IVCM Privacy Policy

The IVCM Privacy Policy is a legal agreement that explains what kind of personal information we gather from our website visitors, how we use this information, and how we keep it safe. This applies to all Jurisdictions in which our products operate.

Information published on this website has been prepared for general information purposes only and not as specific advice to any particular person. Any advice contained on this website is General Advice and does not take into account any person’s particular investment objectives, financial situation and particular needs.

Before making an investment decision based on this advice you should consider, with or without the assistance of a qualified adviser, whether it is appropriate to your particular investment needs, objectives and financial circumstances.

Product Disclosure Statements contain information necessary for you to make a decision whether or not to invest in financial products mentioned on this website. You should also obtain and read this document prior to proceeding with an investment decision.

Although every effort has been made to verify the accuracy of the information contained on this website, IVCM [Aust] Pty Ltd and Tidswell Financial Services Ltd, its officers, representatives, employees and agents disclaim all liability [except for any liability which by law cannot be excluded], for any error, inaccuracy in, or omission from the information contained in this document or any loss or damage suffered by any person directly or indirectly through relying on this information.

Australian Expatriate Superannuation Fund [AESF] ABN 34 300 938 877, IVCM [Aust] Pty Ltd ABN 16 608 923 477 and Tidswell Financial Services Ltd ABN 55 010 810 607 are committed to protecting the privacy and ensuring the security of personal information. The protection of your personal information is a vital part of this relationship. It is supported by our dedication to keeping personal information confidential.

Personal information is information or opinion that allows others to identify you. It includes your name, age, gender, contact details, as well as your health and financial information.

We will act to protect your personal information in accordance with the Australian Privacy Principles. We only collect the personal information we reasonably require, in the course of our business of providing services, in accordance with this Privacy Policy by lawful, fair and non-intrusive means. We co-operate with police and other enforcement bodies as required or allowed by law.

We collect personal information to provide you with the products and services you request as well as information on other products and services offered by or through us. The law also requires us to collect and retain personal information. Personal information may be used and disclosed within the group to administer our products and services, as well as for risk management purposes and, unless you tell us otherwise, to provide you with related marketing information.

We will only collect and hold information that is required by us to deliver our services to you and we will do this in a fair and lawful manner.

The pages that follow set out more detailed information about our privacy and information handling practices. If you have any questions or would like further information on our Privacy Policy or information handling practices, please contact our Professional Standards team by:

Phone. +61 2 7202 0151
Email. enquiries@ivcm.com

Personal information is information or opinion that allows others to identify you. It includes your name, age, gender and contact details. The kinds of personal information we collect and store will depend on what products and services you request from us. However, our ability to provide you with service and advice that meets your particular needs and objectives may entail us collecting information which may include any or all of the following:

a.  Your contact details including names, address, phone and email address;
b.  details of your financial needs and objectives and what hardship means to you;
c.  personal details including your date of birth, associated entities, visa and residency status, private healthcare and smoking status;
d.  your occupation, marital status, financial dependants and identification details such as copies of birth certificate or drivers licenses or other documentation;
e.  details of your investment preferences, past experience and aversion or tolerance to risk;
f.  details of any professional advisers you engage with;
g.  your tax file number;
h.  your agreement to grant access to a spouse or partner’s information.

  1. We will collect, maintain and use personal information both initially and ongoing which is necessary for us to adequately provide the services you have requested including:
    a.  preparation and provision of general financial advice;
    b.  preparation and provision of ongoing general financial advice;
    c.  placement of financial products including purchase, variation or redemption of investments within AESF;
    d.  provision of a financial service, such as actioning share buy/sell instructions within AESF;
    e.  provision of a financial service, such as purchase, variation or cancellation of insurance products within AESF;

As well as providing us with information upon which to provide general advice to your particular needs and objectives, we are required under the Corporations Act 2001 to hold this information.

It is possible that additional information may be collected to allow assessment by insurance providers so they may accept your proposal and, if so, determine terms. This information is only collected where necessary and may include details of your sexual activities and/or personal pursuits.

In addition, we use your information to administer our client relationships.

We will not collect personal information about you except when you have knowingly provided that information to us or have authorised a third party to provide that information to us via their privacy controls. In most cases collection of your personal information will be via application forms, over the telephone, email. From time to time, other service providers may provide us with your information for the purpose of our providing a service to you [referral]. In this case we will contact you to determine if we can be of any assistance.

We may seek your express permission to collect information from other entities such as product providers, accountants, solicitors, etc. where this information may not be currently available to you. If we were to obtain information that is not information that could have been provided or authorised for collection by you, we will de-identify and destroy this information unless it is unlawful to do so.

Identification documentation is required for collection by law under the Anti-Money Laundering and Counter Terrorism Financing Act 2006. In some instances, we are required to verify this documentation against other records. For instance, identification for Australian companies, trusts or registered co-operatives may need to be verified by a search of records held by regulatory bodies such as Australian Securities and Investments Commission, Australian Taxation Office etc.

