In the course of providing our products and services, Sentient Equity Partners may collect personal information from clients, or potential clients.
In the course of providing products and services we may collect:
How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.
Where possible, Sentient Equity Partners have attempted to standardise the collection of personal information by using specifically designed forms. However, given the nature of our operations, we often also receive personal information by email, letters, notes, over the telephone, in face-to-face meetings and through financial transactions.
We may also collect personal information from other people (e.g. a third party administrator) or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly.
Sometimes, we may be provided with your personal information without having sought it through our normal means of collection. We refer to this as “unsolicited information”. Where we collect unsolicited information, we will only hold, use and/or disclose that information if we could otherwise do so had we collected it by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the information as appropriate.
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our uses of personal information include but are not limited to:
We may also need to collect personal information in order to comply with our legal obligations, such as Anti-Money Laundering and Counter-Terrorism Laws.
It may be necessary for Sentient Equity Partners to disclose your personal information to certain third parties in order to assist us with one or more of our functions or activities. This may include organisations providing fund administration or custodial services under an arrangement with us.
We only collect sensitive information reasonably necessary for one or more of these functions or activities if we have the consent of the individuals to whom the sensitive information relates, or if the collection is necessary to lessen or prevent a serious threat to life, health or safety or another permitted general situation.
We store personal information in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers.
The security of your personal information is of paramount importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure.
These steps include:
Personal information we hold that is no longer needed, or required to be retained by any other laws, is destroyed in secure manner, deleted or de-identified as appropriate.
Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies.
A data breach is when personal information held by an entity is lost or subject to unauthorised access, modification, disclosure, or other misuse of interference.
If Sentient Equity Partners suspects there is a data breach we will assess the situation to see if there has been an event involving personal information that is likely to result in serious harm to the information’s owner. Eligible data breaches will be reported to the effected party, and any relevant authorities.
Sentient Equity Partners will also assist the effected individuals with recommendations on what steps they should take in response to the breach. The remedial recommendations will be made on a case by case basis.
We only use personal information for the purposes for which it was given to us, or for purposes which are directly related to one or more of our functions or activities. We may disclose your personal information to government agencies, and other recipients from time to time, only if one or more of the following apply:
We may disclose personal information about an individual to organisations that help us provide our services, in certain circumstances, such as when storing information with a “cloud service provider”. Personal data may be transferred to or accessed from countries whose laws provide a level of protection for personal data not always equivalent to the level of protection that may be provided in your own country. We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:
We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date. These steps include ensuring that the personal information is accurate, complete and up-to-date at the time of collection and when using or disclosing the personal information.
On an ongoing basis we maintain and update personal information when we are advised by individuals or when we become aware through other means that their personal information has changed
Please contact us if any of the details you have provided change. You should also contact us if you believe that the information we have about you is not accurate, complete or up-to-date.
You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us.
If we do not agree to provide you with access or to amend your personal information as requested you will be notified accordingly. Where appropriate, we will provide you with the reason/s for our decision. If the rejection relates to a request to change your personal information, you may make a statement about the requested change and we will attach this to your record.
If you wish to make a complaint about a suspected privacy breach by us, you may do so by providing your written complaint by email, letter, facsimile or by personal delivery to any one of our contact details as noted below.
You may also make a complaint verbally.
We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we may seek further information from you in order to provide a full and complete response.
Your complaint may also be taken to your local supervisory authority. If you are unclear who the appropriate supervisory authority is for you, please contact us.
If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.