Privacy Policy

Privacy Policy 

IMF Bentham Pte. Limited ("IMF") has a commitment to respecting your privacy and believes that privacy is an important individual right.

This Privacy Policy ("Policy") applies in relation to IMF’s operations in Singapore and explains how IMF complies with the Personal Data Protection Act (Cap 26 of 2012) (the “PDPA”).  

This Policy relates to the collection, storage, disclosure and use of personal information that is covered by the PDPA, being personal data relating to an individual. This Policy is not intended to cover information that is not covered by the PDPA.

By supplying us with your personal information, you are agreeing to be bound by this Policy.
Any amendments to this Policy will be notified to you by posting an updated version of the Policy on our website at www.imf.com.sg.

Background

IMF is a company incorporated in Singapore, which provides funding for high value legal claims and other related services. IMF's principal activities are the investigation, management and funding of litigation and arbitration claims in Singapore and other jurisdictions.

IMF is a subsidiary of IMF Bentham Limited, an Australian public company listed on the Australian Securities Exchange (ASX: IMF). The IMF Bentham Limited group of companies also have offices in Australia, United States, Canada and Singapore.  

Collecting information about you

IMF generally collects personal data directly from you or your authorised representative.  In some instances, IMF may collect your personal data before any official engagement is entered into between you and IMF. For example, IMF may collect personal data about you when you deal with us over the telephone, send us correspondence (whether by letter, fax, e-mail or via the IMF website), request litigation funding via IMF’s website or when a representative of IMF meets with you. If you contact us, IMF may keep a record of that contact. In some instances (including but not limited to where we have obtained your personal data via our website) your personal data may be provided to us by your authorised representative.

Generally, the type of information IMF collects and holds about clients, service providers (such as lawyers and experts) and other business contacts will include your name, mailing and email addresses, telephone number, job title and organisation/employer name.  

In order to provide clients with our services, IMF also collects information relating to the legal proceedings for which funding is sought or being provided.

If you do not provide IMF with the information requested, IMF may not be able to provide you with our services.

IMF may also source personal data from a third party or source.  For example, IMF may collect personal data about you from a publicly maintained record or from the public domain generally (for example via the internet or media). IMF will take reasonable steps where necessary to notify you when it collects your personal data from a third party or source.

Using and disclosing your personal information

IMF collects, holds, discloses and uses your personal data to:

  • provide our services and products to you;
  • market our services and products to you (unless you have notified us that you do not wish to receive marketing material);
  • keep you informed of legal and funding developments that may be of interest to you
  • notify you of events that IMF is holding;
  • communicate with you;
  • purchase goods and services from you;
  • help us manage or improve our services;
  • comply with legal obligations; and/or
  • other purposes related to any of the above.

If you are a client or are employed or engaged by a client, IMF may disclose your personal data to:

  • other companies or individuals who assist us in providing services or who perform functions on IMF’s behalf;
  • solicitors, barristers or any other experts engaged to provide you with services which IMF have agreed to fund; and
  • anyone else to whom you authorise us to disclose it.

If IMF engages third parties to perform services for us, which involves the third party handling personal data that IMF holds, IMF prohibits the third party from using personal data about you except for the specific purpose for which IMF supplies it.  IMF does not disclose any personal data it collects to third parties for the purpose of allowing them to directly market their products and services. IMF does not sell or trade personal information.

Disclosure of personal information outside Singapore

IMF may disclose your personal data to overseas persons or entities if the disclosure is required in order for IMF to provide its services to you.

The countries in which such overseas recipients are located will depend on the circumstances of the services IMF provides you. 

Without limiting the foregoing, it is contemplated that your personal data may be disclosed to offices and agents of the IMF Bentham Limited group of companies located in Australia.

IMF will take reasonable steps to ensure that any overseas persons or entities to whom any personal data is disclosed to are bound by legally enforceable obligations to provide a standard of protection that is comparable to that under the PDPA.

Accessing and correcting personal information IMF holds about you

You can contact IMF at any time to request access to your personal data or for your personal data to be corrected or updated. Please direct your request to IMF’s Data Protection Officer on the details provided below.

Unless an exception applies, IMF will, on request, at no charge and within 28 days provide you with access to the personal data IMF holds about you. IMF will provide you with access to your personal data in a manner requested by you, provided it is reasonable and practicable to do so.

If IMF is unable to provide you with access to the information, IMF will provide you with reasons and inform you of any exceptions relied upon under the PDPA, for example that your request is unreasonable or relates to legal proceedings and may be privileged or that providing the information would be unlawful. IMF will also provide you with details of the process for making a complaint about the refusal to grant you access.

