In the course of providing our products and services Beames Capital Management Pty Ltd, may collect personal information from clients, or potential clients.
What types of personal information do we collect?
In the course of providing products and services, we may collect and hold information that is reasonably necessary for the performance of our functions and activities, including maintaining a unitholders’ registry of investor details. This information may include Personal Information such as:
We may collect Sensitive Information about you, with your consent. Sensitive Information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. Provided you consent, your sensitive information may only be used and disclosed for purposes you have consented to or which are directly related to the primary purpose for which the sensitive information was collected, including:
How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.
Where possible we have attempted to standardise the collection of personal information by using specifically designed forms (e.g. our Application Forms). However, given the nature of our operations we often also receive personal information by email, online forms, letters, notes, over the telephone, in face-to-face meetings and through financial transactions. We may also collect personal information from other people (e.g. a third-party administrator) or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly.
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our uses of personal information include but are not limited to:
We may disclose your personal information, only if one or more of the following apply:
This may include disclosure of your personal information to our employees, contractors and related entities, as well as third parties who supply services to us to assist us in performing our administrative functions and in fulfilling our legal and regulatory obligations (e.g. legal and accounting firms, data storage systems and certain SaaS providers). We will take reasonable steps to ensure that they handle your personal information in the same way that we do and in accordance with the Privacy Act and the APPs.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third-party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.
You may request access to the personal information we hold about you or request that we change the personal information, by contacting us in the manner outlined below. You may also contact us if any of the details you have provided change or if you believe that the information we have about you is not accurate, complete or up-to-date. If we do not agree to provide you with access or to amend your personal information as requested you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision and you may seek a review of our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.
You may also request that we restrict the use of your personal information for direct marking purposes by contacting us using the contact details below. Alternatively, to unsubscribe from our e-mail database or opt-out of communications (including marketing communications) you may use the opt-out facilities provided in the communication.
If you wish to make a complaint about a breach by us of the Australian Privacy Principles, you may do so by providing your written complaint by email, letter or by personal delivery to any one of our contact details as noted below. Where possible, the complaint should include enough information to help us resolve it. We will respond to your complaint in writing within a reasonable time (usually no longer than 30 days) and we make seek further information from you in order to provide a full and complete response.
If you are not satisfied with our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner by visiting www.oaic.gov.au.
We do not charge for receiving a request for access to personal information or for complying with a correction request.