PRIVACY POLICY

1. POLICY STATEMENT

This privacy policy (Privacy Policy) applies to Allegro Funds Pty Ltd ACN 128 866 053 (AFSL 345995) (Allegro and we), the related bodies corporate of Allegro and the fund entities managed or advised by Allegro and their affiliates. This policy outlines how we manage your personal information, including how it is collected, used, and disclosed. By using our services, you agree to the terms described herein. Additional privacy disclosures relating to your personal information may also be contained in certain Allegro documents, such as our subscription agreements.

 

2. APPLICATION OF THE POLICY

Allegro is committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) established under the Privacy Act. Please read this Privacy Policy carefully. By providing us with personal information (by any means, whether verbal, written or electronic and either directly or through others, including through Allegro’s website), you agree to Allegro collecting, retaining, using and disclosing your personal information in accordance with the terms set out in this Privacy Policy.

 

3. WHAT IS PERSONAL INFORMATION?

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not, and includes sensitive information.

Generally, we will seek consent from the individual in writing before we collect their sensitive information.

 

4. TYPES OF INFORMATION WE COLLECT AND HOLD

The types of personal information Allegro may collect, hold, use and disclose will depend on the nature of your relationship with us, but may include:

  • Investors and their Associates: We collect the following information:
    • your name, address, personal and business contact details, date of birth, gender, nationality;
    • identification details, such as driver’s licence, passport, tax identification, ABN or social security numbers);
    • personal financial and banking information;
    • details about your advisors;
  • Advisors and Other Service Providers: We collect the following information: name, address, personal and business contact details;
  • For Employment Applicants (for both Allegro Funds and Portfolio Companies): We collect the following information:
    • names, addresses, personal/business contact details, nationality and country of birth;
    • information from your CV, including professional qualifications, memberships, work experience and education; and
    • character and background checks including in relation to your vocational suitability, identity, health, references, directorships, financial probity and criminal record;
    • any other relevant details you provide during the employment application process.

Employee records are not generally subject to the Privacy Act and therefore this Policy may not apply to the handling of employee information by Allegro. This Privacy Policy will apply to the employees of Allegro only to the extent that the collection, holding, use or disclosure of that personal information does not fall within the definition of an exempt practice pursuant to section 7B(3) of the Privacy Act.

We collect and retain some of this personal information under laws including the Corporations Act, Fair Work Act, Superannuation Guarantee (Administration) Act, Income Tax Assessment Act and Anti-Money Laundering and Counter-Terrorism Financing Act.

 

5. WHY DO WE COLLECT AND HOW DO WE USE YOUR PERSONAL INFORMATION

Allegro may collect personal information in a number of ways, including directly from you, from third parties, such as your authorised advisors, agents or attorneys, from publicly available sources, and by analysing our records of your use of our services and website. To operate our business as a private equity firm, we collect, retain, use, and disclose personal information for various purposes, including

  • administrative purposes, including to maintain our records and to verify identity
  • managing relationships with various stakeholders, including communications and providing and improving our services and gaining insights into our stakeholders’ preferences and interests
  • managing our investment portfolio and collaborating with investee businesses
  • identifying, facilitating, and advising on investments and fundraising opportunities
  • recruiting, training, and overseeing staff
  • ensuring compliance with all applicable regulatory, tax or legal requirements, including the requirements of regulatory bodies relating to applicable anti-money laundering and counter-terrorism laws and regulations
  • safeguarding our rights and property, as well as those of third parties.

If you do not provide requested personal information, or provide incomplete or inaccurate details, this may: result in a non-compliance with taxation, anti-money laundering, or financial services licensing laws; affect our ability to accept your investment; or prevent us from contacting you. We will take all reasonable steps to ensure that the personal information we collect, hold, use and disclose is accurate, up-to-date, complete, relevant and not misleading.

 

6. STORAGE & SECURITY OF YOUR PERSONAL INFORMATION

We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or inappropriate disclosure, and implement a range of measures for this purpose, which may include electronic access controls, premises security and network firewalls. Even though we take steps to protect your personal information, we cannot fully eliminate security risks associated with personal information.

