This website (our Website) is owned and operated by Second Wave Corporation Pty Ltd (we, us, and our). We are bound by the Australian Privacy Principles set out in the Privacy Act which impose certain requirements on us with respect to handling personal information. We have implemented procedures to ensure personal information is handled in accordance with the Act.
We recognise your right to privacy and understand that the protection and confidentiality of your personal information is important to you.
Please read the following policy to learn more about the ways in which we protect, use and disclose your Personal Information. This Privacy Policy applies to all Personal Information we hold. By visiting the Website, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use our website.
This policy is effective as of 21/10/2020. We may update our Privacy Policy from time to time by posting a new version on our Website and it will be binding on you and us from the date it is posted on our Website, so please revisit the policy periodically
Why do we collect Personal Information?
We collect and hold Personal Information that is reasonably necessary for the services we provide.
What form of Personal Information do we collect? In the course of providing products and services we may collect names, date of birth, email and delivery addresses, contact number, job title, organisation with which you are affiliated as an employee, contractor or agent, payment details and other information provided by you.
If you correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.
How do we collect Personal Information?
We aim to collect your Personal Information in a fair and lawful manner.
We primarily collect this information when you complete an investment application to make an investment in the Fund, when you access websites operated by us, when you sign up or provide consent to be added to our email distribution list, and when you communicate with us and our service providers.
You do not have to provide us with your personal information, but if you do not provide us with the required personal information, we may not be able to provide our services to you.
How do we use your Personal Information?
We only collect, use and disclose Personal Information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a 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 or more of our financial services or products
- To assess your application for a financial product or service; and/or
- To communicate with you about the services that we offer and to provide investor updates
We may also need to collect Personal Information in order to comply with our legal obligations, such as the AML/CTF laws, under the Anti-Money Laundering and Counter Terrorism Financing Act 2006.
Who do we share your Personal Information with?
We recognize that privacy and confidentiality is important to our users. Where your Personal Information is disclosed to these third parties, they will only be authorised to use your Personal Information for the purpose that we supplied it to them and access to your Personal Information is restricted on a need-to-know basis.
We may disclose your information to:
- Certain service providers and we require those service providers to keep Personal Information confidential. For example, we may provide such information to the custodian or administrator of the Fund, and other persons to enable us to administer the financial products or financial services we provide to customers, including lawyers or auditors, fund registry and entities providing finance, insurance, maintenance, registration and other services;
- Courts, tribunals and other dispute resolution bodies in the course of a dispute;
- Anyone to whom we, or our service providers, are required or authorised by law or regulation to disclose your personal information (for example Government agencies such as the ATO, ASIC and AUSTRAC under corporations, taxation, social security, or anti-money laundering laws.)
Email distribution
If you have given us your express consent to provide you with email communication by signing up to our distribution list, we may collect, hold, use and disclose Personal Information in accordance with that consent to enable us to provide you information about our services.
If you give us consent to provide you with investor updates, you can later request not to receive such updates. Email communications also have an unsubscribe link for you to opt-out of such communications.
Cookies and data activity
We reserve the right to use a standard technology called ‘cookies’ to tell us how viewers use our website. Cookies are digital identifiers that may collect and store the type of browser you are using, the date and time of your visit, the country your service address came from, the pages viewed and any downloads made. We may also use external service providers to track the traffic and usage on the website. We do not use Cookies to store Personal Information about you.
You can set your browser to notify you when you receive a cookie and you can decide whether or not to accept it. Cookies can be turned off or deleted at any time through your browser settings.
How we ensure the quality of your Personal Information
We try to ensure the Personal Information we hold, use and disclose is accurate, complete and up-to-date.
On an ongoing basis we maintain and update Personal Information when we are advised by individuals or when we become aware through other means that their Personal Information has changed.
Updating and access to information
Please contact us if any of the details you have provided change and we will update your details accordingly.
You are able to request for access to your Personal Information in writing and we will provide you with access to that information. This is subject to exceptions allowed by law such as where providing you with access would have an unreasonable impact on the privacy of others.
If it is not possible for us to give you access in which case we will provide a written explanation as to why.
Storage and security of information
We store Personal Information in a variety of formats by storing it in our systems, on our servers and the servers of any third parties we may engage to store data for us, in hard copy files and on personal devices including computers.
The security of your Personal Information is important to us and we take all reasonable steps to protect the Personal Information we hold about you from misuse, loss from unauthorised access, modification or disclosure. We maintain physical, electronic and procedural safeguards to guard and secure investors’ personal information.
If there has been unauthorised interference to your Personal Information, and that interference is likely to result in serious harm to you (Data Breach); we will make any legally required disclosures to you about the Data Breach, consistent with the interests of law enforcement, and take any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Links to other applications and websites
Our websites may have links to external third party websites. External websites should contain their own privacy statements and we recommend you review them when using their websites. Third party websites are not covered by this policy, and these sites are not subject to our privacy standards and procedures.
Enquiries and complaints
If you have any concerns or complaints with respect to our administration of the Fund, please contact us and we will do our best to resolve it quickly and fairly.
If you have queries, complaints or requests regarding this policy, please contact the Manager