The policy explains how Tanarra collects, holds, uses, discloses and protects your personal information. It also explains how you may update your personal information that Tanarra holds and how you may make a complaint about how Tanarra has handled that personal information.
By accessing Tanarra’s website, investing in financial products in Tanarra funds or investments, or using Tanarra’s services, you consent to Tanarra collecting, holding, using and disclosing your personal information as described in this policy.
Collection of personal information
The information that Tanarra collects depends on the nature of your interaction with Tanarra. If you invest in funds or other financial products made available by Tanarra, personal information about you, such as your name, address, date of birth, contact details (including email address), occupation, bank account information and, potentially, tax file number, is collected through our documents, such as fund application forms and mandate letters and agreements.
When you access Tanarra’s website, Tanarra may collect technical and navigational information, such as device type, browser type, internet protocol addresses, pages visited, average time spent, user journeys and demographics and the time and date of access. Such information is collected anonymously and is used by Tanarra to analyse the efficiency of its marketing and publicity efforts as well as the design and functionality of the website.
Use of personal information
If you invest with a Tanarra fund or investment, we use your personal information to establish and administer your investment, comply with applicable laws, including the Anti-Money Laundering and Counter-Terrorism Financing Act and Rules and to communicate with you in relation to your investments.
Tanarra may also use your personal information for the primary purposes for which it was collected, including:
(a) the provision of educational, promotional and marketing material;
(b) the provision of Tanarra’s services; and
(c) assisting Tanarra to manage, develop and enhance its services, including this website, Tanarra reports and publications.
Tanarra may also use your personal information for other purposes to which you consent or which are required or permitted by law. This may include for a secondary purpose that is related to a purpose for which Tanarra collected it, and for which you would reasonably expect Tanarra to use.
If at any time you would like to unsubscribe from receiving future content, surveys, features or other marketing material or communications, Tanarra includes in all electronic messages a statement to the effect that you, as the recipient, may send an unsubscribe message to Tanarra using the contact details in that electronic message. Otherwise, you can contact Tanarra’s privacy officer at any time at the contact details below to unsubscribe or to update your preferences.
Tanarra does not actively seek to collect sensitive information, such as health information or information about criminal records, unless it is required by law, or for business purposes. If Tanarra does have to collect sensitive information, Tanarra will only collect, use and disclose the information in accordance with applicable privacy laws.
Disclosure of personal information
Tanarra may disclose your personal information (including in certain limited circumstances, your sensitive information) to:
(a) a member of the Tanarra group (ie, any related body corporate of Tanarra Capital Pty Ltd);
(b) Tanarra’s external service providers that provide investment administration, registry, custody, hosting, data storage or other services;
(c) any entity with which Tanarra jointly or co-invests;
(d) any external party you authorise, such as a licensed or authorised financial adviser, dealer group or operator of an investor directed portfolio service;
(e) any party where Tanarra is required or authorised to do so by law; and
(f) Courts and tribunals as well as governmental or regulatory bodies and agencies, such as ASIC, the ATO, AUSTRAC or a law enforcement body or agency.
Tanarra uses third party investment administrators and registries to support the administration of Tanarra funds and other investments. Tanarra has contractual arrangements with these service providers to ensure they comply with privacy laws when dealing with your personal information.
Accessing and correcting personal information
If you require access to, or wish to update or correct your personal information, please contact Tanarra’s privacy officer:
If you believe that your personal information that Tanarra holds is inaccurate, incomplete or out-of-date, you should contact Tanarra’s privacy officer at the above details to correct the information. Tanarra will require you to verify your identity and to specify what information you wish to have access to.
Tanarra will endeavour to promptly update any personal information that is inaccurate, incomplete or out-of-date. If Tanarra does not agree that the personal information is inaccurate, incomplete or out-of-date, Tanarra will notify you in writing of the reasons to refuse any correction or update. Tanarra will also notify you of what you can do if you are not satisfied with Tanarra’s response.
Protecting personal information
Tanarra will take reasonable steps to protect your personal information that we hold from misuse, loss, unauthorised access, interference, unauthorised modification or unauthorised disclosure.
Tanarra has physical, electronic and procedural safeguards to protect such personal information, for example by use of physical security and restricted access to electronic records. Access to information stored electronically is restricted to Tanarra employees whose job purpose requires access. Tanarra also requires all employees to maintain the confidentiality of client information except as otherwise required by law.
Eligible data breach
Tanarra’s service providers are required to notify Tanarra of any unauthorised access to, or disclosure or loss of, personal information.
In such a circumstance, Tanarra performs an assessment to determine if there has been an ‘eligible data breach’ whereby the access or disclosure of the personal information is likely to result in serious harm to the individuals to whom the information relates. If Tanarra determines there has been an ‘eligible data breach’, then the individuals affected will be notified as soon as practicable of the details of the breach and the recommended steps to take in response to it. If required, Tanarra will also inform the Office of the Australian Information Commissioner at the same time.
Privacy related complaints
If you have any questions about privacy-related issues or wish to complain about a breach of your privacy or the handling of your personal information by Tanarra, please contact Tanarra’s privacy officer (details above).
Tanarra may ask you to lodge your complaint in writing
Any complaint will be investigated by the privacy officer and you will be notified of the making of a decision about your complaint as soon as is practicable after it has been made, usually 30 days.
If Tanarra is unable to resolve your complaint satisfactorily or your concerns about Tanarra’s handling of your personal information, you can contact the Office of the Australian Information Commissioner: GPO Box 5218 Sydney NSW 2001 Email: firstname.lastname@example.org Tel: 1300 363 992 www.oaic.gov.au
Updates to this policy
Tanarra will review this policy from time to time to take account of new laws and technology, changes to Tanarra’s operations and practices, and the changing business environment.
The most current version of this policy is located at tanarra.com.au and can also be obtained by contacting Tanarra’s privacy officer at the above address.