Privacy Policy

November 2022

Jameson TTB understands the importance of keeping any personal information we may receive about you secure and confidential.
This privacy policy sets out how Jameson TTB collects, uses, manages, and discloses personal information and how Jameson TTB aims to protect the privacy of your personal information.

Jameson TTB may update this policy from time to time.

What is personal information and why do we collect it?

The Privacy Act 1988 (Cth) (‘Privacy Act’) and the relevant privacy principles under the Privacy Act regulate how private sector organisations can collect, store, manage, use, disclose and provide access to personal information.

For the purposes of the Privacy Act, personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Jameson TTB collects personal information primarily for (but not limited to) the purpose of providing our funds management services and conducting our funds management business. This may involve collecting personal information from you to for:

  • process an investment application from you and establish your investments in our funds or other financial products
  • manage our relationships with you and administer any investment you have with us, including communicating with you about the investment
  • monitor and evaluate our investment products or other products or services
  • provide you with access to our website and other online services
  • respond to queries you submit to us
  • provide you with information about our funds, investments, products or services that may be of interest to you
  • accounting, billing and other internal administrative purposes
  • complying with our legal requirements under any applicable laws. These laws may include: the AML/CTF Act, the Financial Sector (Collection of Data) Act (Cth), the Corporations Act (Cth), the Taxation Administration Act (Cth), the Income Tax Assessment Act (Cth) and other taxation laws and other regulatory legislation
  • to the extent required or permitted by any applicable law, rule or regulation which mandates reporting and/or retention of information or to the extent required by any order or directive regarding reporting and/or retention of information issued by any authority or body or agency in accordance with which Jameson TTB is required or accustomed to act. You are not required to provide your personal information to us. However if you do not provide the information requested of you in the Investment Application Form(s), we may not be able to process your Investment Application, or administer your holding of Units.

Sensitive information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

  • For the primary purpose for which it was obtained
  • For a secondary purpose that is directly related to the primary purpose
  • With your consent; or where required or authorised by law.

How we collect Personal Information

Jameson TTB collects personal information regarding investors (or prospective investors), such as a person’s name, date of birth, address, telephone number, email address, driver’s licence details, passport details, tax file number, bank account details, investment information and employment information, only by lawful and fair means.

Generally, Jameson TTB will collect this personal information directly from you, for example by requesting that you provide the information when you fill out an application form or submit an online form to us. Please note your telephone calls and conversations with a Jameson TTB representative may be recorded and monitored for quality, training and verification purposes. We will take any steps as reasonable in the circumstances to notify you when we are collecting personal information about you, and about other matters relating to the collection of your personal information as set out in Australian Privacy Principle 5.2.

There may be other occasions when we collect personal information about you or from other sources, such as from a publicly maintained record or from an information services provider, for example where we are required to verify your identity under anti money laundering legislation. However, we will only do so if you have given consent, we are required by law, or it is unreasonable or impracticable to collect personal information only from you.

If Jameson TTB receives personal information which we did not solicit, we will, within a reasonable period after receiving the information, determine whether or not we could have collected the information under Australian Privacy Principle 3 had we actually solicited the information. If Jameson TTB determines that we could not have collected the personal information and the information is not contained in a Commonwealth record, then the unsolicited personal information will lawfully and reasonably destroy that information.

When and how we use or disclose personal information

From time to time, we may need to use or disclose personal information regarding you to a third party. However, we will only use or disclose personal information in accordance with the primary purpose for which that information was collected and held and therefore not for a secondary purpose, unless:

a. you consent to the use or disclosure; or
b. you would reasonably expect Jameson TTB to use or disclose the information for the secondary purpose and the secondary purpose is:
i. directly related to the primary purpose (if the information is sensitive information); or
ii. related to the primary purpose (if the information is not sensitive information);
c. use or disclosure is required or authorised by Australian law or a Court/Tribunal; or
d. a permitted general situation exists in relation to the use or disclosure; or
e. Jameson TTB reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

Where Jameson TTB uses or discloses personal information in accordance with section 6e., we will keep a copy of this disclosure (e.g.: the email or letter used to do so).

