Conscious Investment Management (“CIM”) understands and appreciates that your privacy is very important to you and that you have a right to control your personal information. We know that providing personal information is an act of trust and we take that seriously. This Policy outlines the steps CIM takes to protect your personal information, and what sort of personal information CIM may hold about you, for what purposes and how it is collected, held, and used.
We respect your privacy and are committed to managing your personal information responsibly and in accordance with our legal obligations, including under the Privacy Act 1988 (Cth).
Collecting personal information
Personal information is any information that can be used to personally identify you. We collect personal information so we can provide you with products and services that you have requested or which you have enquired about, and any additional information necessary to deliver those products and services. We may also collect your personal information to respond to your enquiries and so we can let you know about other products, services, or opportunities you might be interested in.
What personal information do we collect and hold?
We may collect the following types of personal information:
- your name, addresses and contact details (including phone numbers and email addresses);
- your age or birth date;
- your interests in our products;
- your profession, occupation or job title;
- information about your dealings with us or anyone else;
- any information relating to you that you provide to us directly through our websites or indirectly through use of our websites; and
- any other information we consider necessary to your situation.
If you have invested in a fund managed by CIM, CIM or its designated representatives may also collect additional personal and sensitive information required to fulfil obligations under applicable laws and rules.
How do we collect your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect it in ways including:
- through your access and use of our websites;
- during conversations between you and our representatives; or
- when you complete an application to make an investment in a fund managed by CIM.
In some situations, we may collect information about you from third parties such as your legal or personal representatives, your financial advisers, or publicly available sources of information. We will only collect your information from third parties when we reasonably believe that you have consented to these sources collecting and disclosing the information.
In cases where we collect or utilise personal data based on your consent, you have the right to withdraw that consent at any time. To withdraw consent, you can contact us using the information in the “Contacting Us” section below. If you elect to withdraw your consent, it may mean we are unable to continue to provide our services to you.
What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
- we may not be able to provide the requested products or services to you;
- we may not be able to provide you with information about products and services that you may want.
For clients who currently or propose to invest in a fund managed by CIM, failure to provide certain information may result in us not being able to process your application request.
Using and disclosing your personal information
We only use and disclose personal information about you for the purpose for which it was disclosed to us or related purposes which would reasonably be expected without your permission. In line with modern business practices and to assist you with your requirements we may use and disclose your personal information for the reasons and to the organisations/persons described below:
- our employees, related bodies corporate, contractors or service providers for the purposes of operation of our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation: companies involved in maintaining, reviewing and developing our business systems and infrastructure; and organisations involved in processing investment applications and providing, managing or administering the products and services you receive from CIM, such as third party suppliers;
- to service providers who provide other key business services to us, including archival, auditing, administration, accounting, customer contact, custody, legal, business consulting, banking, payment, delivery, investment management, data processing, data analysis, mailing, marketing, research, investigation, identity verification, maintenance, trustee, securitisation, website and technology services;
- your nominated financial adviser(s);
- those people who are your authorised legal or personal representatives;
- government or regulatory bodies as required or authorised by law; or
- any other company or person with your express consent.
We may from time to time also use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, we do respect your right to ask us not to do this.
Your personal information will not be shared, sold, or disclosed other than as described in this Policy.
Protecting your personal information and keeping it accurate and up-to-date
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us, and we take reasonable steps to protect it from misuse and loss and unauthorised access, modification or disclosure. If other organisations provide support services, we require them to appropriately safeguard the privacy of any personal information which may be provided to them.
Where the personal information we collect is no longer required, we will seek to delete the information or permanently de-identify it.
We will also take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. If you believe your personal information is not accurate, complete, or up to date, please contact us.
If you believe that your personal information is incorrect or out of date you can request to have this amended. To request access to your personal information you can contact us using the information in the “Contacting Us” section below.
If the unauthorised access, disclosure or loss of personal information is likely to cause serious harm to the individual to whom the personal information relates and the likely risk of serious harm has not been prevented by remedial action, CIM will notify the affected individual and the Office of the Australian Information Commissioner in accordance with our legal obligations.
If there is a suspected or actual data breach which may compromise personal information, CIM will promptly undertake an assessment of the incident. Where relevant, immediate steps will be taken to contain the breach. Following any data breach incident, CIM will undertake a review process to help prevent future breaches.
Links to other sites
You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to determine what security measures they have in place.
Your sensitive information
We do not generally collect sensitive information about you unless we are required by applicable law or rules.
Sensitive information includes information relating to:
- Political or religious beliefs;
- Sexual preferences;
- Criminal convictions;
- Membership of professional or trade associations or unions; or
- Health information.
Dealing with us anonymously or under a pseudonym
You can deal with us anonymously or you may use a pseudonym where it is lawful and practical to do so. For example, you may enquire about our products or request a copy of our disclosure documents. However, we may not be able to offer you certain product or services if we cannot identify you.
Dealing with CIM online
- A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes.
- An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also derive the general geographic area associated with an IP address.
If you are an anonymous visitor, the information we collect is not capable of personally identifying you.
Once you have accessed our website from an e-mail or other personalised communication sent to you, we may be able to identify you. If we have identified you, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our website, irrespective of how you access our sites (e.g. by clicking a link in an advertisement or from a third party website). In addition, we may combine that information about your use of CIM’s website with certain other online and offline information we have about you in order to tailor your online experience and provide you with further information. If you would prefer not to be identified, you can delete the cookies and reconfigure the cookie preferences on your internet browser.
Use of Third-Party Web Analytics
We may use third-party web analytics services on our website, such as those of Google Analytics. These external service providers assist us in understanding and interpreting the usage patterns of visitors on our platforms. As part of this analytical process, data (which includes, but is not limited to, your IP address and other automatically gathered information) may either be directly accumulated by these service providers or be made accessible to them through disclosure. For those who wish to explore the possibility of opting out from Google Analytics, please follow this link.
Mail: Level 3, 223 Liverpool Street, Darlinghurst NSW 2010
Where you contact us seeking resolution of your privacy concerns, we will respond to let you know who will be handling your matter and when you can expect a further response. If your concerns are not resolved to your satisfaction or if we have not responded to your concerns within 30 days, you may escalate your complaint to the Office of the Australian Information Commissioner as set out at www.oaic.gov.au.
Before you contact the Office of the Australian Information Commissioner, we recommend that you first try to resolve your concern with us.