Overview

Quadrant Private Equity is an Australian private equityinvestment firm. Quadrant Private Equity, QPE Group Operations Pty Limited (ACN 165 056 431) and our related bodies corporate (QPE, we, us and our) recognise and understand the importance of your privacy and protecting the personal information that you disclosed to us and are committed to respecting your privacy.

With a view to protecting your personal information, we conduct our operations in Australia in a manner which complies with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act), by which QPE is bound.

QPE has put in place this privacy policy (Privacy Policy), which sets out how wecollect, use, store and disclose your personal information.

We may modify or amend this Privacy Policy from time to time. We will display a notice on our website indicating when any suchrevisions have been made.

Unless you notify us otherwise, we will assume that you have consented to the collection of all information which is provided to us for use in accordance with this Privacy Policy.

What Personal Information does QPE Collect?

Personal Information

“Personal information”has the meaning given to it in the Privacy Act, and means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. This may include information that could identify a person either directly or indirectly.

The personal information QPE collects depends upon our dealings with our clients, investors, prospective employees and other individuals who contact us, and the particular purpose that is being fulfilled through the collection of such personal information. QPE’s only collects personal information that is reasonably necessary for, or directly related to, QPE’s functions or activities, or where required by law.

Depending on the personal information that a person provides or shares with QPE, and the purposes for collection of personal information, the personal information that we collect includes (but is not limited to):

- your full name (current and former (if any)), date of birth and citizenship;
- your personal and business contact details (including your address, telephone numbers, e‐mail address and fax numbers);
- your government identity documents, including driver’s license and passport numbers;
- your employment details (including your company name, job title, department and business sector);
- banking and tax details (including your tax file number and ABN if applicable, and information relating to transactions and payments exchanged by QPE);
- contact and identification details of any third party who acts on your behalf (including any agents or attorneys appointed by you under a power of attorney);
- identification details of your family members or any other beneficial owners of yourinvestment (for example, where family members are the beneficiaries of your investment vehicles such as through a family trust);
- your estate (e.g. if you die while you are the owner of interests in an investment fund with us, we may need to identify your legal personal representative to manage your assets);
- further details about you (including your educational background, work history and qualifications); and
- any other personal information provided to us when you request information or correspond with us.

Generally, we collect greater personal information in relation to investors, including some information that we are required to collect by law (including AML/CTF, taxation and company laws). Unless you are engaging with usas an investor, we generally do not collect sensitive information about you.

Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, if you contact us with a general enquiry, we will not ask for your name unless we need it to adequately handle your enquiry. However, generally speaking, it is not possible for us to enter into a business relationship or carry out commercial transactions with you without your personal information.

How Does QPE Collect Personal Information?

Generally, we try to collect personal information directly from you. For example,when you:

- call, write or email us;
- provide us with your personal information, such as your contact details, business card or other documents containing your personal information;
- apply to invest in one of our funds;
- meet with us in person; or
- contact us via our website’s contact form.

QPE may also collect personal information from other sources, including publicly available sources or from third parties that we deal with, such as:

- the companies we invest in;
- your business partners;
- other representatives;
- recruitment agencies;
- referees nominated by prospective employees;
- your or our authorised agents or professional advisors (such as lawyers, insurers, auditors or financial advisors); and
- other entities, as consented by you.

Where we collect personal information from third parties you refer to us, we will assume, and you will ensure, that you have made that third party aware of the referral and the purposes of collection, use and disclosure of the relevant personal information.

For What Reason Does QPE Collect, Use and Disclose Personal Information?

We collect, use and disclose your personal information to assess your application, service your needs as a client or investor, provide facilities and services to you, respond to your questions or suggestions and communicate with you, and for other purposes permitted under the Privacy Act.

Tax and company laws also require some of the information to be collected in connection with your application. If you do not provide the information requested, your application may not be able to be processed efficiently, or at all.

We may also collect, use and disclose your personal information so that we can:

- accept, administer and manage your investment;
- provide advice on your investment;
- communicate with you during the course of your business with us;
- carry out any other activities which relate to any investments or requests made by you;
- notify you about important changes or developments to our functions, activities or our services;
- inform you about business or investment opportunities;
- resolve any complaints you may have, if you lodge a complaint with us;
- assess job applications and manage prospective employment relationships;
- meet our legal and regulatory obligations where a regulator requires us to maintain certain records of our dealing with you, disclose any information or take any action; and
- for administrative purposes, for example maintaining accounting records, analysing financial results and meeting internal audit requirements.

However, without your consent, we will not:

- use your name, address or other identifying information in advertising, publicity or otherwise;
- represent that any product or any service has been approved or endorsed by you; or
- disclose any relationship with you using your name.

