WHAT IS PERSONAL INFORMATION For the purpose of this policy and the Act “Personal Information” means information or an opinion (including information or an opinion forming part of a document or other source), whether true or not, and whether recorded in a material form or not, about a person whose identity is apparent, or can be reasonably ascertained, from the information or opinion. Personal information may include:
name, gender and date of birth
contact details such as address, phone number and email address
bank account details for direct crediting of distributions and redemptions
investment information about your holding in our products
login details for our website
Tax File Number/Australian Business Number, if you have chosen to disclose it
responses to our surveys
any personal information necessary for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
To assist Tamim in providing quality services, it is important that the information you entrust to us is accurate and complete. You can help us to keep your information up to date by contacting us immediately if your contact details change. We may also collect personal information if authorised or required by an Australian law or court or tribunal order to collect that information. We will tell you if collection is required or authorised by law and provide you with details of the law, court or tribunal order. For example, when you make an application for a financial product Tamim is required under the Anti-Money Laundering and Counter-Terrorism Financing Act to collect certain information from you to prove your identity, such as your driver’s licence or passport details. Tamim may collect your Australian tax file number (TFN). It is not compulsory to provide your TFN, but if you do not, Tamim may deduct withholding tax from your distribution payments at the highest marginal rate. Tamim will collect your TFN to determine whether you are subject to withholding tax on any distribution payments you receive and for communication purposes of distribution payments to the Australian Taxation Office. If Tamim collects your TFN, we will handle your TFN in accordance with the Privacy Act and Guidelines issued by the Commissioner. Tamim may also be required to ask about your tax residency status under taxation information sharing agreements the Australian Government has in place with other countries. As an example, a tax treaty between Australia and the United States formed under US law (Foreign Account Tax Compliance Act) requires Tamim to ask investors in our applications whether they are US citizens or US tax residents when they make an application. If you are a tax resident of another country, the relevant treaty or law may require us to collect your relevant foreign tax identification number.
COLLECTION OF INFORMATION THAT IS SENSITIVE Sensitive information is personal information including a person’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, genetic information or health information. Tamim will not collect, use or disclose sensitive information about you unless we need the information for one of our functions or activities and we have your consent (or we are legally required to do so).
INFORMATION WE MAY COLLECT FROM YOU We may collect information about you and your interactions with us, when you request or use our products or services, make a card purchase or transfer money, phone us or visit any of our websites. When you use our website or mobile applications we may collect information about your location or activity including IP address, telephone number and whether you’ve accessed third party sites. Some of this website information we collect using Cookies. If you do not wish to accept cookies from our site, you may disable cookies in your internet browser settings.
HOW WE MAY USE AND DISCLOSE YOUR PERSONAL INFORMATION Tamim may use and disclose personal information we collect about you for several purposes including:
to consider your request for a product or service;
to enable Tamim to provide a product or service;
to tell you about other products and services that may be of interest to you;
to assist in arrangements with other organisations (such as loyalty partners) in relation to the promotion or provision of a product or service;
to manage accounts and perform other administrative and operational tasks (including risk management, systems development and testing, staff training and market or customer satisfaction research);
to consider any concerns or complaints you raise against Tamim and/or to manage any legal action between you and Tamim;
to prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
to identify you or establish your tax status under any Australian or foreign legislation, regulation or treaty pursuant to an agreement with any tax authority; and
as required by relevant laws, regulations, codes of practice and external payment systems.
If Tamim uses your personal information for direct marketing of its products or services, it will provide you with the opportunity, at the point of our first contact and at any time afterwards at your request to decline receipt of any further marketing information. Otherwise, Tamim will neither use nor disclose your Personal Information that is not related to the purpose for which we collected your information in the first place without your consent, unless:
A) It is required for public health or public safety or other emergency reasons; or B) It is required to investigate or report suspected fraud or unlawful activity; or C) It is required or authorised by law; or D) Tamim believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body:
the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;
the enforcement of laws relating to the confiscation of the proceeds of crime;
the protection of the public revenue;
the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;
the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.
DISCLOSURE OF PERSONAL INFORMATION We will not disclose personal information collected by us for any purpose other than where you have consented to the disclosure; or where the National Privacy Principles authorise use or disclosure where required or authorised by law, in circumstances relating to public health and safety, social security and taxation in connection with certain operations by or on behalf of an enforcement body. In relation to our role as a financial service provider we are required pursuant to the Corporations Act to maintain certain transaction records with regards to your investment in our products and make those records available for inspection to the Australian Securities and Investments Commission. We may disclose personal information to external service providers such as fund managers, custodians, brokers, portfolio and self managed superannuation fund administration, credit assistance, legal services and property investment and related services, mailing houses and auditors for the purpose of giving effect to the service provided by us. These external parties are only authorised to use personal information for the purpose for which Tamim supplied it. Those organisations are not authorised to use that information for their own purposes.
SENDING INFORMATION OVERSEAS We may send your information overseas, including to overseas Group members and to service providers or other third parties who operate or hold data outside Australia. Where we do this, we make sure that appropriate data handling and security arrangements are in place. Please note that Australian law may not apply to some of these entities. We may also send information overseas to complete a particular transaction, such as an International Money Transfer, or where this is required by laws and regulations of Australia or another country.
INTEGRITY OF PERSONAL INFORMATION We are committed to ensuring that personal information collected and kept by us is kept safe and secure from misuse, loss, unauthorised access, incorrectness, modification or disclosure. Should your details change, we ask that you advise us of the change as soon as possible so that we may maintain correct records. Our security measures include:
educating staff about their obligations with regard to your personal information
confidentiality requirements of our employees
only giving access to personal information to a person who is verified to be able to receive that information
electronic security systems, such as firewalls and data encryption on our websites
security access to our office premises
secure storage for physical records
the use of passwords to access database information
the use of document shredders for the disposal of written information.
Our client login area on our website uses Secure Sockets Layer (SSL) protocol that was developed to protect confidential information such as financial data from interception and hacking. We cannot be held responsible for lapses in security caused by third-party access to information as a result of your failure to keep your personal information private. We reserve the right to gather more extensive information about any attempted access to our website that raises security issues and, if appropriate, make disclosures to the relevant authorities.
The information provided on this website should not be considered financial or investment advice and is general information intended only for wholesale clients ( as defined in the Corporations Act). If you are not a wholesale client, you should exit the website. The content has been prepared without taking into account your personal objectives, financial situations or needs. You should seek personal financial advice before making any financial or investment decisions. Where the website refers to a particular financial product, you should obtain a copy of the relevant product services guide or offer document for wholesale investors before making any decision in relation to the product. Investment returns are not guaranteed as all investments carry some risk. The value of an investment may rise or fall with the changes in the market. Past performance is no guarantee of future performance. This statement relates to any claims made regarding past performance of any Tamim (or associated companies) products. Tamim does not guarantee the accuracy of any information in this website, including information provided by third parties. Information can change without notice and Tamim will endeavour to update this website as soon as practicable after changes. Tamim Funds Management Pty Limited and CTSP Funds Management Pty Ltd trading as Tamim Asset Management and its related entities do not accept responsibility for any inaccuracy or any actions taken in reliance upon this advice. All information provided on this website is correct at the time of writing and is subject to change due to changes in legislation. Please contact Tamim if you wish to confirm the currency of any information on the website.