We will not use or disclose personal information collected by us for any purpose other than:

  1. the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
  2. where you have consented to such disclosure; or
  3. where the Australian Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

We are obliged to maintain records which include personal information and make those records available for inspection by the Australian Securities and Investments Commission or other regulators under a relevant law. If we provide information for the purpose of law enforcement activities we will make a record of that provision.

If you chose not to provide your information

The effectiveness of our services is specifically dependent on information you provide and it being relevant, complete, accurate and up-to-date. Without this, our services may not meet your needs or may cause you to suffer unforeseen financial consequences.

If you elect not to provide us with your personal information as and when requested, we may not be able to provide you with general advice.

We may use personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you, however if you do not wish to receive such information you can request not to receive it. Simply contact us by any of the methods detailed below. There is no cost for this request but please allow 2 weeks for your request to be actioned.

In order to ensure that you receive a personally tailored service, your personal information will be made available to Tidswell Financial Services Ltd authorised representatives and staff for the purposes of assisting you as necessary.

It is a condition of our agreements with each of our authorised representatives [both personal and corporate] that they adopt and adhere to this Privacy Policy. You can be assured that all authorised representatives and their staff will maintain your information in accordance with this policy. If you have any concerns in this regard, you should contact us by any of the methods detailed below.

In order to provide our service, we may disclose your personal information to external parties as follows:

  1. other entities who refer your business to us;
  2. affiliated product and service providers as well as external service providers such as superannuation fund trustees, insurance providers, and product issuers for whom we act as agent [so that they may provide you with the product or service that you seek or in which you have an express interest];
  3. auditors we appoint to ensure the integrity of our operations;
  4. suppliers from whom we order goods and services on your behalf [so that those goods and services can be provided to you];
  5. other persons acting on your behalf including your accountant, solicitor, executor, administrator, trustee, guardian or attorney;
  6. if required or authorised to do so, regulatory bodies and government agencies;
  7. medical assessment services where you have sought insurance for the purposes of underwriting your policy;
  8. other organisations who in conjunction with us provide their products and services [so that they may provide their products and services to you]; and
  9. other Australian Financial Services Licensees or Authorised Representatives or their agents for the purpose of due diligence on one of our associated entities were they to decide to sell all or part of their business. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer and your information will not be exchanged if you object to the transfer.

If we have used an example to describe when we might exchange personal information, the exchange of personal information may not be limited to those examples or examples of a similar kind.

We disclose personal information when we outsource certain functions, including telemarketing, bulk mailing, market research, direct marketing, and information technology support. We also seek expert help from time to time to help us improve our systems, products and services.

In all circumstances where personal information may become known to our contractors, agents, Australian Financial Services Licensees, Authorised Representatives or their agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents, other Australian Financial Services Licensees, Authorised Representatives or their agents and outsourced service providers are not able to use or disclose personal information for any purposes other than our own.

Tidswell Financial Services Ltd, IVCM [Aust] Pty Ltd and AESF takes its obligations to protect client information very seriously and we make every effort to deal only with parties who share and demonstrate the same attitude.

We may require to send personal information overseas to fulfil your investment request, you should be aware of the following:

  • your personal information may be accessed by our Tidswell Financial Services Ltd, IVCM [Aust] Pty Ltd and AESF, representatives or agents in other countries, if that becomes necessary to deliver our services to you. This access is via secure internet connection or, in some instances by email;
  • from time to time, information may be loaded to the cloud for storage or access through programs such as drop box etc; and
  • it is possible that suppliers we deal with may outsource functions using overseas contractors or companies that process these services using offshore resources. Where this is a concern to you, we suggest that you carefully read their privacy policy to determine the extent to which they send information overseas. These service providers have committed to adhering to the Australia Privacy Principles.

We allow access to relevant personal information for external organisations that help us provide services. These organisations are bound by confidentiality arrangements. From time to time we may use service providers whose staff accesses our data outside of Australia to provide services. Where this is the case, these service providers have committed to adhere to the Australia Privacy Principles. These service providers may be located in a number of countries however, we are not aware of any at this stage. We will update if and when if this situation changes.

When you visit our website, details may be recorded about your visit, such as time and date, your computer IP address, pages accessed, time spent on page and type of browser. This information is used in an anonymous format for statistical purposes and as such cannot identify you individually. When you log into the client section of our site, we may use cookies to identify who you are, while you are logged in for the session. The cookie is unique to that session, and the data within the cookie is encrypted. You must have cookies enabled to be able to use our site. Our website may contain links to other websites. When visiting these websites be sure to check the privacy policy as we are not responsible for privacy practices of those other parties.

Where you chose to communicate with us by email, we will store your email, name and address with any other contact or personal details you have provided on our database.

When you browse the IVCM website, our internet service provider and website program logs the following information for statistical purposes:

  • your server [IP] address;
  • top level domain name [e.g. .com, .gov, .au, etc.];
  • the date and time of your web-site visit;
  • country your server [IP] is located in;
  • the pages you looked at;
  • the type of browser you used;
  • the previous site you visited; and
  • the site you visited next.

We will not use information obtained from your browsing activities to send you any unsolicited information. This information is collected in order to determine the relevancy of material posted on the AESF website and to enhance this service to visitors.

