Last updated: 7 August 2018
1. Purpose of policy
1.1 Truebell Financial Group Pty Ltd (Truebell) is committed to complying with its obligations under the Privacy Act 1988 (Cth).
1.1 This Policy sets out:
(a) how and why we collect and use your Personal Information; and
(b) what controls you have over your Personal Information in our possession.
1.2 We regularly review our practices and procedures regarding how we collect, hold, use, disclose and otherwise manage Personal Information. Consequently, this Policy is subject to change at our discretion. The current version will always be available on our website at www.truebellcapital.com.
2.1 In this Policy:
Act means the Privacy Act 1988 (Cth);
OAIC means the Office of the Australian Information Commissioner;
Personal information means information about you which personally identifies you or may reasonably be used to personally identify you;
Sensitive information has the meaning given to that term in the Act; and
Truebell or we or us means Truebell Financial Group Pty Ltd ACN 622 814 742 or its associated entities (including Truebell Capital Pty Ltd ACN 124 307 482) as appropriate.
3. Types of Personal Information we collect
3.1 We collect and hold various types of Personal Information, including:
(a) personal details, including name, contact details and date of birth;
(b) financial information, including tax file number, billing and payment details and details of your financial interests; and
(c) information relating to your qualifications and employment.
3.2 Truebell does not typically collect Sensitive Information about you, unless it is required by law and you have consented to the collection of that information.
3.3 We may collect various other types of Personal Information in the course of conducting our business where it is provided by our clients or other persons without being solicited.
4. How we collect Personal Information
4.1 We may collect Personal Information about you when:
(a) you access or use our website;
(b) you communicate with our employees or clients;
(c) you deal with us in the course of our business; and
(d) it is provided from publicly available records or public registries that we accessed in the course of providing funds management services to our clients.
4.2 If we solicit Personal Information, we will generally solicit it directly from the person it relates to or their agents, unless it is unreasonable or impracticable for us to do so.
4.3 It is generally not practicable for us to deal with persons on an anonymous or pseudonymous basis as we are required by law to obtain certain information in order to provide our services.
4.4 You are under no obligation to provide your Personal Information to us. However, without receiving certain information from you, we may not be able to provide our services to you and may not be able to process any application by you for investment in our funds or other products.
5. How we store and protect Personal Information
5.1 We may hold Personal Information in physical documents or in electronic form. Physical files are kept securely inside our access controlled premises. Electronic files are only accessible through our secure network.
5.2 We take reasonable steps to:
(a) ensure that Personal Information we collect is accurate, up-to-date, complete and relevant, other than where it is only collected to provide advice in respect of a particular point in time, in which case we will seek to ensure it is accurate, complete and relevant as at that particular point in time;
(b) ensure that Personal Information we use or disclose is accurate, up-to-date, complete and relevant, having regard to the purposes for which Personal Information is used or disclosed;
(c) protect Personal Information from misuse, interference and loss, and from unauthorised access, modification or disclosure; and
(d) destroy or de-identify Personal Information which we no longer need for the purposes for which it was collected, except where it is necessary to retain it in order to maintain ongoing records for our clients.
5.3 We cannot guarantee the security of information transmitted via the internet. As such, transmission of Personal Information via the internet is at your own risk.
5.4 Links to third-party websites may appear on our website. Your use of those links is entirely at your own risk and we make no representations or warranties regarding third parties’ privacy practices.
6. Why we collect, hold, use and disclose Personal Information
6.1 We collect, hold, use and disclose Personal Information for various purposes, including:
(a) providing funds management services or products to you;
(b) facilitating other interactions with you in the course of operating our business;
(c) complying with our legal obligations; and
(d) any other uses identified at the time of its collection.
6.2 More specifically, the way we use your Personal Information generally includes:
(a) processing your applications for investment in our funds or other products and establishing your investment in our funds or products;
(b) administering any investment you have with us in our funds or other products, including communicating with you about your investment;
(c) providing access to our website and other related online services;
(d) responding to queries you submit to us;
(e) providing you with information about our products or services that may be of interest to you;
(f) making deposits of distributions or withdrawals of your investment to your nominated bank account;
(g) accounting, billing and other internal administrative purposes;
(h) complying with our legal requirements under any applicable laws, including the anti-money laundering legislation; and
(i) complying with any other legal requirements which we are subject to.
6.3 We may disclose your Personal Information to such persons as is necessary to achieve the above purposes. This will often include disclosure to our related bodies corporate, certain government agencies, contractors or other third party service providers. We may also disclose your Personal Information to your financial and other professional advisers.
6.4 We may use or disclose Personal Information for secondary purposes where it would be reasonable to expect us to do so, and that secondary purpose is related (or directly related in the case of Sensitive Information) to the primary purpose.
6.5 Unless you inform us that you opt out, we may use your Personal Information for the purposes of sending you direct marketing publications, however, we will not disclose your Personal Information for the purposes of third-party direct marketing.
7. Overseas disclosure
7.1 It is unlikely that Truebell will disclose your Personal Information to an overseas recipient.
7.2 If at some future time, Truebell chooses to disclose Personal information to an overseas recipient, it will either obtain the your informed consent prior to doing so, will be required to do so by Australian law or prior to doing so will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the applicable principles under the Act in relation to the information.
8. How you can access correct Personal Information
8.1 You may contact us to access your Personal Information or to correct inaccurate, out-of-date, incomplete, irrelevant or misleading Personal Information by:
Mail: C/o Truebell Capital
Level 9/ 123 Albert St
Brisbane City, 4000
Phone: +61 7 3905 4555
8.2 We will respond to those requests within a reasonable period in accordance with our obligations under the Act.
8.3 To apply for access or to request a correction to your personal information, contact the Privacy Officer.
8.4 Generally, Truebell will provide you with access to your Personal Information in the manner you request and within a reasonable period of time after the request is made.
8.5 There are no charges for requesting access to your Personal Information. However, Truebell may charge a fee to provide access, provided that such fee is not excessive.
8.6 If we refuse a request to access or correct Personal Information, where reasonable, we will provide our reasons for doing so and information about your ability to complain about such refusal.
9.2 We will investigate and attempt to resolve your complaint in accordance with the Act.
9.3 You may contact the OAIC if you are not satisfied with the outcome of this process.
10. Further information
10.2 More information on the Act is available on the website of the OAIC at www.oaic.gov.au.