At Thymos Capital the client always comes first. We respect and protect the privacy of the personal information of individuals with whom we deal.
Personal information is any information, including an opinion, that can be used to identify an individual or can be linked to an individual.
The term ‘Thymos Capital’ includes Thymos Capital Pty Ltd (ACN 648 475 512), its affiliates, all of which are represented in this policy. Any reference to ‘we’, ‘us’ and ‘our’ in this policy means Thymos Capital.
The information we collect and hold
Whenever it is reasonable and practical to do so, we collect information about you directly from you. We may collect personal information about you which is reasonably necessary to:
- Provide you with quality products or services;
- Consider applications and approaches you make to us;
- Maintain your contact details; and
- Fulfil our legal obligations under applicable laws and rules, such as those relating to taxation and Anti-Money Laundering and Counter-Terrorism Financing.
We generally hold personal information relating to:
- The products and services we provide or have provided to you;
- Your financial interests and sometimes your financial position, if you are a customer or potential customer of ours;
- Your name, contact details and identification information; and
- Records of our interactions with you.
Examples of personal information we may collect about you: investment details and instructions, account numbers, usernames, passwords, answers to security questions; details about authorised signatories, agents, or representatives (including deceased estates); contact details, including telephone numbers, addresses, e-mail addresses and fax numbers; tax file number and bank account and payment method details; details about authorised signatories, agents or representatives and copies of drivers licence, passport or other such information as is required for Thymos Capital to comply with its legal obligations including identity verification, tax reporting and withholding and under the Anti-Money Laundering and Counter-Terrorism Financing legislation.
We do not generally collect sensitive information about you unless required by applicable laws or rules. Sensitive information includes information relating to:
- Political or religious beliefs;
- Membership of professional or trade associations or unions; and
- Health information.
We may collect health information if assessing certain matters such as a hardship claim for preferential assistance. We do not use or share that information for any purpose other than as disclosed to the customer when the information was collected. We may collect information about your affiliation with certain organisations such as professional associations.
If you represent a financial adviser or corporate or institutional client (including as an employee or officer), we may collect additional personal information about you that will assist us in the provision of products and services to you and the client you represent.
How we collect personal information
Generally, we will only collect personal information directly from you or from our external services providers. We collect personal information in a number of ways and this may depend on how you interact with us. We may collect it through completed application forms where we offer our products and services, by telephone, by email and website contact, in correspondence with you or in person at one of our offices. We may also collect information about your transactions with us.
Employment participation may also be a way in which we collect personal information, such as the submission of an application or registering an expression of interest for employment with us. This information may also be obtained from recruitment agencies or referees.
We may transfer personal information to another Thymos Capital entity.
How we hold personal information
We may hold your information in either electronic or hard copy form. When we no longer need your personal information, we will either securely destroy it, or irreversibly anonymise the data (and we may further retain and use the anonymised information).
We store hardcopy files in offices and cupboards within an access controlled premises. [We also store hardcopy files with an offsite storage provider whose premises is monitored by CCTV and access is strictly controlled.]
We store electronic records within our own secure network and through third party data storage providers. Refer to the section “Keeping information secure” for more information on our processes for securing personal information provided to us.
Why we collect personal information
In providing financial services to existing and prospective clients, we may collect personal information from a person for a number of reasons including:
- Maintaining, managing and developing our relationship with you;
- Organising, marketing and running our business programs, workshops and events (including competitions and promotions run by us);
- To enable you to use our websites and communication channels;
- assessing and considering applications from clients, contractors, volunteers and service providers;
- Developing and managing relationships with our employees, contractors and service providers;
- Contracting out some of our functions to external service providers and suppliers (such as IT, mailing and couriers, research, event management, accommodation, travel, professional advisors and recruitment);
- Complying with our legal and regulatory obligations; and
- For security purposes;
Financial service purposes
- Performing various functions and activities associated with the provision of financial products and services (including administering accounts), for marketing and promotional purposes;
- Tailoring the content of materials that we send you;
- To better understand how you use our products and services; and
- For research and analytical purposes.