We will only record your e-mail address if you send us a message [including an email].  We will not add it to a mailing list if you ask us not to. Simply send an email to enquiries@ivcm.com and ask for your details to be removed from the mailing list.

The IVCM website contains links to other sites. IVCM is not responsible for the privacy practices or the content of such websites. We encourage the reading of the privacy statements in these linked sites, as their privacy policies may differ from ours.

We will not adopt as our own any identifiers that you may provide to us such as TFNs, Centrelink, Medicare numbers etc. If you have provided us signed consent, we may hold your identifiers on file so that we can provide ongoing services to you. If you chose not to provide this consent we will not hold this information on file.

Our goal is to ensure that the personal information we hold about you is accurate, complete and up-to-date. Please contact us if you believe that the information we have about you is not complete, accurate and up-to-date. We may take steps to update information, for example, an account balance from your account service provider where you have provided us with access rights or an address or contact number from publically available information such as telephone directories or websites.

If you ask, we will tell you what personal information we hold about you within your client file, and what we do with it. On receipt of your request we will facilitate access to you by allowing an inspection of your client file in person, or by providing copies or an accurate summary of relevant documents, depending on what we believe is most appropriate in the circumstances. You can ask us to update or change information on your file at any time. Prior to providing this access we will require you to provide evidence of your identity. We may ask you to put your request in writing and any charge we make for providing access will be reasonable.

If for whatever reason we refuse to change information we hold on your file, we will arrange for a statement from you to be associated with the relevant information so that it can be included in any future use or disclose of that information should you wish to do so.

When we make reference to your client file we mean the following documents: Data collection forms; Written communications [such as letters and emails] Transaction letters; Investment, Superannuation and Personal Insurance applications or statements produced by the issuers of financial products;

We will not provide you with access to your personal information if:

  • providing access would pose a serious threat to the life or health of a person or the health and safety of the public;
  • providing access would have an unreasonable impact on the privacy of others;
  • the request for access is frivolous or vexatious;
  • the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
  • providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
  • providing access would be unlawful;
  • denying access is required or authorised by or under law;
  • Tidswell Financial Services Ltd, IVCM [Aust] Pty Ltd and AESF has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to its functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
  • providing access is likely to prejudice actions being conducted by an enforcement agency; or
  • providing access would reveal evaluative information generated within Tidswell Financial Services Ltd, IVCM [Aust] Pty Ltd and AESF in conjunction with a commercially sensitive decision making process.

In the event we refuse you access to your personal information, we will provide you with a written explanation for that refusal. We will endeavour to respond to any request for access within 14-30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.

Your personal information is generally held in your client file and on our computer database. We will at all times seek to ensure that your personal information is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential.

Our security measures include, but are not limited to:

  • educating our authorised representatives and staff as to their obligations with regard to your personal information;
  • all hard copy files are stored in lockable cabinets/rooms;
  • access to our premises is controlled by only allowing authorised personnel to access those locations where personal information is stored;
  • all computer-based information is protected through the use of access passwords on each computer and screen saver passwords;
  • client data is backed up each evening and stored securely off site;
  • encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;
  • employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
  • using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing; and
  • providing secure storage for physical records.

In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in our secure storage facility for a period of 7 years in order to comply with legislative requirements. Where information we hold is identified as no longer needed for any purpose we ensure it is effectively and securely destroyed, for example, by shredding in the case of paper records and other means in the case of electronic records and equipment.

From time to time it may be necessary for us to review and amend this policy.  We reserve the right to amend this policy at any time.  You should check our website from time to time for our latest privacy policy.

If you seek any further information from Tidswell Financial Services Ltd, IVCM [Aust] Pty Ltd and AESF about this Statement or our privacy policy generally please contact our Privacy Officer using the details below:

Phone. +61 2 7202 0151
Email.   enquiries@ivcm.com

This website is provided by IVCM [Aust] Pty Ltd on an ‘as is’ basis. IVCM [Aust] Pty Ltd makes no representations or warranties of any kind, express or implied, as to the operation of the website or the information, content, materials, or products included on this website.

Tidswell Financial Services Ltd [ABN 55 010 810 607] Australian Financial Services License [AFSL] No 237628, is the issuer and registrable Superannuation Entity [RSE] L0000888 and Trustee of the Australian Expatriate Superannuation Fund [ABN 34 300 938 877] [Registration No. R1004953].

The Promoter of the Australian Expatriate Superannuation Fund is IVCM [Aust] Pty Ltd [ABN 16 608 923 477] Australian Financial Services License [AFSL] No 491530.

Please refer to the Product Disclosure Statement for further details.

To the full extent permissible by applicable law, IVCM [Aust] Pty Ltd disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. IVCM [Aust] Pty Ltd will not be liable for any damages of any kind arising from the use of this website, including, but not limited to direct, indirect, incidental, punitive, and consequential damages.

