Privacy Policy

We collect personal information where reasonably necessary for our functions and activities. We generally collect personal information directly from you, including through application forms, transaction forms, correspondence, telephone calls, emails, meetings, our websites, investor portals, online forms and other communications.

We may also collect personal information from third parties, including your adviser, broker, authorised representative, employer or organisation, other members of the Skybound group, custodians, trustees, fund administrators, unit registry providers, anti-money laundering and counter-terrorism financing (AML/CTF) verification providers, credit reporting bodies, information service providers, regulators, government agencies, public registers, publicly available sources, recruitment agencies, previous employers and referees.

Where reasonable, we will notify you if we collect personal information about you from a third party and the circumstances of collection. Some information we request is mandatory. If you do not provide that information, we may not be able to verify your identity, process your application or withdrawal, provide services, administer your investment, communicate with you, or comply with our legal and regulatory obligations.

The kinds of personal information we may collect and hold include:

• identity and contact details, including name, date of birth, gender, address, email address, telephone number and occupation;
• investor details, including investment holdings, application information, transaction history, distribution information, registry account details, communications preferences and authorised representative details;
• financial, payment and taxation information, including bank account details, tax file number, Australian business number, residency information, FATCA/CRS information and distribution payment details;
• identification and verification information, including driver licence, passport, Medicare card or other identification documents and information collected for AML/CTF, KYC, sanctions, politically exposed person, beneficial ownership, source of funds and source of wealth checks;
• records of communications with you, including enquiries, complaints, telephone calls, emails, online interactions and saved forms;
• website, analytics and technology information, including IP address, device identifiers, browser type, operating system, login information, usage data, cookies and similar technologies;
• information about contractors, suppliers and business contacts, including contact details, role, organisation, payment details and correspondence;
• employment and recruitment information for job applicants and staff, including qualifications, skills, experience, references, screening checks, employment history, payroll, tax, banking, superannuation, emergency contact, performance and conduct information; and

any other personal information reasonably required for our functions or activities or to comply with law.

We collect and hold personal information about you which is reasonably necessary to:

• provide you with our products or services;
• consider applications and approaches you make to us;
• conduct marketing;
• maintain your contact details;
• verify your identity;
• conduct AML/CTF, sanctions and customer due diligence checks;
• administer investments and maintain investor records;
• respond to enquiries and complaints;
• prevent fraud or unlawful activity; and
• comply with our obligations under the Corporations Act 2001 (Cth) (Corporations Act), Privacy Act, AML/CTF legislation and taxation laws.

If you do not provide information requested by us, we may be unable to provide products or services, process your application or comply with our legal obligations.

We collect personal information about you directly from you – this can be in person, in documents you give us, from telephone calls, emails or from transactions you undertake with us.

We may also collect your personal information from third parties including public sources, your adviser(s), agents, referrers, brokers, our related companies and service providers (including AML/CTF verification providers, registry providers, trustees, regulators, government agencies, public registers, publicly available sources, credit reporting bodies and information service providers). Where reasonable and practicable, we will notify you where personal information is collected from third parties.

We keep personal information in physical and electronic records, including at our premises and with service providers. Electronic records may be stored in our IT systems, cloud platforms, investor portals and third-party systems located in Australia or overseas.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps may include premises security, secure storage, electronic access controls, network security, firewalls, staff training, confidentiality obligations, internal policies, monitoring, and contractual arrangements with service providers requiring appropriate privacy and security safeguards.

If we become aware of a data breach that is likely to result in serious harm, we will comply with our obligations under applicable privacy laws, including notifying affected individuals and the Office of the Australian Information Commissioner where required.

We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints.

We use personal information about you for the purpose for which it was provided to us, including to:

• process applications for investments in our managed funds;
• administer and manage our products and services (including monitoring, auditing, and evaluating those products and services); and
• maintaining investor registers;
• operating our website and investor portal;
• risk management and fraud prevention;
• system administration and business improvement; and
• communicate with you and deal with or investigate any complaints or enquiries.

We may also use your personal information for related purposes which would reasonably be expected without your permission.  For example, we may from time to time use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, you may opt out of receiving direct marketing communications at any time by using the unsubscribe facility in the communication or by contacting us using the details in this policy.

While we may sometimes share personal information with companies we do business with (e.g. in product development, joint venture arrangements or distribution arrangements), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.

We may disclose your personal information to:

• other members within the Skybound group of companies;
• trustees, custodians, fund administrators, unit registry providers, payment providers and other service providers involved in the establishment, operation, administration or management of our products and services;
• your adviser, broker, authorised representative, attorney, accountant or other professional representative;
• auditors, accountants, legal advisers, tax advisers, compliance consultants, valuers, property managers, insurers and other professional advisers;
• AML/CTF, KYC, identity verification, sanctions screening, credit reporting, information broking and research service providers;
• banks, financial institutions, payment processors and debt collection providers;
• technology, website, data hosting, cloud storage, analytics, document management, mailing and communications service providers;
• government agencies, regulators, law enforcement bodies, courts, tribunals, external dispute resolution bodies and other persons where required or authorised by law;
• prospective purchasers, investors, financiers or counterparties in connection with an actual or proposed transaction involving Skybound, its assets, business or products and services; and
• other third parties where you have consented or where disclosure is otherwise permitted by law.

Where we disclose personal information to overseas recipients, we will take reasonable steps to ensure those recipients handle the information in accordance with the Australian Privacy Principles unless an exception under the Privacy Act applies.

We take reasonable steps to ensure that all information we hold is accurate, up to date, complete and relevant for the purposes for which it is used or disclosed. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

We use security procedures and technology to protect the information we hold. Access to and use of personal information within Skybound seeks to prevent misuse or unlawful disclosure of the information – this includes internal policies, training and monitoring of staff.

If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.

We retain personal information for as long as reasonably necessary for the purposes for which it was collected, including to provide services, administer investments, maintain records, respond to queries or disputes, and comply with legal, regulatory, accounting, tax, Corporations Act, AML/CTF and other record-keeping obligations.

When personal information is no longer required for any purpose for which it may lawfully be used or disclosed, we will take reasonable steps to destroy or permanently de-identify it, unless we are required or authorised by law to retain it.

When you use our website, we may collect information about your use of those services, including IP address, device information, browser type, pages visited, time and date of visits and other usage data.

We may use cookies and similar technologies to operate secure areas of our website, authenticate users, remember preferences, analyse traffic, improve functionality, manage communications and understand how users interact with our services. You can configure your browser to reject cookies, but this may affect website functionality.

Where you access our website from a personalised communication, we may be able to identify you and combine website usage information with other information we hold about you.