We will only collect personal information that is reasonably necessary for us to fulfil our functions and activities.
You are not obliged to provide any of the personal information we ask for. However, if you do not provide the personal information requested, we may not be able to accept or process an application from you or provide you with the products and services you have requested.
We will cooperate with all law enforcement bodies, including providing personal information we have collected from you when required or requested.
How that information is used
In order to fulfil our functions and activities, including to service your needs and perform our role, we may need to disclose your personal information with another person or organisation.
For example, we may use and disclose personal information to:
- Administer and manage our products and services including monitoring, auditing, and evaluating those products and services;
- Model and test data in connection with the products and services we provide or intend to provide;
- Communicate with you; and
- Deal with any complaints or enquiries.
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.
We do not sell personal information to other organisations, nor provide organisations outside Thymos Capital with your personal information unrelated to the management or administration of your investment.
We may disclose personal information outside Thymos Capital:
- As required by relevant laws or rules, such as those relating to Anti-Money Laundering and Counter-Terrorism Financing;
- To service providers who provide services including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, mailing, marketing, research, operational, compliance, investigation, identity verification, maintenance, trustee, securitisation, website and technology services; and
- To your nominated financial adviser or an authorised person with your permission.
In some circumstances the parties with whom we share personal information may operate outside of Australia (this includes locations in the countries listed in the Appendix). Where this occurs, we take steps to protect personal information against misuse or loss.
Keeping information accurate and up to date
We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.
Keeping information secure
We use security procedures and technology to protect the information we hold. Access to and use of personal information within Thymos Capital seeks to prevent misuse or unlawful disclosure of the information.
If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.
Where the personal information we collect is no longer required, we delete the information or permanently de-identify it.
If there is a suspected or actual data breach which may compromise personal information, Thymos Capital will promptly undertake an assessment of the incident. Where relevant, immediate steps will be taken to contain the breach. These steps may include limiting any further access or distribution of the affected personal information, or the possible compromise of other personal information.
If the unauthorised access, disclosure or loss of personal information is likely to cause serious harm to one or more individuals and the likely risk of serious harm has not been prevented by remedial action, Thymos Capital will notify affected individuals and the Office of the Australian Information Commissioner as soon as practicable. The notification will include details of the Thymos Capital identity and contact details, a description of the incident, the kind/s of information concerned and any recommended steps for affected individuals.
Following any data breach incident, Thymos Capital will undertake a review process to help prevent future breaches.
How you can access or correct your information
You can contact us as set out below to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
If you believe that the personal information we hold is inaccurate, incomplete or out-of-date, you should contact us to correct this information.
Our contact details are below under the heading “Contacting us”.
How you can make a complaint
If you have any concerns about how we have handled your personal information, please contact us, refer to the contact details below under the heading “Contacting us”. We will seek to provide a response and resolve a complaint as soon as practicable and, in general, no later than 45 days after receipt of the initial complaint.
If you are not satisfied with the outcome of your complaint, you may refer the matter to the Office of the Australian Information Commissioner.
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 regret that we will not be able to offer you the product or services if we cannot identify you.
Dealing with Thymos Capital online
When you visit the Thymos Capital website you will browse anonymously unless you have accessed the Website from a personalised communication from Thymos Capital.
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 our 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 (see below).
We, or a third party that we partner with, such as a data analytics specialist service provider, may also collect information about you when you log-in or browse our Website via a ‘cookie’.
A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes. Cookies are generally used on the Thymos Capital Website to collect identifiable information about your use of our website – if we have identified you as a result of you accessing our website from an e-mail or other personalised communication sent to you.
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences).
If you wish to contact us, require access to, or wish to update your personal information or would like to make a complaint, please contact our Privacy Officer:
Attention: Privacy Officer
Suite 208, Great Buckingham Street, Redfern, New South Wales, 2016
Email: [email protected]