Applicable Law This website is created and controlled by IVCM [Aust] Pty Ltd in South Australia, Australia. As such, the laws of the state of South Australia and Australia will govern these disclaimers, and terms and conditions, without giving effect to any principles of conflicts of laws. We reserve the right to make changes to our website and these disclaimers, and terms and conditions at any time.

Risk and Liability You accept all risks and responsibility for losses, damages, costs and other consequences resulting directly or indirectly from using this website and any information or material available from or through it.

To the maximum permitted by law, IVCM [Aust] Pty Ltd and its affiliates excludes all liability to any person arising directly or indirectly from using this website and any information or material available from or through it.

IVCM [Aust] Pty Ltd limits any liability that cannot be excluded to restoring the service, re-supplying the material or refunding any amount paid to IVCM [Aust] Pty Ltd for the service or material. Any products or services provided by IVCM [Aust] Pty Ltd may be modified over time.

None of the information and data contained in this website [ aesf.com.au ] nor any opinion expressed, constitutes a recommendation to purchase or sell a security, or to provide investment advice. Past performance of financial products is no assurance of future performance. The payment of dividends and the return of capital are not guaranteed.

The information contained on all Australian Expatriate Superannuation Fund product is provided for general informational purposes, as a convenience to the customers of IVCM [Aust] Pty Ltd. The materials are not a substitute for obtaining professional advice from a qualified person, firm or corporation. Consult the appropriate professional advisor for more complete and current information.

IVCM [Aust] Pty Ltd is not engaged in rendering any legal or professional services by placing these general informational materials on this website.

IVCM [Aust] Pty Ltd makes no representations or warranties about the accuracy or completeness of the information contained on this website. Any links provided to other server websites are offered as a matter of convenience and in no way are meant to imply that IVMC [Aust] Pty Ltd endorses, sponsors, promotes or is affiliated with the owners of or participants in those websites, or endorses any information contained on those websites, unless expressly stated.

IVCM [Aust] Pty Ltd does not warrant or represent that the website is error free or free from viruses or defects. You must do all that is necessary [including using virus checking software] to satisfy yourself that accessing this website will not adversely affect your computer system[s].

IVCM [Aust] Pty Ltd is the copyright owner of all text and graphics contained on this website, except as otherwise indicated. Other parties` trademarks and service marks that may be referred to herein are the property of their respective owners. You may print a copy of the information contained herein for your personal use only, but you may not reproduce or distribute the text or graphics to others or substantially copy the information on your own server, or link to this website, without prior written permission of IVCM [Aust] Pty Ltd.

Permission to use and reproduce documents and related graphics available from this website is granted, provided that:

  1. the below copyright notice appears in all copies and that both the copyright and this permission notice appear;
  2. use and reproduction of documents and related graphics available from this website is limited to personal, non-commercial use;
  3. no documents or related graphics, including logos, available from this website are modified in any way; and
  4. no graphics, including logos, available from this website are used separate from accompanying text. Use or reproduction for any other purpose is expressly prohibited by law, and may result in civil and criminal penalties.

Violators will be prosecuted to the maximum extent possible.

If any part of this disclaimer is held to be invalid, unenforceable or illegal for any reason, the remaining parts of the disclaimer shall nevertheless continue in full force.

Complaints resolution

The Trustee has an established complaints handling process. If you have a complaint about your investment, please take the following steps:

Step 1

Contact your adviser and discuss your complaint with them. If your complaint is not satisfactorily resolved, put your complaint in writing and address it to:

Complaints Officer
Tidswell Financial Services Ltd
GPO Box 1900
ADELAIDE  SA  5001
Telephone: +61 8 8223 1676
Email: mail@tidswell.com.au

We will acknowledge receipt of your complaint within 7 days and determine what further action is required to resolve your complaint quickly and fairly.

Step 2

If the matter cannot be resolved by the Trustee to your satisfaction within 90 days, you can lodge an appeal to an external forum, known as the Superannuation Complaints Tribunal [SCT]. The SCT is an independent body, established by the Commonwealth Government to resolve disputes between superannuation funds and their members and/or potential beneficiaries if the internal complaints procedure of the superannuation fund has failed to resolve the complaint. Acting as a mediator, the SCT aims to resolve issues by mutual agreement. If a mutual agreement cannot be reached, the SCT may review the matter and making a binding decision.

The complaints that the SCT can deal with are limited. If you wish to find out whether the SCT can deal with your complaint and, if so, what information you will need to supply, you may contact them at:

Superannuation Complaints Tribunal
Locked Bag 3060
MELBOURNE VIC 3001
Phone: 1300 884 114
Email: info@sct.gov.au

Information published on this website has been prepared for general information purposes only and not as specific advice to any particular person. Any advice contained on this website is General Advice and does not take into account any person’s particular investment objectives, financial situation and particular needs.

Before making an investment decision based on this advice you should consider, with or without the assistance of a qualified adviser, whether it is appropriate to your particular investment needs, objectives and financial circumstances.

The IVCM (Gibraltar) Retirement Annuity Trust is a ‘Qualifying Recognised Overseas Pension Scheme’ under HMRC number QROPS 510207. The Trustees are IVCM Trustees (Gibraltar) Limited who are located at IVCM Trustees (Gibraltar) Ltd 215B Neptune House, Marina Bay, Gibraltar and are fully regulated and licensed by the Gibraltar Financial Services Commission.

