PRIVACY

Introduction

This Privacy Policy details how we protect your privacy and how we comply with the requirements of the Privacy Act 1998 (Cth) and the 13 Australian Privacy Principles (“APPs”). This policy also describes:

Who do we collect personal information from?

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 and hold your personal information

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 may use cookies on our website from time to time. Cookies are text files placed in your computer & browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our website with personal information, this information may be linked to the data stored in the cookie. We may use web beacons on our website from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We hold your personal information:

How we use your personal information

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:

When we disclose your personal information

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.

We may provide links to third-party websites. Any information provided to the third party website is outside our control and not subject to this Privacy Policy.

Disclosure of your personal information to overseas recipients

In certain limited circumstances, such as where there are foreign indicia on your account, your personal information may be shared with the Australian Tax Office and/or ASIC which will then exchange this information with similar overseas regulatory bodies as a result of Australia’s participation in the Common Reporting Standard and Foreign Account Tax Compliance Act. We may also, in accordance with this Privacy Policy, disclose your personal information to other third parties who reside outside Australia. In this instance, we will take reasonable steps to ensure that the third party recipient does not breach the Australian privacy laws.

Your rights of access, correction and restriction

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.

Your right of complaint

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.

How to contact us

You can contact us about this Privacy Policy or about your personal information by emailing hello@beamescapital.com or writing to our Privacy Officer at GPO Box 1226, Melbourne VIC 3001, Australia.

Changes to our privacy and information handling practices

This Privacy Policy is subject to change at any time.