(a) This is the privacy policy of Inheritance Capital Asset Management Pty Ltd (ABN 77 608 095 030) (‘ICAM’). The purpose of this policy is to ensure that any individual who provides information to ICAM is protected under Australian law, in accordance with the Privacy Act 1988 (Cth) (‘Privacy Act’).
(b) Words defined in the Privacy Act have the same meaning when used in this policy.
Protecting your privacy
We seek to protect and maintain the privacy, accuracy and security of your personal information. We will comply with the Australian Privacy Principles (‘APPs’) in the Privacy Act.
Collection of information
(a) We may collect personal information about you such as:
(i) your name, current address, previous address details;
(ii) date of birth and gender;
(iii) email addresses and telephone and or mobile numbers;
(iv) current and previous employment information; and
(v) information to verify your identity and comply with anti-money laundering obligations.
(b) We collect information when you use our website. Please refer to the website section of this policy for further details. We do not collect sensitive information about you such as your racial or ethnic origin, political opinions, religious beliefs or affiliations.
(c) If there is another person named in any correspondence, you may need to provide their personal information and you warrant that the other person has consented to the collection of their personal information for the reasons it is being collected.
If you do not provide personal information
The main consequence for you, if some or all of the above personal information is not collected by us is that we may not be able to provide products, services or information to you, or be able to provide them to the same standard as if we had the information requested.
How we collect personal information
We collect personal information in a variety of ways. We mainly collect information from you when you knowingly provide it to us including via our website, when you contract with us, when you make a request or enquiry of us or when you join our mailing list. We may collect information about you from third parties (including your brokerage or financial advisory firm or other consultants) for the purposes set out in this privacy policy.
Why we collect, hold and use and disclose personal information
(a) We collect, hold, use and disclose personal information about individuals when it is necessary for us to carry on our business functions or to comply with laws.
(b) We may collect, hold, use and disclose your personal information to answer your enquiry or to provide the information or service that you requested.
(c) We may also collect, hold, use or disclose your personal information:
(i) to enable us to develop, administer and manage our services and business;
(ii) to verify your identity;
(iii) to customise service to better meet your needs and preferences;
(iv) for statistical purposes;
(v) for future promotional and marketing purposes including direct marketing;
(vi) for research purposes to better improve our websites, products or services;
(vii) for other customer support purposes;
(viii) to deal with complaints, queries or feedback; and
(ix) when authorised or required by law.
Direct Marketing
ICAM may send you marketing material. You may choose to “opt-out” of receiving this material by emailing investors@icamfunds.com. ICAM will not charge you any additional cost or in any way disadvantage you for choosing to “opt-out” of receiving marketing material.
When we may disclose your personal information to third parties
As is common in the industry, ICAM engages or may engage non-affiliated companies to provide certain services on its behalf, such as preparing and mailing investor correspondence including reports, account statements and other information, undertaking marketing activities, and conducting research on client satisfaction.
In the course of conducting our business we may also provide your personal information to:
(a) our related companies;
(b) your nominated financial advisory firm, financial adviser or broker, or their service providers;
(c) our business partners and affiliates, such as investment funds, our authorised representatives under our Australian financial services licence or brokers and dealers that we work with when providing and marketing our products and services;
(d) our professional advisers, including our lawyers, auditors and accountants; and
(e) government bodies, regulators or law enforcement authorities, as required or authorised by law.
We may disclose your personal information to third parties:
(a) to meet the purpose for which it was submitted;
(b) if we have your consent to do so or otherwise when we are authorised by law;
(c) if we are required by law to disclose the information.
Overseas recipients
We will not disclose your personal information to overseas recipients.
Security
We will take reasonable steps to:
(a) make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
(b) protect the information from misuse, interference, loss or unauthorised access, modification or disclosure both physically and through security methods; and
(c) destroy or permanently de-identify the information if it is no longer needed for any purpose.
Third party websites
(a) This privacy policy is strictly limited to the collection, storage and use of personally identifiable information collected by ICAM, in the course of business, and does not apply to any third parties. We have no control over the privacy practices or the content of any third party websites, and assume no liability for the privacy practices of these websites.
(b) Any link on the ICAM site to external entities are not covered within this policy. The terms and conditions set out in this privacy policy only cover the domain name of https://icamfunds.com.
Privacy
(a) At your request we will provide details of the personal information we hold about you. The release of information is subject to some exceptions such as information relating to existing or any anticipated legal proceeding, together with exceptions provided by the Privacy Act.
(b) Unless unusual circumstances apply, we should provide access to you within 30 days of the request.
(c) We reserve the right to charge a fee for providing access to your information to your information when permitted by law.
(d) To protect your personal information, the request to us must be in writing and can be sent by letter or facsimile or email. All correspondence should be addressed to:
Mail:
Inheritance Capital Asset Management Pty Ltd
Level 4, 91 King William Street
Adelaide SA 5000
Email:
investors@icamfunds.com
(e) Our objective is to respond to any request within a reasonable timeframe.
(f) We also aim to ensure that your personal information is accurate, up to date and complete. Amendment of personal information will be conducted upon written or verbal request from you. You can contact by writing to us to do this.
Complaints
(a) We are committed to the protection of your privacy and personal information. Complaints you may have about your personal information can be lodged with us by using the contact details above.
(b) We will attempt to resolve any complaints within 10 working days. If resolution is not possible within this timeframe we will contact you to discuss the matter further.
(c) You also have the right under the Privacy Act to make a complaint to the Information Commissioner.
Changes to this policy
This policy is subject to change over time without prior notice. We may amend this policy by updating this posting.
Copies of this policy
You can ask us to provide you with a copy of this policy, including a hard copy, by contacting us using the contact details above.
Date published: March 2020