This summary is of a general nature only and is not intended to be relied upon, nor to be a substitute for professional advice, or used in formulating any personal decisions without first seeking such advice. No liability is accepted for any consequences arising from any transaction in connection with this summary. The benefits in this summary may vary according to residence and domicile and different rules apply to different individuals. No warranty regarding the appropriateness of investing in this type of structure is being given and none of the above comments should be construed as tax advice. You should always take independent advice as personal circumstances may mean the comments above do not apply. We do not in any circumstances give advice directly to prospective or existing members, all business is accepted only through professional advisers and they and your other professional advisers should advise you if you have any questions relating to this plan. Advice should be sought from tax advisers as to the tax implications on payment of benefits in the individual’s country of residence.

In the unlikely event that you should wish to register a complaint in relation to your Plan, then such complaints should be made in writing to:
IVCM Pensions, 215B Neptune House, Marina Bay, Gibraltar

Ranfurly Strategic Limited or any of their authorised agents (each an “Authorised Person”) may collect and use the information set out in (or in connection with) the Application Form for the purpose for which it is provided. Each Authorised Person will hold the information securely and may use it in developing and running IVCM (NZ) PIE Superannuation Fund. You may ask any Authorised Person, in writing, to show you the personal information it holds about you to make corrections to it. The information set out in this form will be collected and held by IVCM (NZ) PIE Superannuation Fund whose address is Level 3, 120 Featherston Street, Wellington Central, Wellington 6011.

How to Complain

In the first instance, please direct any complaints to:

Ranfurly Strategic Limited
Level 1, Awly Building
293 Durham Street
Christchurch 8013
New Zealand

If for any reason we can’t resolve things, you can contact:

Public Trust
Public Trust Customer Feedback
PO Box 13 853
Christchurch 8140
Email: cts.enquiry@publictrust.co.nz
Telephone: 0800 371 471

Ranfurly and Public Trust are Members of Financial Services Complaints Limited (FSCL), an approved dispute resolution scheme. If you’ve complained and you’ve reached the end of Ranfurly and Public Trust internal complaints processes without your complaint being resolved to your satisfaction, FSCL may be able to consider your complaint.

Financial Services Complaints Limited
PO Box 5967
Wellington 6145
Email: info@fscl.org.nz
Telephone: 0800 347 257

FSCL will not charge a fee to any complainant to investigate or resolve a complaint.

Information published on this website has been prepared for general information purposes only and is not personal advice. Heritage Pensions and IVCM do not give advice and are not authorised to provide you with any advice.

Before making an investment decision we strongly recommend you seek the assistance of a qualified adviser, who will consider whether it is appropriate to your particular investment needs, objectives and financial circumstances.

You should also obtain and read this document prior to proceeding with an investment decision.

This guide is based on our understanding of current law relating to pensions. The law and tax rates may change in the future.

Although every effort has been made to verify the accuracy of the information contained on this website, IVCM and Heritage Pensions, their officers, representatives, employees and agents disclaim all liability [except for any liability which by law cannot be excluded], for any error, inaccuracy in, or omission from the information contained in this document or any loss or damage suffered by any person directly or indirectly through relying on this information.

You can view the Heritage Pensions Ltd Privacy Policy here

IVCM and Heritage Pensions Ltd are committed to protecting your privacy and ensuring the security of personal information. The protection of your personal information is a vital part of this relationship. It is supported by our dedication to keeping personal information confidential.

Personal information is information or opinion that allows others to identify you. It includes your name, age, gender, contact details, as well as your health and financial information.

We will act to protect your personal information in accordance with the Data Protection Act 1998 (“the Act”). We only collect the personal information we reasonably require, in the course of our business of providing services, in accordance with this Privacy Policy by lawful, fair and non-intrusive means. We co-operate with police and other enforcement bodies as required or allowed by law. Heritage Pensions is a registered data controller for the purpose of the Act.

We collect personal information to provide you with the products and services you request as well as information on other products and services offered by or through us. The law also requires us to collect and retain personal information. Personal information may be used and disclosed within the group to administer our products and services, as well as for risk management purposes and, unless you tell us otherwise, to provide you with related marketing information.

We will only collect and hold information that is required by us to deliver our services to you and we will do this in a fair and lawful manner.

The pages that follow set out more detailed information about our privacy and information handling practices. If you have any questions or would like further information on our Privacy Policy or information handling practices, please contact our compliance team by:

Phone. 0044 1525 408120
Email. info@heritagepensions.co.uk
Postal address. 6 Doolittle Mill, Froghall Road, Ampthill, Bedfordshire, MK45 2ND, United Kingdom

The types of personal information we collect and store will depend on what products and services you request from us. However, our ability to provide you with service and advice that meets your particular needs and objectives may entail us collecting information which may include any or all of the following:

a) Your contact details including names, address, phone and email address;
b) personal details including your date of birth, associated entities, visa and residency status, national insurance number;
c) your occupation, marital status, financial dependants and identification details such as copies of birth certificate or drivers licenses or other documentation;
d) details of your investment preferences, past experience and aversion or tolerance to risk;
e) details of any professional advisers you engage with;

We will collect, maintain and use personal information both initially and ongoing which is necessary for us to adequately provide the services you have requested such as the placement of financial products including purchase variation or redemption of investments within all of our pension products.

