Privacy Statement

This Privacy Statement (the “Privacy Statement”) is the Privacy Policy of Tactical Global Management Limited (“TGML”), for the purposes of the Privacy Act 1988 (the Act) and provides information on how your “personal information” is managed, including how it is collected, held, used and disclosed from time to time.

In this document, “we”, “us”, “our” means TGML.

We may make changes to this Privacy Statement from time to time and for any reason. Any changes will be reflected on our website, www.tgm-global.com .

 

Table of Contents

1 Introduction.

2 Personal Information we may collect?.

3 Why do we have to collect, hold, use and disclose personal information?.

4 How we collect personal information.

5 Is The Information Disclosed To Third Parties?.

6 Use Of Cookies.

7 Security Information.

8 Changing or Updating Individual Information.

9 Linked Sites.

10 Feedback.

 

Introduction

At TGML we respect your right to privacy and are committed to ensuring your personal information is collected, used, disclosed and maintained in accordance with the Australian Privacy Principles (APP) under the Act.

We protect your personal information with the same integrity that we would use to handle our own individual personal information. This enables us to conduct business and exchange information in a secure environment, meeting employee, customer and regulator expectations for privacy, security and confidentiality.

 

Personal Information we may collect?

The type of personal information that we may collect and hold will vary depending on both the service we provide and the circumstances in which we are dealing with you.

The identifiable personal information that we collect may consist of a user’s full name, title, employer, and contact information such as e-mail addresses, and telephone and fax numbers. We may also collect your tax file number, but only where we are required or authorized by law to do so.

The Act restricts the collection of sensitive personal information. Examples of this include health information and information about an individual’s criminal record. Generally, we do not collect this sort of information. However, we may do so if you are applying for a job with us and you have provided your consent to this collection.

 

Why do we have to collect, hold, use and disclose personal information?

We collect, hold, use and disclose your personal information as is reasonably necessary for our business purposes and as permitted by law.

We may also collect, hold, use and disclose your personal information for the following purposes:

  • Recruitment and employment purposes – for example, to assess your suitability to the position you are applying for;

  • Engaging service providers, contractors or suppliers;

  • To maintain your details so we are able to respond to any of your inquiries;

  • Dealing with complaints; and

  • Meeting legal and regulatory requirements. Various Australian laws may expressly require the APP entities to collect your personal information or the APP entities may need to do so in order to be able to comply with other obligations under those laws. Such laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (for example, to comply with obligations to combat money laundering and financing of terrorism) or the Taxation Administration Act 1953, the Income Tax Assessment Act 1936 and other taxation laws (for example, to comply with obligations relating to employment or with information requests issued by the Commissioner of Taxation); enforcing our rights including undertaking legal proceedings.

 

How we collect personal information

If it is reasonable and practical to do so, we will collect personal information directly from you. For example, if we are dealing with you as a representative of a Client (such as a director or other officer of a client) or as a client of a Client, you may provide personal information as a result of your dealings with us. We may collect your personal information through application forms, over the telephone, the internet or in person when you visit our office. We may also collect your personal information when you call us.

We may also need to collect personal information from third parties, including:

  • Client’s service providers, for example, Fund Administrators or Custodians;

  • Your representative (such as a legal adviser, financial adviser, accountant), for example, where we need to verify information you have provided;

  • And government agencies, such as the Federal Policy, for example where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation for reporting of the matter.

 

Is The Information Disclosed To Third Parties?

We do not give, sell, rent, share or trade any identifiable personal information regarding our clients to any third party.

Information will remain within the TGM group, unless TGM is required by law to disclose the information.

 

Use Of Cookies

A cookie is a small piece of text that is placed within the memory of your computer and can be later retrieved by web page servers for marketing and other purposes.

TGM respects your privacy and accordingly does not use cookies to collect information about your web browsing habits. Read More about our use of cookies on this website.

 

Security Information

TGM has implemented appropriate physical, electronic and managerial security procedures in order to protect personally identifiable information from loss, misuse, alteration or destruction.

Only authorised TGM personnel are provided access to personally identifiable information in order to perform their roles and these employees have agreed to ensure confidentiality of this information.

TGM regularly reviews security and encryption technologies and will strive to protect information to the fullest extent possible.

 

Changing or Updating Individual Information

TGM will take reasonable steps to ensure that the individual information it collects, uses or discloses is accurate, complete and up-to-date, including asking the user to provide any changes or updates to individual information in each e-mail TGM sends. You may request access to all your personally identifiable information that we hold at any time, by contacting us.

Should you wish to update or verify the accuracy of or remove any of your personal information held by us, please notify us immediately.

We may not always be able to give you access to all the personal information we have about you. For instance, we may not be able to give you access to information that:

  • Would reveal personal information above another person;

  • Would reveal a commercially sensitive decision-making process;

  • We are prevented by law from providing to you; or

  • Relates to existing or anticipated legal proceedings.

 

Linked Sites

Our site contains links to other sites. TGM is not responsible for the privacy practices or the content of such web sites. We encourage you to read the privacy statements of these linked sites, as their Privacy Policy may differ from ours.

 

Feedback

We welcome your inquiries or comments about our Privacy Policy and any queries or concerns that you may have about our site.

You may direct these to Melanie Woodward:

Tactical Global Management Limited

ABN 35 077 796 411

Level 20, 10 Eagle Street

GPO Box 7892 Brisbane QLD 4001 Australia

t. +61 7 3239 2777

f: +61 7 3239 2700

melanie.woodward@tgm-au.com