Protecting your privacy and ensuring the security of your personal data is important to us at Cameron James/BFMI.
Cameron James/BFMI (“hereinafter referred to as “Cameron James/BFMI”) ensures all personal data is protected at all times, whether for prospective, actual or withdrawn clients.

The Privacy Policy below describes and explains how Cameron James/BFMI handles the collection, management and the protection of confidential Client, business partners and user’s information. Cameron James/BFMI takes security very seriously and adopts industry and information technology best practices to protect your personal information and ensures that your right to privacy is not infringed in any way and is not accessed by any unauthorized persons.

The terms “you” and “your” includes our clients, business partners and users of this website.

Cameron James/BFMI processes and stores personal information in accordance with the Data Protection Act 2004 (the “Data Protection Act”, which includes any modification or amendment to that Act), this Privacy Policy and the provisions of other applicable laws, regulations and rules.

What is Personal Information?

When used in this policy, the term ‘personal information’ has the meaning given to it in the Act. In general terms, personal information is information or an opinion that can be used to reasonably identify you, whether the information or opinion is true or not. This includes any information we collect from you directly, or from a third party such as your employer, in order to offer you a service or product. It may include, but is not limited to, your name, address, date of birth, contact details including email address, Tax File Number, occupation, financial information and/or any additional information you provide to us directly or indirectly through a website or via a representative. Personal information may also include ‘sensitive information’.

What is Sensitive Information?

Sensitive information includes information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional trade or association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information or biometric information.

Cameron James/BFMI will not collect sensitive information about you without your consent unless it is required by Gibraltar law, or other limited exemptions apply.

Collection of your Personal Information

Generally, we are required to collect personal or sensitive information directly from you in the course of offering and administering our products and services and managing the employment and engagement of our staff and contractors. The information we may collect includes:

  • Name;
  • Address;
  • Date of birth;
  • Contact details (including telephone and email);
  • Gender;
  • Occupation;
  • Tax File Number;
  • salary;
  • Relevant financial information;
  • Employment history and other information collected during the recruitment process.
  • Any additional information relating to you that you provide to us directly through our websites or indirectly through our websites or online presence such as ‘cookies’.

Where relevant, your personal information may also be provided to us via a third party such as your employer, other superannuation or investment fund, recruitment company, financial adviser or other representative authorized by you, as well as publicly available sources.

The Purpose of Collecting Personal Information

We will only collect personal information about you where it is reasonably necessary for one or more of the activities or functions that we undertake for you, your employer or the trustee of a superannuation fund. Where it is reasonable and practicable to do so, we will collect the personal information from you directly.

We collect your information in order to provide the following services and products and to manage the employment and engagement of our staff and contractors and to give you information about these matters:

  • For financial advisory services, to provide you with financial advice and implement your instructions in relation to your finances;
  • For regular savings and Lump-Sum Investments;
  • Pension transfers services;
  • Tax planning services;
  • To provide any consulting or other services you may request;
  • For handling any complaints, inquiries or disputes regarding our services, products and your employment with Cameron James/BFMI;
  • To manage and assess your claim, and manage subsequent correspondence in relation to your claim; and
  • For recruitment purposes, to manage your employment application and, if you are successfully placed in a position at Cameron James/BFMI, your ongoing employment.

If you do not provide the personal information requested, we may not be able to provide you with these services and products or continue with your recruitment or employment. We may also use it to supply you with information about the other products and services offered by our related companies and us.

Use and Disclosure

Cameron James/BFMI collects, uses and discloses personal information about individuals for the primary purpose of providing a product or service and the recruitment and employment of staff and contractors as a part of conducting our business operations. Our business model includes the provision of:

  • Consulting and investment services to our clients;
  • Financial Advice and related services.

We use and disclose personal information to:

  • Provide products, services or financial advice to individuals and to send communications requested by them;
  • Answer enquiries and provide information or advice about new or existing products or services;
  • Manage and assess insurance claims;
  • Provide access to protected areas of our website; provide marketing information and materials (including direct marketing), product or service development and research purposes;
  • Perform data analytics for marketing, product or policy development;
  • Keep your contact details up-to-date;
  • Investigate and respond to any complaint and deal with any subsequent dispute resolution process;
  • manage applications for employment with us and any subsequent employment; and
  • Comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (where relevant).

We may disclose your information to:

  • Related bodies corporate, contractors or other business support service providers for the purposes of the operation of our business, products, and services such as administration, document storage warehouses, printing and mail houses, couriers, payment system operators, debt collectors and authorized professional advisers such as accountants, solicitors, and consultants;
  • Your financial adviser or other third-party appointed by you;
  • Our data hosting and IT (related and non-related party) service providers who may be located or store data in other countries;
  • Other Cameron James/BFMI companies which need to use the information to provide products or services to you;
  • Other superannuation, pension, and investment fund trustees or administrators should you transfer your investment to another fund;
  • Recruiters and employment screening service providers for the purposes of considering applications for employment;
  • As required by law, to government bodies.

Cameron James/BFMI is required to collect and use certain government-related identifiers such as Tax File Numbers when providing certain services to our employees, members, and clients. Cameron James/BFMI is not permitted to and does not adopt government identifiers as an identifier of the individual. Cameron James/BFMI does not use or disclose government related identifiers in any way that is inconsistent with the purpose for which they were originally issued other than where it is required or authorized by or under a Madagascar law or a court/tribunal order.