In addition, we use your information to administer our client relationships.

We will not collect personal information about you except when you have knowingly provided that information to us or have authorised a third party to provide that information to us via their privacy controls. In most cases collection of your personal information will be via application forms, over the telephone, email. From time to time, other service providers may provide us with your information for the purpose of our providing a service to you [referral]. In this case we will contact you to determine if we can be of any assistance.

We may seek your express permission to collect information from other entities such as product providers, accountants, solicitors, etc. where this information may not be currently available to you. If we were to obtain information that is not information that could have been provided or authorised for collection by you, we will de-identify and destroy this information unless it is unlawful to do so.

We would like to remind you that you are entitled to access information held about you (you may be charged a fee for this) and if found to be inaccurate, have the information collected or deleted. For further information please visit the website of the Information Commissioner at: www.dataprotection.gov.uk

Identification documentation is required for collection by law under the Money Laundering Regulations, Proceeds of Crime Act, Terrorism Act and the Bribery Act. In some instances, we are required to verify this documentation against other records. For instance, identification for companies, trusts or registered co-operatives may need to be verified by a search of records held by other bodies such as Companies House.

We will not use or disclose personal information collected by us for any purpose other than:

1. the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
2. where you have consented to such disclosure; or
3. where use or disclosure is required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

We are obliged to maintain records which include personal information and make those records available for inspection by the Financial Conduct Authority or other regulators under a relevant law. If we provide information for the purpose of law enforcement activities we will make a record of that provision.

If you chose not to provide your information

The effectiveness of our services is specifically dependent on information you provide and it being relevant, complete, accurate and up-to-date. Without this, our services may not meet your needs or may cause you to suffer unforeseen financial consequences.

We may use personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you, however if you do not wish to receive such information you can request not to receive it. Simply contact us by any of the methods detailed below. There is no cost for this request but please allow 2 weeks for your request to be actioned.

In order to ensure that you receive a personally tailored service, your personal information will be made available to Heritage Pensions Ltd authorised representatives and staff for the purposes of assisting you as necessary.

It is a condition of our agreements with each of our authorised representatives [both personal and corporate] that they adopt and adhere to this Privacy Policy. You can be assured that all authorised representatives and their staff will maintain your information in accordance with this policy. If you have any concerns in this regard, you should contact us by any of the methods detailed below.

In order to provide our service, we may disclose your personal information to external parties as follows:

1. other entities who refer your business to us;
2. affiliated product and service providers as well as external service providers such as scheme trustees, investment providers, and product issuers for whom we act as agent [so that they may provide you with the product or service that you seek or in which you have an express interest];
3. auditors we appoint to ensure the integrity of our operations;
4. suppliers from whom we order goods and services on your behalf [so that those goods and services can be provided to you];
5. other persons acting on your behalf including your accountant, solicitor, executor, administrator, trustee, guardian or attorney;
6. if required or authorised to do so, regulatory bodies and government agencies;
7. other organisations who in conjunction with us provide their products and services [so that they may provide their products and services to you]; and
8. Authorised Representatives or their agents for the purpose of due diligence on one of our associated entities were they to decide to sell all or part of their business. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer and your information will not be exchanged if you object to the transfer.

If we have used an example to describe when we might exchange personal information, the exchange of personal information may not be limited to those examples or examples of a similar kind.

We disclose personal information when we outsource certain functions, including telemarketing, bulk mailing, market research, direct marketing, and information technology support. We also seek expert help from time to time to help us improve our systems, products and services. You have the opportunity to opt out of such marketing if you wish.

In all circumstances where personal information may become known to our contractors, agents, Authorised Representatives or their agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents, Authorised Representatives or their agents and outsourced service providers are not able to use or disclose personal information for any purposes other than our own.

IVCM and Heritage Pensions Ltd takes its obligations to protect client information very seriously and we make every effort to deal only with parties who share and demonstrate the same attitude.

We may require to send personal information overseas to fulfil your investment request, you should be aware of the following:

• your personal information may be accessed by our IVCM and Heritage Pensions Ltd, representatives or agents in other countries, if that becomes necessary to deliver our services to you. This access is via secure internet connection or, in some instances by email;
• from time to time, information may be loaded to the cloud for storage or access through programs such as drop box etc; and
• it is possible that suppliers we deal with may outsource functions using overseas contractors or companies that process these services using offshore resources. Where this is a concern to you, we suggest that you carefully read their privacy policy to determine the extent to which they send information overseas. These service providers have committed to adhering to local data protection laws where applicable.