Direct Marketing

We may from time to time, communicate with you directly to promote opportunities or events. When we send you such communications, we will advise how you may unsubscribe or opt out of receiving these communications. You may, at any time, request not to receive direct marketing communications from us and we will comply with that request.

Disclosure

We may disclose personal information to:

- our related bodies corporate;

- our shareholders;

- financial institutions (for payment processing);

- service providers used by us to assist in providing services to us or you (such as contractors who provide IT, administration, human resources, payroll, training and other services to support us), on the basis that they deal with such information in accordance with this Privacy Policy;  

- agencies we engage for identity verification, data processing and other support functions;

- our professional advisers (e.g. our insurers, auditors, lawyers, accountants and consultants);

- your authorised agents or professional advisors;

- foreign and domestic government entities and regulators as required by law (e.g.the Australian Taxation Office); and

- other entities with your consent.

We may also disclose your personal information as permitted or required by law.

These entities may in turn disclose personal information to other entities as described in their respective privacy policies.

How QPE Holds and Protects Personal Information it has Collected

We take reasonable steps to ensure that the personal information that we hold (both electronically and physically) is kept confidential and secure and we endeavour to prevent unauthorised access, disclosure and loss of your personal information. We protect your personal information through:

- having a robust physical security of our premises and databases / records;
- having technological measures, such as computer passwords, firewalls, data back-ups, spamfilters and anti‐virus protections; and
- implementing user access controls and password protection for accessing our electronic ITsystems, including restricting access to personnel who need that information inorder for QPE to be able to provide our products and services to you.

In the unlikely event of a suspected data breach, we will assess the breach to determine whether it is likely to result in serious harm to any of the individuals to whom the information relates. In which case, we will notify the individual(s) at risk of serious harm and the Office of the Australian Information Commissioner as soon as practicable.

QPE monitors the measures it takes to ensure the protection and proper management of personal information are sufficient. This may include monitoring logs of employee actions (e.g. login and authentication to access QPE systems) and employee use of QPE property. In addition, QPE monitors files, programs and processes that run on QPE managed devices, to prevent malicious code.

Transfer of Personal Information Outside of Australia

Some QPE systems may require the transfer, storage or access of personal information outside of Australia. QPE ensures that service providers transferring, storing or accessing personal information from outside of Australia protect information in line with Australian legal requirements,and only use personal information for purposes agreed by QPE.

QPE may transfer information to service providers located in the United States and Singapore. QPE may also be required by law to disclose information to authorities overseas.

Data Retention and Disposal

We hold your personal information for as long as such information is required for us to provide you with our products or services, or otherwise assist you. If we have a business relationship with you, this will be for the duration of our business relationship. After the date of termination of this business relationship, we are required by law to retain the records for 7 years from the date oftermination. We will take reasonable steps to destroy, delete or de‐ identify your personal information in a secure manner once we no longer require this information.

Access and Correction

It is important that the personal information we hold about you is complete, accurate and current. You have a right to request access to and correction of any personal information that we hold about you.

Accessing your personal information

You can request access to the personal information we hold about you by contacting us using our details provided below. We will respond to a request for access within a reasonable period after the request is made, either by giving you access to the personal information requested, or by notifying you of our refusal to give access. We may request to verify your identity before responding to any request. If we decide not to provide you with access to or make a correction to your personal information, we will give you reasons for our decision.

Correcting your personal information

If you believe that the personal information we hold about you is inaccurate, out‐of‐date, incomplete, irrelevant or misleading or otherwise needs to be corrected or updated, you can request that we correct your personal information using our contact details provided below. We will respond to a request to correct your personal information within a reasonable period after the request is made and notify third parties to which we have provided the information. We may need to verify your identity before making the correction. If we refuse your request, we will give you reasons for our decision in writing.

Complaints

If you wish to lodge a complaint about how we handle your personal information, please contact us using the contact details below. Please note that we may ask you to lodge your complaint in writing and to verify your identity. We will acknowledge receipt of your complaint as soon as possible after receiving your complaint. We will investigate your complaint and provide you with a response within a reasonable timeframe.

If you are dissatisfied with our response, you have the right to make a complaint to the Office of the Australian Information Commissioner by:

- phoning 1300 363 992 or;

- email at enquiries@oaic.gov.au.

Contacting us

If you wish to contact us regarding our handling of your personal information or any of the matters covered in this Privacy Policy, please contact us:

Address:          Level 30, 126 Phillip Street, Sydney, NSW 2000

Email:               quadrant@quadrantpe.com.au

Telephone:      +61 (02) 9221 3044 

Last updated:  12 April 2024