Five V Capital Privacy Policy

1.  Introduction

Five V Capital Pty Limited (ACN 162 193 928) (Five V Capital), any Related Body Corporate or Associate of Five V Capital (as defined under the Corporations Act 2001 (Cth)) (but excluding, for the avoidance of doubt, any investee entity) and any partnership or trust of which Five V Capital (or any of its Related Bodies Corporate or Associates) is the manager, general partner or trustee (as applicable), together we, us or our, understand that your privacy is paramount, and are committed to protecting your privacy. This privacy policy sets out how we handle personal information about you.

2.  Introduction

Personal information is information or an opinion about an individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in material form or not

3.  Introduction

(a) We may collect personal information from you:
• to manage your investments;
• to provide products and services to you, such as seminars, market commentary or email alerts;
• to send you marketing materials; and
• when you contact us by any method, such as telephone, email, post or in
person, including to respond to your enquiries; or otherwise as notified to you from time to time.

(b) The personal information you provide to us may vary depending on the nature of your interaction with us, but may for example include your name, email address and postal address. We do not normally collect your sensitive information.

(c) There may be occasions when we collect information about you from a third party, such as investment brokers when we are assessing a potential investment opportunity for our affiliated funds (whether through due diligence or otherwise). This may include a broader range of personal information than identified above, but normally occurs under strict conditions of confidentiality and only for the purpose of allowing us to assess the relevant opportunity.

(d) We generally do not permit people that we do business with to deal with us anonymously or using a pseudonym. If you do not provide us with your personal information, we may not be able to conduct business with you.

(e) Unless you notify us otherwise, we will assume that you have consented to the collection of all information which is provided to us for use in accordance with this privacy policy.

4.  Introduction

(a) Our web servers may automatically collect information when you visit our websites (such as https://www.fivevcapital.com), including:
• your IP address;
• your network location;
• the date and time of your visit;
• the parts of our website you access during your visit;
• your actions on our website; and
• the browser and device you are using.

(b)  In using our websites, your personal information may be collected through the use of cookies. Some of these cookies may be placed by third parties such as our service providers. Cookies are small text files placed on your mobile device or computer by our websites which automatically collect information about you without you providing that information to us directly. Most browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt you whether you wish to accept cookies on a particular site, or by default reject cookies.

(c)  Please note that rejecting cookies may mean that some or all of the functions on our website will not be available to you.

(d)  To control which web servers collect information by automated means, we may place tags on our websites called web beacons. Web beacons are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with our websites.

(e)  We may use third-party web analytics services on our websites, such as those of Google Analytics. These service providers help us analyse how visitors use our websites. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.

(f)  The providers of third-party plug-ins and widgets on our websites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of our websites and your interactions with the plug-ins and widgets. This information is subject to the privacy policies or notices of the providers of the plug-ins and widgets.

(g)  Sometimes our websites contain links to other websites. When you access a website other than our websites, we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each website you visit.

5.  Using your personal information

(a) We only use personal information for the purpose for which it was collected, for related purposes which we consider come within your personal expectations, or as permitted or required by law.

(b) In particular, the personal information that we collect is generally used in the conduct of our business.

(c) We may contact you from time to time for marketing purposes. If you would rather not receive any marketing material from us, you may opt out by notifying us using the contact details in section 9 below, or following the unsubscribe instructions on any marketing email you have received.

6.  Sharing your personal information

(a) We may disclose your personal information to other related entities within our corporate group for our own business purposes, in which case that group company will only use and disclose your personal information in accordance with this privacy policy as if a reference in this privacy policy to us included a reference to that group company.

(b) We may disclose information to third party contractors and advisers, who help us conduct our business. We may also disclose anonymous or aggregated information to such contractors and advisers for any purpose. Some of these recipients may be located overseas, but it is not practical to list the countries in which they are located. Where information is shared with these third parties, we will take reasonable steps to ensure that third parties observe the confidential nature of such information and are prohibited from using any or all of this information beyond what is necessary to assist us.

(c) We do not sell, rent or trade personal information to third parties for marketing purposes.

(d) We may also disclose your personal information as permitted or required by law.

7.  Access and correction of your personal information

(a) We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under the Australian Privacy Principles (APPs).

(b) If you require access to your personal information, please use the contact details set out in section 9 below. Before we provide you with access to your personal information we will require some proof of identity. For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.

(c) If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).

(d) We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it. If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

8.  Protecting your personal information

We are committed to protecting your personal information. We take appropriate security measures to protect your personal information from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes the use of technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information.

9.  Contact information

If you have any queries or complaints with regards to our collection, use or management of your personal information, please contact us at the following details:

A: Srdjan Dangubic

E: sdangubic@fivevcapital.com

If you make a complaint, we will endeavour to respond to it as soon as possible. If you are dissatisfied with our response, you have the right to make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email enquiries@oaic.gov.au.

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