Talisman Advisory Pty Ltd Group Privacy Notice
Talisman Advisory Pty Ltd respects your privacy and is committed to protecting your personal data. This privacy notice describes how Talisman Advisory Pty Ltd processes the personal data you provide to us or that we collect during the course of our business activities, including from our websites (regardless of which ones and where you visit them from).
Important information and who we are
This privacy notice is issued on behalf of Talisman Advisory Pty Ltd and other companies within the Talisman Advisory Pty Ltd. Accordingly, references to “Talisman Advisory Pty Ltd”, “we”, “us” or “our” in this privacy notice are to the relevant company in the Talisman Advisory Pty Ltd responsible for processing your personal data and include the following Talisman Advisory Pty Ltd subsidiaries.
The identity of the data controller for data protection purposes will vary depending upon which Talisman Advisory Pty Ltd entity or subsidiary you contract with.
Talisman Advisory Pty Ltd operates in jurisdictions that are outside the European Union, some of which have not been deemed adequate by the European Commission. Where we share your data with Talisman Advisory Pty Ltd subsidiaries we do so on terms whereby such data is to be kept secure and confidential.
Talisman Advisory Pty Ltd’s Director may be contacted in relation to questions arising in relation to this privacy notice or if you have any questions in relation to exercising your legal rights.
The Director may be contacted at: corporate (at) talismanadvisory (dot) com.
We would, appreciate the chance to deal with your concerns before you approach any information commissioner authority so please contact us in the first instance.
The data we collect about you
Personal data, means any information about an individual from which that person can be identified it includes information that you provide to us or which we gather in the course of operating our business.
Talisman Advisory Pty Ltd may collect, use, store and transfer various types of personal data about you including:
Identity data (which may include your title, name and passport/driving licence/national identification card information, politically exposed person (PEP) status and personal data available in the public domain);
Contact data (which may include postal address, email address and telephone numbers);
Professional/employment data (which may include educational background, professional qualifications, employment, details of directorship and other offices which you may hold);
Financial data (which may include sources of wealth, details of your assets, shareholdings and beneficial interest in assets, bank account details, credit history);
Family relationships data (which may include your marital status, the identity of your spouse/partner and any children you may have);
Third party relationships data (which may include your employer, advisors, service providers (including bankers and investment advisers) and entities with which you are associated);
Technical data (which may include your internet protocol (IP) address, how you use our website, browser type and version, time zone setting and location, and other technology available from the devices you use to access our websites);
Marketing and communications data (which may include your preferences in receiving marketing from us and our third party providers and your communication preferences).
We may also collect and process “Special Categories of Personal Data” about you where we are required to for the purposes of our legal and/or regulatory obligations including, but not limited to, legislation and regulatory obligations relating to anti-money laundering and combating the financing of terrorism and other related legislation. This may include information about your race or ethnicity, religious or philosophical beliefs, political opinions and information relating to criminal convictions). We may also collect Special Categories of Personal Data comprising information about your health to enable us to meet our contractual obligations.
If you fail to provide personal data
Where Talisman Advisory Pty Ltd is required to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or propose to enter into with you. In this case, we may have to withdraw the service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from you and about you including but not limited to:
Direct Interactions. You may give us your personal data by filling in forms or by corresponding with us by post, telephone, email or otherwise. This includes personal data you provide when you:
apply for our services;
subscribe to our services or publications;
request material to be sent to you.
Third Parties or Publicly Available Sources. We may receive personal data about you from various third parties and public sources including but not limited to:
personal data gathered through client due diligence undertaken to meet regulatory requirements (including through credit reference agents);
personal data from publicly available sources such as companies registries;
personal data received in the course of dealing with advisors, lawyers, regulators, official authorities and service providers;
our clients in connection with the services we are providing (for example a settlor may provide personal data on beneficiaries);
other financial services providers (including from other trust and companies administration service providers);
personal data on potential candidates may be obtained from recruitment agencies, past or current employers, educational institutions and/or professional bodies;
analytics providers such as Google based outside the EU.
Information that we collect through our websites
Talisman Advisory Pty Ltd may collect information from you through your use of our websites, when you request information from us or otherwise in the course of our business. Talisman Advisory Pty Ltd has three websites:
You are not required to provide any personal data in order to access our websites.
You may voluntarily choose to provide personal data by signing up for news letters or other publications.
Our websites collect the domain names, IP addresses, user statistics, analytics and browsing history of all visitors. Talisman Advisory Pty Ltd uses this data to promote our services.
Purposes for which Talisman Advisory Pty Ltd uses your personal data
Talisman Advisory Pty Ltd provides corporate, private client and fund administration services to our clients and we use your personal data for those purposes. Talisman Advisory Pty Ltd will use your personal data to:
perform a contract that we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
comply with a legal or regulatory obligation (to include the prevention and detection of fraud, money laundering and other crimes);
respond to requests, enquiries or complaints received from you or someone connected to you;
establish, exercise or defend legal proceedings and/or Talisman Advisory Pty Ltd’s legal rights;
conduct administrative or operational processes within Talisman Advisory Pty Ltd;
compile statistics in relation to the use of our websites;
send you marketing material;
for other legitimate business purposes;
enable us to display relevant targeted advertisements to you about products and services that may be of interest;
review and process any application you make in relation to recruitment.
Talisman Advisory Pty Ltd does not generally rely on consent as a legal basis for processing your
personal data other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above purposes, where this is required or permitted by law.
Sharing personal data
Talisman Advisory Pty Ltd may share your personal data with the parties set out below for the purposes listed above.
Internal. Other companies in the Talisman Advisory Pty Ltd Group.
External. The following third parties:
Service providers acting as processors who provide IT and system administration services;
Professional advisers acting as processors or joint controllers including lawyers, bankers, investment advisers, auditors, brokers, insurers and accountants who provide, legal, banking, advisory, audit, insurance and accounting services;
Tax authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing or information for tax, regulatory or legal compliance.
Fraud prevention agencies acting as joint controllers.
Courts or other competent judicial or governmental body to comply with legal obligations such as combating money laundering and terrorist financing where such parties would be acting as joint controllers.
Organisations and individuals if you have applied for a role with Talisman Advisory Pty Ltd, in order for us to obtain references and confirmation of details.
Talisman Advisory Pty Ltd will provide you with choices regarding certain use of your personal data, particularly around marketing and advertising. Talisman Advisory Pty Ltd may contact you by email or other means to inform you about news, market updates, services or events which we think may be of interest to you.
You have the right to ask Talisman Advisory Pty Ltd to stop sending you marketing messages at any time by adjusting your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Data retention: how long will you use my personal data for?
Talisman Advisory Pty Ltd will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data we process, you have the right to:
request access your personal data;
request correction of your personal data;
request restriction of the use of your personal data;
request your personal data is erased; and
object to processing of your personal data.
Where we have relied on consent or our legitimate interests to process your personal data, you have the right to withdraw consent at any time. If you choose to do so, we may not be able to provide our services to you.
If you wish to exercise any of the rights set out above please contact the Director.
Changes to the privacy notice and your duty to inform us of changes
We may make changes to this privacy notice from time to time without notice, in which case the date of the notice will be up dated.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.