This Privacy Statement applies to each of the following entities within the TWT corporate group:
(the term TWT applies equally to each of the entities listed above, both as a corporate group and individually, as applicable). This Statement may be updated to include additional TWT entities or to remove one of the above entities by the Privacy Officer of TWT from time to time.
TWT operates a real estate development and financial services business, in which it sources and invests into real estate development opportunities and provides general financial advisory, management and transactional services for wholesale clients in respect of real estate investment opportunities, as well as acting as an investor or financier in its own right. In this role, TWT may act as a trustee or investment manager. TWT may also act as a development manager in respect of real estate development opportunities.
TWT collects personal information from people who are potential clients and clients and from other people who are connected to its operations and activities – including employees, investors, investee companies, borrowers, service providers and suppliers.
Personal information is any information or an opinion, whether true or not, about you that identifies you, or by which your identity can be reasonably ascertained. This includes information such as name, date of birth, gender, contact information, credit/debit card information, credit file information, information about your business or investment and business or investment track record.
Whenever reasonable and practical to do so, TWT collects information about individuals directly from the individual.
In some cases, TWT collects personal information from third parties, including public sources, its related companies, referrers, brokers, agents, an individual' or entity's adviser(s), its service providers (including credit reporting agencies and information service providers), investee companies and other persons and entities with whom it does business. TWT may also obtain information about you from third parties such as credit bureaus and identity verification services (such as Dun & Bradstreet, Veda and Experian), but if you are an individual, only where you have given express consent for it do so.
The primary purpose for which TWT collects personal information is so that it can carry out its financial services business as an independent investment and advisory firm. We may use your personal information and you consent to your personal information being used to:
TWT does not sell personal information to other organisations.
Your personal information may also be used for any other specific purpose for which it was requested and which was advised to you and any directly related purpose to a primary purpose above.
Where we use your personal information to send you marketing and promotional information by post, email or we contact you by telephone, you will be provided with an opportunity to opt-out of receiving such information. By electing not to opt-out, we will assume we have your implied consent to receive similar information and communications in the future. We will always ensure that our opt-out notices are clear, conspicuous and easy to take up.
You have the option to deal anonymously or by pseudonym if you contact us by telephone and you merely seek information about our services but you do not wish to enter into any further discussions with us. However, if you wish to deal with us in this way, you will not be able to engage with us in respect of our service offering. If you wish to engage with us in respect of our service offering, you must provide us with your personal information.
If you do not provide some or all of the personal information requested, we will not be able to offer you with our services you require and we may not be able to provide you with all of the information that you seek about our services. For example, if you do not provide your personal information which is required for us to conduct our AML/CTF check in respect of your identity, we will not be able to engage with you as a potential client, investor or co-investor.
In carrying out our business, we may need to disclose your personal information to others, as follows:
Your personal information will be stored on a password protected electronic database, which may be a TWT database, a database maintained by a cloud hosting service provider or other third party database storage or server provider. All such personal information is maintained with in the effective control of TWT. We have arrangements which require third party service providers to maintain the security of the information and we take reasonable steps to protect the privacy and security of that information, however, we are not liable for any unauthorised access or use of that information.
Your personal information will stay on the database indefinitely until you advise you would like it removed, unless we de-identify it or destroy it earlier in accordance with privacy law requirements.
TWT will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we request that you identify, as clearly as possible, the type/s of information requested. We will deal with your request to provide access to your personal information within 30 days and you agree we may charge you our reasonable costs incurred in supplying you with access to this information.
Your rights to access personal information are not absolute and in certain circumstances, privacy laws dictate that we are not required to grant access such as:
If you agree to us verifying your identity using e-verification (i.e. electronic identity verification by a credit reporting agency), you have the right to access the verification assessment provided by the relevant credit reporting agency.
You may ask us to update or delete the personal information we hold about you at any time. You accept that we will take reasonable steps to verify your identity before granting access or making any corrections to or deletion of your information. We also have obligations to take reasonable steps to correct personal information we hold when we are satisfied that it is inaccurate, out- of-date, incomplete, irrelevant or misleading for the purpose for which it is held.
If you require access to, or wish to update your personal information, please contact us at TWT Funds Limited ACN 165 806 351 of Suite 2, 9 Atchison Street, St Leonards NSW 2096, +61 2 9906 1888, or firstname.lastname@example.org.