We note that this section does not apply to personal information for the purposes of direct marketing or government related identifiers.
The types of third parties to which we may disclose personal information include:

  • the Escrow Agent, your financial advisers or other professional advisers or other persons you have authorised to act on your behalf
  • service providers we engage to provide custody, administration, technology, auditing, mailing, printing or other services
  • regulatory or Government authorities (where required to or authorised by law)
  • our professional advisers (including legal and accounting firms, auditors, consultants and other advisers)
  • our related companies (e.g. entities of Jameson TTB), their related parties, agents and contractors

Any such disclosures will be made on a confidential basis and, where possible, will require the third party to comply with appropriate privacy obligations.

Some of the recipients to whom Jameson TTB disclose your personal information may be based overseas. It is not practicable to list every country in which such recipients are located but it is likely that such countries may include the People’s Republic of China (including Hong Kong) and Singapore. Such overseas recipients may not be bound by the Privacy Act. You acknowledge that by consenting to Jameson TTB disclosing your personal information to overseas recipients, Australian Privacy Principle 8.1 will not apply to the disclosure. This means that Jameson TTB will not be required to take reasonable steps in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation that personal information and as a result Jameson TTB may not be liable under the Privacy Act if the recipient does not act consistently with the Australian Privacy Principles.

Jameson TTB will not use or disclose your personal information, whether sensitive or not, for the purpose of direct marketing unless you have given us consent.

Jameson TTB may use or disclose personal information (other than sensitive information) about an individual for the purposes of direct marketing if:

a. Jameson TTB collected the information from the individual; and the individual would reasonably expect Jameson TTB to use or disclose the information for that purpose; or
b. Jameson TTB has collected the information from a third party; and either:
i. Jameson TTB has obtained the individual’s consent to the use or disclose the information for the purpose of direct marketing; or
ii. it is impracticable for Jameson TTB to obtain the individual’s consent; and
c. Jameson TTB provides a simple way for the individual to opt out of receiving direct marketing communications from Jameson TTB;
d. each direct marketing communication with the individual Jameson TTB:
i. includes a prominent statement that the individual may make such a request; or
ii. directs the individual’s attention to the fact that the individual may make such a request; and
e. the individual has not made a request to opt out of receiving direct marketing
How we keep your information secure
Jameson TTB takes all reasonable steps to protect the personal information we hold about you from misuse and loss and from unauthorised access, modification or disclosure.
Jameson TTB has in place a number of data security, information security and other similar security policies and procedures. These policies and procedures are regularly reviewed to ensure they remain current and appropriate.

How to access your personal information

Under the Privacy Act, you have a right to access your personal information that is collected and held by Jameson TTB. If you would like to access or change the personal information Jameson TTB holds about you, you can contact Jameson TTB and request the relevant change or access.

To action any change or access request, we will need to verify your identity and comply with our other procedures which are in place to prevent unauthorised access to personal information. We will take all reasonable steps to provide access to your personal information within 30 days from your request. If you have concerns about the completeness or accuracy of the information we have about you, we will take steps to address them.

Jameson TTB will not normally charge you any fees or costs for access to your personal information. Fees or costs may apply if providing you with access would require us to incur retrieval or other out of pocket costs. We will notify you if any such fees or costs would be payable.

If we refuse you access, we will provide you reasons for refusal and outline the mechanisms available to complain about the refusal and any other matter prescribed by the regulations.

How we maintain the quality of your personal information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

How do you opt out

If we have your personal information, we may keep you informed about other products, services and offers which may be on interest to you. We may do this by phone, mail, email, SMS or other electronic messages (without an unsubscribe facility). If you do not wish to receive these communications please notify us in writing or by phone. If you have not told us that you do not wish to receive these communications by phone, you may be contacted even if you have registered your phone number on the national Do Not Call Register.

What if you have a privacy complaint

If you believe that Jameson TTB has contravened the Privacy Act or have any other privacy complaint regarding Jameson TTB, you can make a complaint by contacting our Privacy Compliance Manager (the contact details for our Privacy Compliance Manager are below).

Jameson TTB will seek to resolve any privacy complaints and will deal with privacy complaints as quickly as possible and in a respectful and confidential manner.
Jameson TTB will investigate any privacy complaint you make and will inform you of the outcome of your complaint following the completion of the investigation.
In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.

How to contact us

Under the Privacy Act, you may request access to your personal information that we hold. You can contact us to make such a request or for any other reason relating to the privacy of your personal information or email the Privacy Officer at: or by telephoning +61 3 9614 7600.