Privacy Policy

Scope

1. This privacy policy relates to Tanarra Capital Pty Ltd ABN 57 604 388 892 and its related bodies corporate, including Tanarra Capital Australia Pty Ltd ABN 88 114 164 331 (collectively, Tanarra, Manager or TCA).
2. The policy explains how Tanarra collects, holds, uses, discloses and protects your personal information. It also explains how you may update your personal information that Tanarra holds and how you may make a complaint about how Tanarra has handled that personal information.
3. By accessing Tanarra’s website, investing in financial products in Tanarra funds or investments, or using Tanarra’s services, you consent to Tanarra collecting, holding, using and disclosing your personal information as described in this policy.

Collection of personal information

1. The information that Tanarra collects depends on the nature of your interaction with Tanarra. If you invest in funds or other financial products made available by Tanarra, personal information about you, such as your name, address, date of birth, contact details (including email address), occupation, bank account information and, potentially, tax file number, is collected through our documents, such as fund application forms and mandate letters and agreements.
2. When you access Tanarra’s website, Tanarra may collect technical and navigational information, such as device type, browser type, internet protocol addresses, pages visited, average time spent, user journeys and demographics and the time and date of access. Such information is collected anonymously and is used by Tanarra to analyse the efficiency of its marketing and publicity efforts as well as the design and functionality of the website.
3. Tanarra may collect your name, investor number, address, phone number, email address and postcode when you complete or sign up to publications available on or through this website or indirectly through emails, forms, face-to-face or electronic meetings, registration and attendance at seminars, business cards, online inquiries and telephone conversations, as well as through the website, blogs and social media channels which may involve the use of cookies. You should be able to control your browser setting to limit or exclude the collection of cookies by Tanarra; however, if you do so, you may not be able to use certain features of the website. The information is used by Tanarra to provide you with online access to details of your investments with Tanarra or to provide you with information, educational material, publicity and marketing material.

Use of personal information

1. If you invest with a Tanarra fund or investment, we use your personal information to establish and administer your investment, comply with applicable laws, including the Anti-Money Laundering and Counter-Terrorism Financing Act and Rules and to communicate with you in relation to your investments.
2. Tanarra may also use your personal information for the primary purposes for which it was collected, including:
   1. (a) the provision of educational, promotional and marketing material;
   2. (b) the provision of Tanarra’s services; and
   3. (c) assisting Tanarra to manage, develop and enhance its services, including this website, Tanarra reports and publications.
3. Tanarra may also use your personal information for other purposes to which you consent or which are required or permitted by law. This may include for a secondary purpose that is related to a purpose for which Tanarra collected it, and for which you would reasonably expect Tanarra to use.
4. If at any time you would like to unsubscribe from receiving future content, surveys, features or other marketing material or communications, Tanarra includes in all electronic messages a statement to the effect that you, as the recipient, may send an unsubscribe message to Tanarra using the contact details in that electronic message. Otherwise, you can contact Tanarra’s privacy officer at any time at the contact details below to unsubscribe or to update your preferences.
5. Tanarra does not actively seek to collect sensitive information, such as health information or information about criminal records, unless it is required by law, or for business purposes. If Tanarra does have to collect sensitive information, Tanarra will only collect, use and disclose the information in accordance with applicable privacy laws.

Disclosure of personal information

1. Tanarra may disclose your personal information (including in certain limited circumstances, your sensitive information) to:
   1. (a) a member of the Tanarra group (ie, any related body corporate of Tanarra Capital Pty Ltd);
   2. (b) Tanarra’s external service providers that provide investment administration, registry, custody, hosting, data storage or other services;
   3. (c) any entity with which Tanarra jointly or co-invests;
   4. (d) any external party you authorise, such as a licensed or authorised financial adviser, dealer group or operator of an investor directed portfolio service;
   5. (e) any party where Tanarra is required or authorised to do so by law; and
   6. (f) Courts and tribunals as well as governmental or regulatory bodies and agencies, such as ASIC, the ATO, AUSTRAC or a law enforcement body or agency.

1. Tanarra uses third party investment administrators and registries to support the administration of Tanarra funds and other investments. Tanarra has contractual arrangements with these service providers to ensure they comply with privacy laws when dealing with your personal information.
2. Tanarra may provide links to websites operated by third parties. Tanarra makes no representations or warranties in relation to the privacy practices of any third party or third-party website and Tanarra is not responsible for the privacy policies or the content of any third party or of any third-party website. If you visit a third-party website, including through a link on this website, the third-party website will be governed by its own terms of use, including privacy policies.

Accessing and correcting personal information

1. If you require access to, or wish to update or correct your personal information, please contact Tanarra’s privacy officer:
   

   Business Address	Level 13, 8 Exhibition Street Melbourne VIC 3002
   Mail	As above
   Telephone	(03) 8656 5700
   Email	margaret.lesnik@tanarra.com
   Privacy Officer	Margaret Lesnik

2. If you believe that your personal information that Tanarra holds is inaccurate, incomplete or out-of-date, you should contact Tanarra’s privacy officer at the above details to correct the information. Tanarra will require you to verify your identity and to specify what information you wish to have access to.
3. Tanarra will endeavour to promptly update any personal information that is inaccurate, incomplete or out-of-date. If Tanarra does not agree that the personal information is inaccurate, incomplete or out-of-date, Tanarra will notify you in writing of the reasons to refuse any correction or update. Tanarra will also notify you of what you can do if you are not satisfied with Tanarra’s response.

Protecting personal information

1. Tanarra will take reasonable steps to protect your personal information that we hold from misuse, loss, unauthorised access, interference, unauthorised modification or unauthorised disclosure.
2. Tanarra has physical, electronic and procedural safeguards to protect such personal information, for example by use of physical security and restricted access to electronic records. Access to information stored electronically is restricted to Tanarra employees whose job purpose requires access. Tanarra also requires all employees to maintain the confidentiality of client information except as otherwise required by law.

Eligible data breach

1. Tanarra’s service providers are required to notify Tanarra of any unauthorised access to, or disclosure or loss of, personal information.
2. In such a circumstance, Tanarra performs an assessment to determine if there has been an ‘eligible data breach’ whereby the access or disclosure of the personal information is likely to result in serious harm to the individuals to whom the information relates. If Tanarra determines there has been an ‘eligible data breach’, then the individuals affected will be notified as soon as practicable of the details of the breach and the recommended steps to take in response to it. If required, Tanarra will also inform the Office of the Australian Information Commissioner at the same time.

Privacy related complaints

1. If you have any questions about privacy-related issues or wish to complain about a breach of your privacy or the handling of your personal information by Tanarra, please contact Tanarra’s privacy officer (details above).
2. Tanarra may ask you to lodge your complaint in writing
3. Any complaint will be investigated by the privacy officer and you will be notified of the making of a decision about your complaint as soon as is practicable after it has been made, usually 30 days.
4. If Tanarra is unable to resolve your complaint satisfactorily or your concerns about Tanarra’s handling of your personal information, you can contact the Office of the Australian Information Commissioner:
   GPO Box 5218
   Sydney NSW 2001
   Email: enquiries@oaic.gov.au
   Tel: 1300 363 992
   www.oaic.gov.au

Updates to this policy

1. Tanarra will review this policy from time to time to take account of new laws and technology, changes to Tanarra’s operations and practices, and the changing business environment.
2. The most current version of this policy is located at tanarra.com.au and can also be obtained by contacting Tanarra’s privacy officer at the above address.