about you at any time. You may also ask us to correct information about you that you may believe is inaccurate, incomplete or out of date.
We will need to verify your identity before giving you access to, or correcting your information.
In certain circumstances, we may not be able to correct or provide you with access to your information, where this is permitted or required by law. In these circumstances, we will explain and provide the reasons as to why access cannot be granted. If we are unable to correct it, you may request we associate the information with a statement that the information is incorrect, out of date, incomplete, irrelevant or misleading.
We take all reasonable precautions to ensure the personal information we collect, use and disclose is accurate, complete and current. We require that you advise us if there are any errors in your personal information and that you update us on any changes to your personal information such as changes of name, address or bank account details.
If we receive a request to update your personal information we will undertake an identification verification procedure.
Only once the relevant process outlined above has taken place, will we proceed to update our client records.
13. Data Breaches
We have internal processes in place to deal with any data breaches. Where there has been unauthorised access or disclosure of personal information and this access is likely to result in serious harm, we will, as soon as practicable, investigate the matter in an attempt to mitigate any harm caused.
We will take reasonable steps to notify you if your information has been affected in this way.
14. General Data Protection Regulation
The General Data Protection Regulation (GDPR) refers to a set of data protection requirements which aim to create clear and uniform data protection laws that apply to European Union residents. If the GDPR applies to us, we will comply with the data handling regime in respect of any personal data of data subjects (residents) in the European Union that we may obtain.
The meaning of personal data is similar to personal information, however, it is broader as it includes any information relating to an identified or identifiable natural person.
The types of information we may collect from European Union residents include:
- email address;
- phone number; and
- billing and shipping address.
We will take appropriate steps to ensure that personal data is:
- processed lawfully, fairly and in a transparent manner;
- collected for legitimate purposes;
- accurate and up to date;
- kept for no longer than is necessary for the purposes for which it was collected; and
- secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage.
European residents have the right to access personal data we hold about them and to request that personal data be corrected, updated, deleted or transferred to another organisation. European residents are also able to request that the processing of their personal data be restricted or object to their personal data being processed.
To make any of these requests, please contact us through the contact details set out below.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, please be aware that:
- such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other customers/clients subject to appropriate confidentiality protections; and
- even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular;
- to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and
- in exercising and defending our legal rights and meeting our legal and regulatory obligations.
15. Resolving Your Privacy Concerns & Complaints
If you have a query or a complaint regarding your personal information, please contact us (contact details provided below).
We will acknowledge your complaint within 30 days of receipt of your complaint. We will inform you if we need any further information from you to resolve your complaint. We aim to resolve complaints as quickly as possible.
If a complaint remains unresolved, you may apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. The Commissioner may be contacted on the privacy hotline: 1300 363 992.
16. Contact details
Address: Sentient Impact Group
Level 10/ 54 Wellington Street
Collingwood Vic 3066