We allow access to relevant personal information for external organisations that help us provide services. These organisations are bound by confidentiality arrangements. From time to time we may use service providers whose staff accesses our data outside of the United Kingdom to provide services. Where this is the case, these service providers have committed to adhere to local data protection laws where applicable. These service providers may be located in a number of countries however, we are not aware of any at this stage. We will update if and when if this situation changes.

When you visit our website, details may be recorded about your visit, such as time and date, your computer IP address, pages accessed, time spent on page and type of browser. This information is used in an anonymous format for statistical purposes and as such cannot identify you individually. When you log into the client section of our site, we may use cookies to identify who you are, while you are logged in for the session. The cookie is unique to that session, and the data within the cookie is encrypted. You must have cookies enabled to be able to use our site. Our website may contain links to other websites. When visiting these websites be sure to check the privacy policy as we are not responsible for privacy practices of those other parties.

Where you chose to communicate with us by email, we will store your email, name and address with any other contact or personal details you have provided on our database.

When you browse the IVCM website, our internet service provider and website program logs the following information for statistical purposes:

• your server [IP] address;
• top level domain name [e.g. .com, .gov, .uk, etc.];
• the date and time of your web-site visit;
• country your server [IP] is located in;
• the pages you looked at;
• the type of browser you used;
• the previous site you visited; and
• the site you visited next.

We will not use information obtained from your browsing activities to send you any unsolicited information. This information is collected in order to determine the relevancy of material posted on the IVCM website and to enhance this service to visitors.

We will only record your e-mail address if you send us a message [including an email]. We will not add it to a mailing list if you ask us not to. Simply send an email to enquiries@ivcm.com and ask for your details to be removed from the mailing list.

The IVCM website contains links to other sites. Neither IVCM or Heritage Pensions is responsible for the privacy practices or the content of such websites. We encourage the reading of the privacy statements in these linked sites, as their privacy policies may differ from ours.

We will not adopt as our own any identifiers that you may provide to us such as National Insurance numbers etc. If you have provided us signed consent, we may hold your identifiers on file so that we can provide ongoing services to you. If you chose not to provide this consent we will not hold this information on file.

Our goal is to ensure that the personal information we hold about you is accurate, complete and up-to-date. Please contact us if you believe that the information we have about you is not complete, accurate and up-to-date. We may take steps to update information, for example, an account balance from your account service provider where you have provided us with access rights or an address or contact number from publicly available information such as telephone directories or websites.

If you ask, we will tell you what personal information we hold about you within your client file, and what we do with it. On receipt of your request we will facilitate access to you by allowing an inspection of your client file in person, or by providing copies or an accurate summary of relevant documents, depending on what we believe is most appropriate in the circumstances. You can ask us to update or change information on your file at any time. Prior to providing this access we will require you to provide evidence of your identity. We may ask you to put your request in writing and any charge we make for providing access will be reasonable.

If for whatever reason we refuse to change information we hold on your file, we will arrange for a statement from you to be associated with the relevant information so that it can be included in any future use or disclose of that information should you wish to do so.

When we make reference to your client file we mean the following documents: Data collection forms; Written communications [such as letters and emails] Transaction letters; Investment, Applications or statements produced by the issuers of financial products;

We will not provide you with access to your personal information if:

• providing access would pose a serious threat to the life or health of a person or the health and safety of the public;
• providing access would have an unreasonable impact on the privacy of others;
• the request for access is frivolous or vexatious;
• the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
• providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
• providing access would be unlawful;
• denying access is required or authorised by or under law;
• IVCM or Heritage Pensions Ltd has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to its functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
• providing access is likely to prejudice actions being conducted by an enforcement agency; or
• providing access would reveal evaluative information generated within IVCM and Heritage Pensions Ltd in conjunction with a commercially sensitive decision making process.

In the event we refuse you access to your personal information, we will provide you with a written explanation for that refusal. We will endeavour to respond to any request for access within 30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.

Your personal information is generally held in your client file and on our computer database. We will at all times seek to ensure that your personal information is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential.

Our security measures include, but are not limited to:

• educating our authorised representatives and staff as to their obligations with regard to your personal information;
• all hard copy files are stored in lockable cabinets/rooms;
• access to our premises is controlled by only allowing authorised personnel to access those locations where personal information is stored;
• all computer-based information is protected through the use of access passwords on each computer and screen saver passwords;
• client data is backed up each evening and stored securely off site;
• encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;
• employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
• using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing; and
• providing secure storage for physical records.

In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in our secure storage facility for a period of 7 years in order to comply with legislative requirements. Where information we hold is identified as no longer needed for any purpose we ensure it is effectively and securely destroyed, for example, by shredding in the case of paper records and other means in the case of electronic records and equipment.

From time to time it may be necessary for us to review and amend this policy. We reserve the right to amend this policy at any time. You should check our website from time to time for our latest privacy policy.

If you seek any further information from IVCM or Heritage Pensions Ltd about this statement or our privacy policy generally please contact our compliance team using the details below:

Phone. +971 4429 8686
Email. enquiries@ivcm.com
Postal address. IVCM Services, PO Box 345804, Building 7, Dubai Outsource City, Dubai, United Arab Emirates

You can view the Heritage Pensions Ltd Legal Statement here

This website is provided by IVCM on an ‘as is’ basis. Neither IVCM or Heritage Pensions makes any representations or warranties of any kind, express or implied, as to the operation of the website or the information, content, materials, or products included on this website.

