Why are we providing this information?

This Privacy notice details how we comply with the requirements of the Privacy Act 1998 (Cth) and the 13 Australian Privacy Principles (“APPs””). The privacy notice is intended to ensure that individuals outside of our organisation with whom we interact, including visitors to our website, clients, potential clients, personnel of service providers or other suppliers and others who interact with us whether via our website or by corresponding with us by other means (e.g. by emailing or phoning us) are aware of the categories of personal data about them that AirTree Ventures Pty Ltd and its subsidiaries and affiliates (“we”, “us” or “our”) may collect, how we collect it, what we use it for and with whom we share it.

“Personal data” means any information relating to you, such as your name, contact details, but does not include data where you can no longer be identified from it such as anonymised, aggregated data.

What type of personal information do we collect?

In the course of providing our products and services we may collect and hold information that is reasonably necessary for the performance of our functions and activities, This information may include, but is not necessarily limited to;

• Names, address, and other contact details;
• Date of birth;
• Financial information;
• Nationality and country of birth;
• Data required for AML/CTF purposes; and
• Government identifiers (such as TFN where necessary and relevant).

We may collect Sensitive Information about you, with your consent. Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, health, political opinions, religion, trade union or other professional associates or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

Provided that you consent, your sensitive information may only be used and disclosed for purposes you have consented to or which are directly related to the primary purpose for which the sensitive information was collected, including (but not restricted to):

• For the purpose of us maintaining a comprehensive company file;
• For the purpose of data compilation or analysis for internal purposes; and
• In an anonymised format for the purpose of data compilation or analysis to share with third parties.

How we collect and hold your personal information

This is dependant upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.

Where possible we standardise the collection of personal information by using specifically designed forms (eg our application form). However, given the nature of our operations we often also receive personal information by email, through our website, online forms, letters, notes, in face-to-face meetings and through financial transactions.

We may also collect personal information from third parties or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly.

We may use cookies on our website from time to time. These cookies collect information about how you use our website and other technical data (such as your IP address, browser type and version, time zone settings and location), and allow third parties, such as Facebook, to cause our advertisements to appear on your social media and online feeds as part of our retargeting campaigns. If and when you choose to provide our website with personal information, this information may be linked to the data stored in the cookie.

• We hold your personal information: In a variety of formats including on databases, in hard copy files and on computer devices, including computers;
• Only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any application legal reporting or document retention requirements; and
• Using industry standard security methods and best practices to protect your personal information from unauthorised access, modification or disclosure and from misuse, interference and loss.
• Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

How we use your personal information

We only use personal information that is reasonably necessary for one of more of our functions or activities (the primary purpose) or for related secondary purpose that would be reasonably expected by you, or to which you have consented.

Our uses of personal information include, but are not limited to:

• Providing you with one of more of our financial products or services or products including to assess your application for a financial product or service;
• Fulfilling our legal and regulatory obligations;
• Performing our related administration and organisational functions and tasks; and / or
• To communicate with you about the products and services that we offer.
• If we collect, hold or use personal information in ways other than as stated in his policy, we will ensure we do so pursuant to the requirements of the Privacy Act.
• Employee records are not generally subject to the Privacy Act and therefore this policy may not apply to the handling of information about employees by AirTree.

When we disclose your personal information

We do not routinely disclose personal information to other organisations unless one or more of the following apply:

• You have consented;
• You would reasonably expect us to use or disclose your personal information in this way;
• We are authorised or required to do so by law;
• Where a permitted general situation under the SSP applies.
• We may also share non-personal, de-identified and aggregated information for research or promotional purposes. Except as set out in this policy, we do not sell to, or trade personal information with third parties.

This may include personal information to our employees, contractors and related entities, as well as third parties who supply services to us to assist us in performing our administration functions and in fulfilling our legal and regulatory obligations (e.g. legal and accounting firms, data storage systems and certain SaaS providers). We will take reasonable steps to ensure that they handle your personal information in the same way that we do and in accordance with the Privacy Act and the APPs.

We may use Google Analytics from time to time to collect and process data. To find out how Google uses data when you use third party websites or applications, please see here, or any other URL Google may use from time to time.

Disclosure of your personal information outside Australia

In certain limited circumstances, your personal information may be shared with the ATO, and / or ASIC which will then exchange this information with similar overseas regulatory bodies as a result of Australia’s participation in the Common Reporting Standard and Foreign Account Tax Compliance Act.

Where in accordance with this Privacy Policy, we disclose your personal information to third parties who reside outside Australia, you agree and acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.

Your right of access, correction and restriction

We will provide access to personal information upon request by an individual, except in the limited circumstances in which it is permitted for us to withhold this information (for instance, where granting access would infringe another personal privacy).

You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us in the manner outlined below.

You may also contact us if any of the details you have provided change or if you believe that the information we have about you is not accurate, complete or up to date.

When you make a request to access personal information, we will require you to provide some form of identification (eg driver’s licence or passport) so that we can verify that you are the person to whom the information relates.

If we do not agree to provide you with access or to correct your personal information you will be notified accordingly. Where appropriate we will provide you with the reasons for our decision and you may seek a review of our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.

You may also request that we restrict the use of your personal information for direct marketing purposes by contacting us using the contact details below. Alternatively, to unsubscribe from our email database or opt-out of communication including marketing communication) you may use the opt-out facilities provided in the communication or email us using the contact details below.

Your right of complaint

If you wish to make a complaint about a breach by us to the Australian Privacy Principles, you my do so by providing your written complaint by email, letter or personal delivery to any one of our contact details as noted below. Where possible, the complaint should include enough information to help us resolve it.

We will respond to your complaint in writing within a reasonable time (usually no longer than 30 days) and we may seek further information from you in order to provide a full and complete response.

If you are not satisfied with our response to a complaint, you may lodge a complaint with theOffice of the Australian Information Commissioner.

We do not charge for receiving a request for access to personal information or for complying with a correction request.

How to contact us

You can contact us about this Privacy Policy or about your personal information by;

• Emailing Helen Norton - helen@airtree.vc
• Writing to our Privacy Office at 131 Devonshire St, Surry Hills NSW 2010

Changes to our privacy and information handling practices

This Privacy Policy is subject to change at any time. The amended policy will apply between us whether or not we have given you specific notice of any change. Please check our Privacy Policy on our website.