IMF will take appropriate steps to verify your identity (or verify that you act as a legal guardian or authorised agent of the individual concerned) before granting a request to access your personal information. 

IMF will take reasonable steps to ensure that the personal data IMF collects about you is accurate, up-to-date, complete and relevant.

IMF will also take reasonable steps to ensure that any personal data about you which IMF uses or discloses is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.

On request, IMF will correct your information within 28 days of the request and at no charge. IMF will take reasonable steps in the circumstances to notify any relevant third parties of the correction.

Storage, security and destruction of your personal information

IMF will take all reasonable steps to ensure that your personal data is kept secure and that it is protected from misuse, interference, loss, unauthorised access, modification or disclosure.

Your personal data may be stored in hard copy documents and/or as electronic data in IMF’s software or systems. IMF maintains physical security over its premises and also maintains computer and network security.

IMF requires its employees to respect the confidentiality of any personal data held by IMF. 

IMF may be legally required to keep some of your personal data for a significant period of time. However, once IMF believes the information is no longer required for legal or business purposes, we will take reasonable steps to remove any identifying details or destroy the information entirely. 

IMF's website and use of cookies

A cookie is a small data file that a website may write to your hard drive when you visit. A cookie file can contain information (such as a user ID) that the website can use to track the pages you have visited and your preferences. The only personal data a cookie can contain is information you personally supply. A cookie cannot read data from your hard disk or read cookie files created by other websites. 

IMF uses cookies to track user traffic patterns through its website. 

Dealing with IMF anonymously

Where lawful and practicable to do so, you can deal with IMF anonymously or using a pseudonym. You can deal with IMF anonymously or using a pseudonym when making a general enquiry about the services that IMF can offer to you including via telephone or our website.  At the time you engage our services, it is no longer practicable for you to deal with us anonymously or using a pseudonym. 

Spam Control Act

IMF complies with the Spam Control Act (Cap 311A) which regulates the sending of emails and other commercial electronic messages with a Singapore link. An electronic message has a Singapore link where:  

  • the message originates in Singapore;
  • the sender of the message is:
    • an individual physically present in Singapore when the message is sent; or
    • an entity whose central management and control is in Singapore when the message is sent;
  • the computer, mobile telephone server or device that is used to access the message is located in Singapore;
  • the recipient of the message is:
    • an individual who is physically present in Singapore when the message is accessed; or
    • an entity that carries on business or activities in Singapore when the message is accessed; or
  •  if the message cannot be delivered because the relevant electronic address has ceased to exist (assuming that the electronic address existed), it is reasonably likely that the message would have been accessed using a computer, mobile telephone, server or device located in Singapore.

For the avoidance of doubt, the foregoing does not apply to any electronic message where the sending of the message is authorised by the Government or a statutory body on the occurrence of any public emergency, in the public interest or in the interests of public security or national defence.

Effect of the Policy

This Policy does not form a contract between an individual and IMF. This Policy may change to reflect IMF's business, laws and technology. Whenever you need to refer to this Policy you should refer to IMF's website - www.imf.com.sg - or contact us for the most up to date version.

Please note that IMF's website contains links to other websites. When a user has clicked on a link to another site, they leave the IMF site and are no longer protected by this Policy. IMF entities operating outside of Singapore are subject to different laws regarding privacy. If you access the websites of such other entities, either directly or via the IMF site, you should ensure that you check the privacy policy of each site. 

How you may lodge a complaint about privacy and how IMF will deal with the complaint

If you believe that IMF has breached a term of this Policy or the PDPA you may submit a written complaint. The written complaint can be emailed or posted to us using the contact details set out below. You must include contact details for us to contact you regarding your complaint.

Our Data Protection Officer will consider your complaint and respond as soon as reasonably possible, but not more than 28 days from receiving the complaint.

If you are unsatisfied with the outcome of your complaint you may ask the Date Protection Officer to be referred to a higher authority within the company, such as IMF's Managing Director. If you still remain unsatisfied with the outcome, you may refer your complaint to the Personal Data Protection Commission (https://www.pdpc.gov.sg/home or telephone +65 6377 3131). 

Contacting IMF

If you wish to gain access to your personal information, amend your personal information, request not to receive direct marketing communications from IMF, wish to lodge a complaint about privacy, have any query regarding the Policy or wish to obtain a hard copy of the Policy, please contact our Data Protection Officer as follows:

By telephone: +61 8 9225 2300

Address: PO Box Z5106, St George's Terrace PERTH   Western Australia   6831 

By email: [email protected]

This Policy was last updated on 21 June 2017 
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