Heritage Pensions Ltd are the operator and scheme administrator for the IVCM Heritage SIPP and are authorised and regulated by the Financial Conduct Authority (FCA 475096). The asset trustee for the IVCM Heritage SIPP is Heritage Trustees Limited.

The International Expat SIPP is operated and administered by Heritage Pensions Limited who are authorised and regulated by the Financial Conduct Authority, registration number 475096. The asset trustee for the International Expat SIPP is International SIPP Trustees Limited.

The Brooklands SIPP is operated and administered by Heritage Pensions Limited who are authorised and regulated by the Financial Conduct Authority, registration number 475096. The asset trustee for the Brooklands SIPP is IVCM Heritage Trustees Limited.

To the full extent permissible by applicable law, IVCM and Heritage Pensions disclaim all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. Neither IVCM or Heritage Pensions will be liable for any damages of any kind arising from the use of this website, including, but not limited to direct, indirect, incidental, punitive, and consequential damages.

Applicable Law; This website is created and controlled by IVCM in the United Arab Emirates. As such, the laws of the UAE will govern these disclaimers, and terms and conditions, without giving effect to any principles of conflicts of laws. We reserve the right to make changes to our website and these disclaimers, and terms and conditions at any time.

Please note the Law applicable to Heritage Pensions Ltd is England and Wales.

Risk and Liability; You accept all risks and responsibility for losses, damages, costs and other consequences resulting directly or indirectly from using this website and any information or material available from or through it.

To the maximum permitted by law, IVCM and its affiliates excludes all liability to any person arising directly or indirectly from using this website and any information or material available from or through it.

IVCM limits any liability that cannot be excluded to restoring the service, re-supplying the material or refunding any amount paid to IVCM for the service or material. Any products or services provided by IVCM may be modified over time.

None of the information and data contained in this website [ www.ivcm.com ] nor any opinion expressed, constitutes a recommendation to purchase or sell a security, or to provide investment advice. Past performance of financial products is no assurance of future performance. The payment of dividends and the return of capital are not guaranteed.

The information contained on the Heritage SIPP is provided for general informational purposes, as a convenience to the customers of IVCM. The materials are not a substitute for obtaining professional advice from a qualified person, firm or corporation. Consult the appropriate professional advisor for more complete and current information.

IVCM is not engaged in rendering any legal or professional services by placing these general informational materials on this website.

IVCM makes no representations or warranties about the accuracy or completeness of the information contained on this website. Any links provided to other server websites are offered as a matter of convenience and in no way are meant to imply that IVCM endorses, sponsors, promotes or is affiliated with the owners of or participants in those websites, or endorses any information contained on those websites, unless expressly stated.

IVCM does not warrant or represent that the website is error free or free from viruses or defects. You must do all that is necessary [including using virus checking software] to satisfy yourself that accessing this website will not adversely affect your computer system[s].

IVCM is the copyright owner of all text and graphics contained on this website, except as otherwise indicated. Other parties` trademarks and service marks that may be referred to herein are the property of their respective owners. You may print a copy of the information contained herein for your personal use only, but you may not reproduce or distribute the text or graphics to others or substantially copy the information on your own server, or link to this website, without prior written permission of IVCM.

Permission to use and reproduce documents and related graphics available from this website is granted, provided that:

the below copyright notice appears in all copies and that both the copyright and this permission notice appear;
use and reproduction of documents and related graphics available from this website is limited to personal, non-commercial use;
no documents or related graphics, including logos, available from this website are modified in any way; and
no graphics, including logos, available from this website are used separate from accompanying text. Use or reproduction for any other purpose is expressly prohibited by law, and may result in civil and criminal penalties.
Violators will be prosecuted to the maximum extent possible.

If any part of this disclaimer is held to be invalid, unenforceable or illegal for any reason, the remaining parts of the disclaimer shall nevertheless continue in full force.

Please find the link to the Heritage Pensions Limited complaint procedure.

If you are not satisfied with any aspect of the Heritage Pensions Ltd products or service, you may wish to register a formal complaint. In the event of this please contact:

The Compliance Officer
Heritage Pensions Ltd
6 Doolittle Mill
Froghall Road
Ampthill
Bedfordshire
MK45 2ND

If you are not satisfied with our response to your Complaint you have the right to take it to the Financial Ombudsman Service. Their details are:-

The Financial Ombudsman Service, Exchange Tower London, E14 9SR. Telephone: +44 800 0234 567

You may also refer to:

The Pensions Ombudsman
10 South Colonnade
Canary Wharf
E14 4PU
Tel: 020 7630 2200
Fax: 020 7821 0065
Email: enquiries@pensions-ombudsman.org.uk
Website: www.pensions-ombudsman.org.uk

A copy of our complaints procedure is available on request. Making a complaint will not affect your legal rights. Any complaint regarding advice given to you by your Financial Adviser should be referred to them.