Central to the success of Channel Investment Management Limited (‘CIML’) is our commitment to our clients. 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.
Whenever it is reasonable and practical to do so, we collect information about you directly from you. In some cases, we collect personal information from third parties including public sources, our related companies, referrers, brokers, agents, your adviser(s) and our service providers.
We collect personal information about you which is reasonably necessary to:
We generally hold personal information relating to:
We do not generally collect sensitive information about you unless required by applicable laws or rules.
Sensitive information includes information relating to:
We may collect health information if assessing certain claims including hardship. 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.
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. For example, we may use and disclose personal information to process applications, administer and manage our products and services including monitoring, auditing, and evaluating those products and services, model and test data, communicate with you and deal with any complaints or enquiries. We may also use and disclose your personal information (on a confidential basis) in connection with acquisitions, mergers or changes in control of our business or assets.
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 to allow them to do this.
We may disclose personal information outside CIML:
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.
We take reasonable steps to ensure that all information we hold is as accurate as 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.
We use security procedures and technology to protect the information we hold. Access to and use of personal information within CIML 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, CIML 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, CIML will notify affected individuals and the Office of the Australian Information Commissioner as soon as practicable. The notification will include CIML's 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, CIML will undertake a review process to help prevent future breaches.
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.
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.
When you visit the Company’s website you will browse anonymously unless you have accessed the website from a personalised communication from CIML.
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 the CIML 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).
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 CIML site to:
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).
Before you contact AFCA or the Office of the Australian Information Commissioner, we recommend that you first try to resolve your concern with us.
Policy updated December 2019.
Personal information may be disclosed to third parties in jurisdictions including: Canada, Luxembourg, Singapore, Hong Kong, Malaysia, United Kingdom and the United States of America.
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