We may be required by law to retain your personal information for a set time period. If any such time period has elapsed and if we no longer need your personal information for the purposes set out in this Privacy Policy, we will take reasonable steps to destroy your personal information or to ensure that the information is de-identified.

 

7. SENDING INFORMATION OUTSIDE OF AUSTRALIA

Allegro currently stores your personal information on servers kept in Australia. We may be required to disclose your personal information overseas for the purposes of complying with FATCA, CRS or other tax, anti-money laundering, counter-terrorism or regulatory requirements.

For Allegro investors investing through an offshore entity, we may also be required to disclose your personal information with the offshore entity, its professional service providers and foreign governments. If this is applicable to you, further information may be provided at the time of your subscription to our funds.

Other than where required by law, we will only disclose your personal information to overseas recipients with your consent.

Where we disclose your personal information overseas, we will take reasonable steps to ensure that any overseas third parties have processes in place to protect personal information from unauthorised use and disclosure and do not breach the Australian Privacy Principles in relation to your information.

However, these third parties may not be subject to the Privacy Act or the APPs (or equivalent laws). By providing Allegro with personal information, you consent to the disclosure and transfer of your personal information to these overseas recipients. If you wish to withdraw your consent to any future disclosures of your personal information to these overseas recipients, please contact us using the details below.

 

8. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

We update personal information when we are advised of changes by individuals or when we become aware through other means. If you believe the information we hold about you may not be accurate, current or complete, please advise us. In addition, we may also contact you from time to time to request new or updated personal information, to ensure that we are able to meet our legal, tax and regulatory obligations.

You can request access to the personal information Allegro holds about you by contacting us on our contact details below. You may also request us to update or correct your personal information if you do not believe that the personal information we hold about you is accurate, current or correct.

We will respond to any request to access or update your personal information within a reasonable period after the request is made. We may need to verify your identity before responding to any request. Where it is reasonable and practicable to do so, we will provide access to the personal information in the manner requested by you.

If Allegro is unable to provide you with access to, or amend, your personal information as requested, we will notify you and provide a written explanation for our decision. If Allegro is unable to correct your personal information, you may request that we associate a statement with the information that the information is inaccurate, out of date, incomplete, irrelevant or misleading.

 

9. ALLEGRO’S WEBSITE

This Privacy Policy also applies to your use of Allegro’s website and any personal information that you may provide to us via our website.

When you visit Allegro’s website, certain information, such as general site visit information, may be passively collected by Allegro or our contractors. This information is not combined with personal information you provide to us elsewhere unless you have consented to it.

The Allegro website may contain links to third party websites which do not belong to us and are not covered by this Privacy Policy. Allegro is not responsible for the privacy policies and practices of any such third party websites.

 

10. CONTACTING US

If you have any questions or concerns about our handling of your personal information or this Privacy Policy, please contact us:

by phone: +61 2 8228 8700
by email: enquiries@allegrofunds.com.au
by post: Compliance Officer
Allegro Funds
Level 29, 20 Bond Street
Sydney NSW 2000

If practical, you can contact us anonymously or by using a pseudonym. However, given the nature of our business, if you choose not to identify yourself, we may be unable to provide you with the information, services or assistance you seek.

If you wish to make a complaint about how we have handled your personal information, or if you believe we have breached this Privacy Policy, Australian Privacy Law or the Australian Privacy Principles, you may make a complaint in writing or verbally via the contact details provided above.

We will acknowledge receipt of your complaint as soon as possible and will respond to the issues raised within a reasonable time frame (usually no longer than 30 days).

If you are unsatisfied with our response, you may lodge a formal complaint with the Office of the Australian Information Commissioner using one of the methods available on their website at https://www.oaic.gov.au/about-us/contact-us.

 

11. CHANGES TO OUR PRIVACY POLICY

We reserve the right to vary this Privacy Policy from time to time. The updated Privacy Policy will be made available here. Alternatively, if you would like to obtain an electronic or hard copy of our Privacy Policy, please let us know.

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