GDPR Compliant - The General Data Protection Regulation (EU)

From the 25th May 2018, the General Data Protection Regulation (Regulation (EU) 2016/679a>, more commonly known as the ‘GDPR’) provides data subjects more rights in relation to their personal data. You can find out more about the GDPR and your rights by accessing the European Commission’s website. You have the following rights:

  • Information about the processing of your personal data (and if you did not give it to us, information as to the source);
  • Obtain access to the personal data held about you;
  • Ask for incorrect, inaccurate or incomplete personal data to be corrected;
  • Request, in certain cases, that personal data be erased when it’s no longer needed or if processing it is unlawful;
  • Object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation;
  • Request the restriction of the processing of your personal data in specific cases;
  • Receive your personal data in a structured, commonly used and machine-readable format, or ask us to send it to another person (‘data portability’); and
  • Request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision.

Please note these rights may only apply in certain cases. For example, some rights only apply where our lawful ground of processing is your consent, or where we have a contract with you. You also have a right to lodge a complaint with the appropriate data protection authority whose details are provided below, and in certain cases may receive compensation from us, as data controller, for any damage you suffer.

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example, if you change your email address or name, please let us know the correct details by contacting us on the details below. You may ask us, or we may ask you to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate. You can find out more about the GDPR and your rights by accessing the European Commission’s website.

Security

Cameron James/BFMI places a high priority on the security of personal information, and we are committed to protecting the personal information that you provide to us. We take reasonable steps to ensure that your personal information is secure and we use and maintain appropriate safeguards to prevent misuse and loss and from unauthorized access, modification or disclosure. We implement administrative, physical and technical safeguards to protect the confidentiality and integrity of your personal information and data that we use and hold.

Where practical, your personal information is de-identified or destroyed when it is no longer required. Where Cameron James/BFMI becomes aware of any actual or potential unauthorized access or disclosure of your personal information, we will ensure that the potential breach is managed by Cameron James/BFMI in accordance with the law.

Privacy on The Internet

We take care to ensure that the information you give us via our websites is protected. Cameron James/BFMI uses and maintains appropriate safeguards to prevent unauthorized access to or use of your personal information and data. We implement administrative, physical and technical safeguards to protect the confidentiality and integrity of your personal information and data which may be transmitted via the internet.

We use ‘cookies’ to store the information provided by your browser when you visit our websites. This includes the date and time of your visit, the pages accessed and documents downloaded. This enables us to keep track of products or services you view so that, unless you have opted out, we can send you news about those products or services. We also use cookies to measure demographic usage patterns to determine which areas of our website have been visited and to improve our services.

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website, and we are not responsible for the privacy policies or the content of any third party website. Third-party websites are responsible for informing you about their own privacy practices.

Access and Correction

Cameron James/BFMI aims to ensure that the personal information we hold about individuals is accurate, up-to-date and complete. We will take reasonable steps to ensure the quality of your personal information at two distinct points in the information handling process: collection and use or disclosure.

If you advise us that the information that we hold about you is not accurate, up-to-date or complete, we will take reasonable steps to correct your information. Otherwise, you may request access to your personal information by contacting Cameron James/BFMI’s Privacy Officer (see the ‘Contacting Us’ section below). The Cameron James/BFMI Privacy Officer will need to establish the identity of the individual requesting the information prior to providing it Cameron James/BFMI.

There are a number of situations where Cameron James/BFMI may deny an individual access to personal information. These can include circumstances where it would have an unreasonable impact on the privacy of other individuals, the information relates to existing or anticipated legal proceedings, we have reason to suspect that unlawful activity or misconduct of a serious nature is being or maybe engaged in, or where the law requires or authorizes such access to be denied. Cameron James/BFMI’s Privacy Officer will advise you if any of these or other circumstances apply.

Cross-Border Disclosure

Cameron James/BFMI outsources some of its activities and may disclose personal information to our related bodies corporate and third-party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your information do not breach the privacy obligations relating to your personal information.

Direct Marketing

Cameron James/BFMI may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms including mail, fax and electronic media such as email and SMS and social media such as Twitter and Facebook. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from Cameron James/BFMI by using the opt-out facilities provided within the marketing communications.

Cameron James/BFMI does not share, sell, rent or disclose your personal information to other organizations other than as described in this Privacy Policy.

Governing Law and Jurisdiction

All issues regarding our website and Privacy Policy are governed by Gibraltar law and are subject to the exclusive jurisdiction of the Gibraltar courts.

Contacting Us

If you have any questions about this privacy policy, would like to know more about Cameron James/BFMI’s personal information principles, or if you have any concerns or would like to make a complaint regarding the treatment of your personal information, you can contact Cameron James/BFMI’s Privacy Officer using the details set out below.

We treat any concerns or complaints that you may have with respect and confidentiality. A privacy representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

How can you contact us or make a complaint?

The data controller for any personal data you provide to us is Cameron James/BFMI. If you have any questions, concerns or comments or if you would like further information about this Privacy Policy, how we handle your Personal Data or otherwise wish to enforce your data protection rights, please contact us at:

Cameron James/BFMI has not designated a Data Protection Officer, but our Privacy Team can be contacted directly via the above details.

Your right to complain

We always try to meet the highest standards in order to protect your privacy. If you are concerned about the way in which we are managing your personal information and think we may have breached any applicable privacy laws or any other relevant obligation, please raise any complaints regarding the processing of personal data to us directly on the contact details above.

We will make a record of your complaint and refer it to our internal complaint resolution committee for further investigation. We will deal with the matter and keep you informed of the progress of our investigation.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Data Protection Commissioner under the Data Protection Act, which is the Gibraltar Regulatory Authority (GRA). The GRA is responsible for ensuring that your rights and obligations are respected. The GRA is also competent to hear your complaints and may prohibit or restrict the processing of your personal data in certain cases. You can contact the GRA as per below.

  • Gibraltar Data Protection Commissioner
    Gibraltar Regulatory Authority
    2nd Floor, Eurotowers 4
    1 Europort Road
    Gibraltar
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