March 29, 2021

Solido Capital Partners Pty Ltd – Privacy Policy

This is the Privacy Policy for Solido Capital Partners Pty Ltd (ACN 615 299 922).  It applies to us in our capacity as trustee, administrator and investment manager of the various trusts to which we are a service provider as well as in our personal capacity.

Solido Capital Partners is bound by the Privacy Act, its Amendment (Enhancing Privacy Protection) Act and its Privacy Amendment (Notifiable Data Breaches) Act.  We will protect your personal information in accordance with the Australian Privacy Principles.  These principles govern how we can collect, use, hold and disclose your personal information when you invest with us in any of our Managed Investments Schemes (MIS).  They also govern how we respond when a data breach is likely to result in serious harm to any investors whose personal information is involved in the breach.

You are not required to provide us with your personal information but if you do not do so we may not be able to provide you with our products or services.

If you apply for or accept any of our products or services or otherwise provide us with your personal information, you agree to your information being collected, held, used and disclosed as set out in this Privacy Policy.  We may revise this Privacy Policy from time to time by placing the revised Privacy Policy on our website or otherwise notifying you of the change.

What kinds of personal information do we collect and hold?

When you apply for an interest in any of our MIS we may collect information that is necessary to process your investment application, for the purposes of administering your ongoing participation in the scheme and to comply with relevant legislation.

For instance, we may ask for:

  • your full name, date of birth, gender and contact details including telephone, address, e-mail and fax;
  • a copy of your driver licence and/or passport or other identification documentation;
  • your tax file number (TFN) and bank account;
  • your investor contribution details and investment choice;
  • details about authorised signatories on your investments or accounts with us;
  • detailed contact information about your financial adviser; and
  • copies of any relevant trust deeds, partnership agreements or constitutions and other information which may be relevant.

It may on occasion also be necessary to obtain other details, including information relating to powers of attorney or for probate and estate administration.

Why do we collect, hold, use and disclose personal information?

The main reason we collect, use, hold and disclose personal information is so we can service your application and manage your participation in our MIS.  This may include, but is not limited to:

  • Confirming your identity and complying with AML/CTF requirements;
  • Checking your eligibility to invest in Solido Capital Partners MIS;
  • Processing your investment application;
  • Ensuring that income distributions are paid into your correct bank account;
  • Providing you with information about the status of your investment in MIS;
  • Helping you manage your interests in one or multiple MIS;
  • Administering tax requirements including reporting and withholding; or
  • Assisting you to call a meeting of fellow investors in MIS.

How do we collect personal information?

We collect most personal information directly from you.  Sometimes we collect personal information about you from other people.  This may include publicly available sources of information such as the Australian Securities & Investment Commission (ASIC) or it may include others such as:

  • your financial adviser or broker;
  • authorised representatives, such as executors or administrators; or
  • identification verification service providers.

How do we hold personal information?

The personal information we hold is stored electronically in our online data storage system and in paper files, secured by us at our registered office.  We use a range of security measures to protect the personal information we hold.

To whom do we disclose your personal information and why?

Sometimes we may disclose your personal information to organisations outside Solido Capital Partners.  For example, the accountants and auditors of the MIS so that they may perform their duties for the Fund.

Where an investor seeks to call a meeting of investors in a particular MIS we will provide them with your contact details so that they may contact you and other investors for the express purpose of arranging the meeting.

Whom do we notify when there is a data breach of your personal information?

In accordance with the Notifiable Data Breaches scheme under the Privacy Act, we are obliged to notify investors whose personal information is involved in a data breach that is likely to result in serious harm (these are referred to as ‘eligible data breaches’).  This notification must include recommendations about the steps investors should take in response to the breach.  The Australian Information Commissioner (Commissioner) must also be notified of eligible data breaches.

In summary, subject to certain exemptions, the scheme requires us to:

  • carry out a reasonable and expeditious assessment if there are reasonable grounds to suspect that there may have been an eligible data breach (and to take reasonable steps to complete that assessment within 30 days); and
  • make the prescribed notifications (to the Commissioner and if practicable to affected investors) as soon as we are aware that there are reasonable grounds to believe that there has been an eligible data breach. The notifications must include a description, the kinds of information concerned and recommendations about the steps investors should take in response to the data breach.

Do we disclose personal information overseas?

We will only disclose personal information to parties overseas where we are satisfied that we are required by law to do so.

Do we use or disclose personal information for marketing?

We may use your personal information to offer you opportunities in future MIS that we believe may interest you.  We will not do this if you tell us not to.

If you don’t want to receive marketing offers, please contact us on the details listed at ‘Contact us’.

Access to and correction of personal information

You can request access to the personal information we hold about you.  You can also ask for corrections to be made.  To do so, please contact us on the details listed at ‘Contact us’.

Resolving your privacy concerns and complaints – your rights

If you are concerned about how your personal information is being handled or if you would like to make a complaint, please contact us on the details listed at ‘Contact us’.

If you are unhappy with our response there are regulatory bodies you can go to such as the Office of The Australian Information Commissioner: https://www.oaic.gov.au/

Contact us

If there is anything you would like to discuss, please contact us.

If you have any questions or concerns about our privacy policy or practices, please contact:

The Privacy Officer

[email protected]

 

Last Updated: 16 September 2020

This information is provided for information only.  It does not constitute an offer or invitation to enter into any legal agreement of any kind for units in our MIS.

Solido Capital Partners Pty Ltd, AFSL 501143, ABC 615 299 922.