Privacy Policy

About

This Privacy Policy outlines how Advance VC Pty Ltd and Advance VC Investments Pty Ltd (“we”, “us” or “our”) complies with the Privacy Act 1988 (Cth) (“Privacy Act”) and the 13 Australian Privacy Principles (“APPs”). It is intended to ensure that individuals outside of our organisation — including visitors to our website, clients, potential clients, personnel of service providers or suppliers, and others who interact with us online or offline — understand the types of personal data we collect, how we collect it, what we use it for, and with whom we may share it.

“Personal data” means any information relating to you, such as your name or contact details, but does not include data where your identity has been removed (e.g. anonymised or aggregated data).

Types of Personal Information

In the course of providing products and services, we may collect and hold information that is reasonably necessary for the performance of our functions and activities, including maintaining a registry of investor details and fulfilling regulatory obligations. This information may include, but is not limited to:

• Names, addresses 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 your Tax File Number, where relevant and permitted).

We may collect Sensitive Information about you, with your consent. Sensitive Information includes information about your racial or ethnic origin, political opinions, religion, trade or professional associations or memberships, sexual orientation, criminal record, health or biometric data.

Where you consent, your Sensitive Information may be used and disclosed for purposes that are directly related to the reason it was collected, including:

• Maintaining a comprehensive company file;
• Internal data compilation and analysis;
• Anonymised data sharing with third parties; or
• As required or authorised by law.

Collecting and Holding Your Personal Information

Where reasonable and practical, we collect personal information directly from you. This may occur via application forms, email, our website, online forms, in-person meetings, or financial transactions. We may also collect information from third parties or publicly available sources where direct collection is impractical.

We may use cookies on our website to collect information about your use of our site and other technical data (such as IP address, browser type, time zone, and location). This may enable third parties, such as Google and other providers, to show our ads on other websites as part of remarketing campaigns. If you provide personal information via our website, it may be linked to cookie data.

We may also use technologies such as web beacons (also known as clear GIFs) to monitor site usage or serve cookies.

Your personal information may be stored in various formats, including electronic databases and physical files, and will be held only as long as is reasonably necessary for the purpose it was collected or to meet legal obligations. We apply reasonable security safeguards to protect your data from unauthorised access, misuse, or loss.

Where practicable, we may allow you to interact with us anonymously or using a pseudonym.

Use of Your Personal Information

We use your personal information only for purposes that are reasonably necessary for our operations or for related secondary purposes that would be reasonably expected, or where you have given consent. These uses include:

• Assessing applications and providing financial products or services;
• Fulfilling legal and regulatory obligations;
• Conducting our administrative and operational functions;
• Communicating with you about our offerings.

Where required by the Privacy Act, we will obtain consent or notify you prior to other uses.

This policy does not apply to employee records held by Advance VC in relation to current or former employees.

Disclosure of Your Personal Information

We do not routinely disclose your personal information to third parties unless:

• You have provided consent;
• Disclosure is reasonably expected in the context;
• Required or authorised by law;
• A permitted general situation under the APPs applies.

We may disclose your personal information to:

• Our employees and contractors;
• Australian Financial Services licensees we are affiliated with;
• Our fund administrator;
• Accounting and legal service providers;
• CRM and email communication platforms;
• Software and SaaS providers used in fund management operations.

We take reasonable steps to ensure these parties manage your data in accordance with the Privacy Act and the APPs.

We may use Google Analytics and other similar platforms to collect usage data. For more on how Google uses data, see: https://www.google.com/policies/privacy/partners/

Our website may contain links to external websites. We are not responsible for the privacy practices of third parties and recommend reviewing their policies.

We may also share non-personal, de-identified, or aggregated data for research or promotional purposes. We do not sell or trade personal information.

Disclosure Outside of Australia

In certain cases, we may disclose your personal information to the ATO and/or ASIC, which may exchange this data with overseas regulators as required under the Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA).

Additionally, your information may be disclosed to overseas third-party service providers. You acknowledge that we are not required to ensure that these entities comply with Australian privacy laws.

Access, Correction, and Restriction

You may request access to or correction of the personal information we hold about you by contacting us at the details below. We will assess your request and respond within a reasonable timeframe (typically within 30 days). If your request is declined, we will explain why and, where appropriate, allow you to attach a statement of correction to your records.

You may also request to restrict or opt out of marketing communications using the contact details below or the opt-out functionality provided in our emails.

Complaints

If you believe we have breached the APPs or mishandled your personal information, you may submit a written complaint to us at the contact details provided below. Please include sufficient details to allow us to investigate.

We will respond in writing within a reasonable timeframe (usually within 30 days). If you are not satisfied with our response, you may escalate the complaint to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au

We do not charge a fee for access, correction, or complaints.

Contacting Us

If you have any queries about this Privacy Policy or your personal information, please contact:

Max Kausman

Email: max@advancevc.com

Changes to this Privacy Policy

We may update this Privacy Policy at any time. Any changes will be effective immediately.