Privacy
About
This Privacy Policy details our commitment to protecting the privacy of personal information provided to us or otherwise collected by us from providing our products and services. This includes information provided or collected from visitors to our website, clients, potential clients, personnel of service providers and other people we interact with. This includes people who contact us via our website or correspond with us by other means (including phone and email).
This Privacy Policy applies to OIF Ventures Manager Pty Limited (ABN 68 154 200 996) and all of its subsidiaries and affiliates.
Personal information we collect
“Personal information” means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
The type of personal information we collect includes:
- Identity information: including names, date of birth, address, photographic identification, gender, pronouns and titles;
- Contact information: including telephone number, address and email;
- Financial information: including bank account and payment card details;
- Background verification information: including your government-issued identification details (such as your TFN or passport information) and any information and documents required for Anti Money Laundering and Counter Terrorism Financing checks;
- Technical and usage data: including information about when you access any of our websites, login data, browser session and approximate geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies or analytics), and communications with our website;
- Submitted information: information you provide to us via forms, surveys, promotions, activities, events or participation in other interactive features; and
- Marketing and communications data: including your preferences in receiving marketing from us and our third parties and your communication preferences; and
- Professional information: including employer and job title, career history, qualifications, and if you are applying for a role with us, visa status and any other information we need to employ and onboard you including background checks.
“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.
Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Unless otherwise permitted by law, we will only collect sensitive information with your consent.
How we collect and hold your personal information
We collect personal information in a variety of ways:
- Directly: you may provide personal information directly to us including by submitting forms, requesting our assistance via the website, email, phone or our social media accounts (e.g. LinkedIn), or registering for events we are hosting;
- Indirectly: you may indirectly provide us information when interacting with us, such as when you use our website, in emails, over the phone and in your online enquiries; and
- Third parties: we may also collect personal information from third parties or independent sources (including from publicly available sources such as LinkedIn, from businesses in our network, from third parties we engage to conduct background checks or AML/CTF checks, and details of your use of our website from our analytics and cookie providers and marketing providers.
How we use your personal information
We only collect personal information if it is reasonably necessary for our functions or activities (the primary purpose) or for related secondary purposes that would be reasonably expected by you, or to which you have consented.
We may collect, hold, use and disclose personal information for the following purposes:
- Financial services: to provide you with one or more of our financial products or services, including to process an investment application, manage our relationships with you and administer your investments with us, to provide you information about our funds, products and services, and to assess whether to take you on as a new investor (including to perform AML/CTF checks, sanction screening and other “Know Your Customer” checks on you);
- Investment services: to assess investment opportunities, conduct due diligence, undertake transactional steps, to administer our investments, and to provide advice, support and ongoing commercial assistance;
- Legal: to fulfil our legal and regulatory obligations;
- Administrative: for internal record keeping, administrative, invoicing and billing purposes;
- Analytics: for advertising and marketing, for market research and business development, including to send promotional information about information that we consider may be of interest to you; and
- Employment: if you have applied for employment with us, to consider your employment application.
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;
- 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.
We may disclose personal information (excluding sensitive information) to:
- our employees, contractors and/or related entities;
- cloud-based IT service providers, data storage, web-hosting and server providers (such as Sharepoint, Affinity and Automic). As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed in this policy;
- service providers who assist with background checks and AML/CTF verification and store such information (such as Veremark, Infotrack and FirstAML);
- generative AI services (such as Claude) to review and analyse the information for the primary purpose for which it was collected or a secondary purpose that would be reasonably expected by you (such as summarising business materials to assist us with forming an investment decision);
- marketing or advertising providers;
- professional advisors, bankers, auditors, lawyers, accountants, financial institutions, our insurers and insurance brokers;
- payment systems operators and processors (such as Xero);
- our existing or potential agents or business partners;
- to our portfolio entities or other entities or persons where we are introducing you to them;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties to collect and process data, such as analytics providers and cookies;
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Disclosure of your personal information to overseas recipients
Your personal information may be transferred outside of the country in which you are located.
If you are based in Australia, unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.
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.
Your right of access, correction and restriction
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not it may affect our ability to provide our services to you and your use of our services.
Access:
- 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.
- When you make a request to access personal information, we will require you to provide some form of identification (e.g. driver’s licence or passport) so that we can verify that you are the person to whom the information relates.
Correction:
- 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.
- 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.
Restrict and unsubscribe: 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.
Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Complaints
If you wish to make a complaint, you may do so by providing your written complaint 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 promptly investigate your complaint and respond in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint.
If you are not satisfied with our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner.
Storage and security
We are committed to ensuring that the personal information we collect is secure. We hold your personal information:
- in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers; and
- 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.
In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
How to contact us
You can contact us about this Privacy Policy or about your personal information by contacting our Privacy Officer:
- By emailing: legal@oifvc.com
- By writing to our office at: OIF Ventures, Level 2/30-36 Bay St, Double Bay NSW 2028
Changes to our privacy policy
This Privacy Policy is subject to change at any time. We may, at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. The amended policy will apply between us whether or not we have given you specific notice of any change.