1.1 In order to provide our services to our clients/investors, we would need to request and retain some personal information. This allows us to process applications, administer accounts and provide you with information. We may also use your personal details to communicate with you about products and services and comply with relevant laws. We consider all information about our clients to be private and confidential.
1.2 We are required to collect certain personal information under Australian law, including the Corporations Act 2001, the Anti-Money Laundering and Counter Terrorism Financing Act, other financial services laws and taxation laws.
1.3 If you do not provide the personal information requested, we may not be able to process an application, provide services to you or provide you with information about our products and services.
2.1 The privacy laws regulate the way organisations:
- keep secure; and
- give people access to their personal information, i.e. information about an individual that identifies them.
3. Details of Policy
Whom do we collect information from?
Wherever practicable, SUMO SIV will collect information about individuals from those individuals. However, it may be necessary at times to collect information about individuals from other external sources, such as:
- a financial adviser or broker;
- authorised representatives, such as executors or administrators; and
- identity verification service providers.
We may also collect information about financial advisers from third parties for the purpose of providing information about our product and services.
What kind of information will we collect?
In order to establish and administer accounts for our investors and provide information about our products and services to investors and financial advisers, and to comply with relevant legislation, we may collect all or some of the following:
- full name, date of birth, gender and contact details including telephone, address, e-mail and fax;
- copy of a driver’s licence and /or passport or other identification documentation for the purpose of verifying identity and to ensure compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act and/or other Australian legislation and regulations regarding identification verification, and tax reporting and withholding;
- tax file number and bank account details for the purpose of administering investor accounts and tax reporting and withholding;
- investor contribution details and investment choice;
- details about authorised signatories;
- detailed contact information about a financial adviser;
- copies of any relevant trust deeds, partnership agreements, constitutions or articles of association, which may be relevant to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act; and
- details of services investors or financial advisers are interested in and about the investment needs of individual investors, for the purpose of gathering demographic information.
3.2 Use and disclosure
How is personal information used?
Generally, we only use and disclose information for the purpose for which it was disclosed to us or related purposes which would reasonably be expected. Those purposes include:
- to establish and administer an investor’s investment account and their relationship with us;
- for communication purposes;
- to enable us to provide information about new and existing products and services that will enhance our relationship with the relevant parties. However, we do respect the right of individuals to ask us not to do this;
- to conduct analysis about our products and services to enhance our service offering;
- to comply with our record-keeping, reporting, and tax obligations;
- to protect legal rights and comply with legal obligations;
- to prevent fraud and abuse; and
- to handle any relevant enquiries or complaints.
Who may we disclose your information to?
Required by law
We may be required by law to disclose personal information. For instance, we may be required to provide details to:
- Australian Government regulators such as the Australian Securities and Investments Commission (ASIC), Australian Prudential Regulatory Authority (APRA), Australian Tax Office (ATO), Australian Transaction Reports and Analysis Centre (AUSTRAC) and to other regulatory or government entities;
- Financial Ombudsman Service (FOS);
- as required by a court order; and
- to other regulatory or governmental entities as may be required.
- In order to meet our investors’ needs and provide some investor services, such as administration of accounts and mailing of investor distribution statements, it may be necessary to release information or provide access to external service providers, for instance:
- any organisations involved in providing, managing or administering our products systems or services such as administrators, mail houses and software and information technology providers;
- auditors, consultants and other professional advisers;
- authorised financial advisers;
- a legal personal representative, attorney or any other person who may be entitled to receive the proceeds from a deceased investor’s account balance and any person contacted to assist us in that process;
- other financial institutions who hold an account in an investor’s name, for example, where amounts have been transferred to or from that account.
3.3 Information quality & security
SUMO SIV relies on the accuracy of the personal information provided. We aim to ensure that it is accurate, up to date and complete. If any of your details change or you have any concerns regarding its accuracy you should contact us.
We take steps to protect personal information from unauthorised access, modification, and disclosure including requiring use of passwords, user logins, or other security procedures. Developments in security and encryption technology will be reviewed regularly.
Where necessary, we will remind our clients that the internet is an insecure medium.
3.4 Access to & correction of information
You may request access to any personal information we hold about you. We may charge you an administration fee that is applicable from time to time for complying with your request. Generally, if it is incorrect, we will correct it at your request. However, this is subject to some exceptions allowed by law, for example:
- if access to information would have an unreasonable impact on the privacy of others;
- if the request is frivolous or vexatious;
- if providing access would be unlawful;
- if access would prejudice enforcement activities relating to criminal activities and other breaches of revenue, or a security function;
- where a third party has given us health information about you in confidence;
- if denying access is required or authorised by or under law.
If access is denied we will provide you with the reason why.
If you have any further questions relating to this privacy statement, wish to request access to personal information we hold about you, or have concerns about the way in which we have handled your personal information, please do not hesitate to contact us. Our contact details are as follows:
SUMO SIV Pty Ltd
GPO Box 4192
Sydney NSW 2001
Telephone: +61 2 8297 6666