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WATERCREST CAPITAL PTY LTD


PRIVACY NOTICE

Introduction
Your privacy is of great importance to us. This notice (this “Privacy Notice”) is provided by Watercrest Asset Management Pty Ltd. (the “Investment Manager”) and Watercrest Capital Pty Ltd. (the “Company” and together with the Investment Manager, “we” or “us”) and outlines our policies regarding the collection, use, storage, sharing, disclosure (collectively, “processing”), and protection of personal data relating to current, prospective, and former investors in the Company.

References to “you” or an “investor” in this Privacy Notice refer to any individual investor, or any individual associated with an investor that is a legal entity, as applicable.

Who to Contact About This Privacy Notice
This Privacy Notice is provided in accordance with the applicable requirements under the privacy and data protection laws relevant to the jurisdictions in which we operate (collectively, the “Data Protection Laws”). The Company and the Investment Manager are considered data controllers in respect of the personal information we hold about you under certain Data Protection Laws. This means that each of the Company and the Investment Manager (individually or jointly, as applicable) determines the purposes and means of processing your personal data.

For questions about this Privacy Notice or requests regarding the personal data we hold, please contact our Sydney Office, on +61 (0)280 754 799 or by emailing to info@watercrestcapital.com.

Please note that the Administrator, along with other service providers such as the Company’s corporate broker, registrar, custodians, and prime brokers, operate under specific legal and professional obligations requiring them to process personal data (e.g., anti-money laundering legislation). In such cases, they may act as data controllers in their own right, independently of the Company. For details about how these service providers handle your personal data, please refer to the address specified in the Company’s Prospectus or their respective websites.

The Types of Personal Data We May Hold
During the private phase of the Company, we, or service providers acting on our behalf, collected personal information such as your name, address, tax identification number, date of birth, copies of identification documents, bank account details, and transaction information. This information may have been provided by you through subscription agreements, correspondence, or transactions with the Company.

In the public phase of the Company, we may continue to collect similar categories of personal data, including additional information obtained through background checks or as required under applicable Data Protection Laws.

How We Collect Personal Data
We may collect personal data in several ways, including:

  • Information provided directly by you or on your behalf through forms, documents, or correspondence;

  • Information obtained through conversations with representatives of the Company or its service providers;

  • Information received from third parties or publicly available sources, such as tax authorities, government agencies, credit agencies, or public registers;

  • Data shared by our affiliates or service providers, such as the Administrator.

How We May Use Personal Information
We process your personal data for the following purposes:

  • Administering the relationship between you and the Company (including communication and reporting);

  • Marketing our products and services;

  • Monitoring and analysing the Company’s activities;

  • Complying with legal and regulatory requirements, such as anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to regulatory authorities.

We will process your personal data only where permitted by applicable Data Protection Laws, including where:

  1. It is necessary to fulfil our obligations under the Company’s Prospectus and Articles of Association;

  2. We are required to comply with legal or regulatory obligations;

  3. It is necessary for our legitimate interests or those of a third party, such as for business purposes where you would reasonably expect such processing.

How We May Share Personal Data
We may disclose your personal data to:

  • Affiliates, service providers (including the Administrator), or other third parties to facilitate account management and corporate transactions;

  • Regulatory, tax, or law enforcement authorities to meet legal or regulatory requirements;

  • Trading counterparties such as custodians, brokers, or other financial institutions to complete transactions.

Additionally, the Company is required by law to maintain a share register. Copies of the register, which include the names and addresses of registered members, may be made available to third parties under specific conditions.

We may also share your personal data with affiliates for marketing purposes unless you opt out by contacting us (see “Who to Contact About This Privacy Notice”).

Retention Periods and Security Measures
We retain personal data only as long as necessary for the purposes outlined in this Privacy Notice, subject to applicable Data Protection Laws. Generally, we retain data for a minimum of five years or longer where required by law or for business purposes, such as marketing.

We implement organisational and technical measures to safeguard your personal information, including secure IT systems and physical security measures. In the event of a significant data breach, we will notify you as required under applicable laws.

Additional Information Under the GDPR and Related Laws
Under the General Data Protection Regulation (GDPR) and equivalent laws, you may have certain rights regarding your personal data, including:

  1. The right to access, correct, or request deletion of your personal data;

  2. The right to restrict or object to processing;

  3. The right to data portability, where applicable;

  4. The right to withdraw consent where processing is based on consent;

  5. The right to lodge a complaint with a supervisory authority.

Please note that some rights, such as the right to be forgotten, may not apply where data retention is required for legal or regulatory purposes.

International Data Transfers
Given the global nature of our operations, your personal data may be transferred to jurisdictions outside your home country, including those with data protection laws less stringent than those of the GDPR or GDPL. We take appropriate measures, such as contractual safeguards, to ensure the security of your data during such transfers.

Complaints to Supervisory Authorities
If you believe your data has been processed in violation of applicable laws, you may lodge a complaint with the relevant data protection authority, such as the Office of the Australia Information Commissioner or the Information Commissioner’s Office in the United Kingdom.

© 2024 Watercrest Capital, Pty Ltd. All Rights Reserved. Read our Disclaimer

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