Stamford Capital Funds Management Pty Ltd ACN 146 670 626 is committed to protecting you and your clients’ privacy in accordance with the Privacy Act 1998 (Cth). This Privacy Policy describes our current policies and practices in relation to the handling and use of personal information.

If you are in a country that is a member of the European Economic Area (EEA), the EU General Data Protection Regulation 2016/679 (‘GDPR’) governs the way we collect, use, hold, process and disclose your personal information. Under the GDPR, we are a data controller. We make decisions on how and why your personal information is processed.

What personal information do we collect and how do we use it?

We will ask you for personal information when you invest with Stamford Capital Investments. We use the information you provide to verify your identity and wholesale investor status. We only provide your information to the companies with whom you choose to deal with (and their representatives).

The types of information that we collect and hold about you or your clients’ could include:

• ID information such as name, postal or email address, telephone numbers, and date of birth;
• financial details such as bank account information, tax file number; and
• other information we think is necessary.

We may occasionally notify you about new investment opportunities, company and/or market updates, events or articles we think will be of interest to you. We may send you regular updates by email or by post.

You can let us know at any time if you no longer wish to receive direct marketing offers from us by contacting us at info@stamfordcapital.com.au. We will process your request as soon as practicable.

We may also use your information internally to help us improve our services and help resolve any problems.

How do we collect your personal information?

The means by which we collect your personal information will depend on the nature of the services that we are providing to you. We may collect your personal information:

• directly from you, either in person, via email, over the phone, through our website or any other social media platforms, or through our third-party investment platform, powered by Caruso;
• from related third parties, including but not limited to, wealth managers, accountants, financial advisers.

What if you don’t provide some information to us?

If you don’t provide your information to us, it may not be possible:

• for us to verify your investment status and eligibility;
• to return investment capital or deposit distributions;
• verify your identity or protect against fraud;
• to provide tax and/or holding statements;
• to let you know about other investment opportunities that you or your client might be interested in.

How do we hold and protect your information?

We strive to maintain the reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

We hold the information we collect from you. In some cases, your file is archived and sent to an external data storage provider for a period of time. We only use storage providers located in Australia who are also regulated by the Privacy Act. We ensure that your information is safe. We maintain physical security over our paper and electronic data and premises by using locks and security systems.

Will we disclose the information we collect to anyone?

We do not sell, trade, or rent your personal information to others.
We may need to provide your information to our investor management platform e.g. for administration and supervision activities, contractors who supply services to us e.g. to handle mailings on our behalf, or to other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event. However, we will do our best to ensure that they protect your information in the same way that we do.

We may also provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.

How can you check, update or change the information we are holding?

Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate.

You can also check and update your contact and investment information through our investor portal: invest.scinvestments.com.au/login
If you wish to access or correct your personal information, please write to info@stamfordcapital.com.au.

We do not charge for receiving a request for access to personal information or for complying with a correction request.

How do you make a complaint?

If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.

You can contact us by using the details below:

Email: info@stamfordcapital.com.au
Phone: +61 2 9046 8900

We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.

Need more help?

If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:

• Online: www.oaic.gov.au/privacy
• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au
• Fax: +61 2 9284 9666
• Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601.

Website Terms of Use and Disclaimer

The content on this website is issued by Stamford Capital Funds Management Pty Ltd ACN [146 670 626], AFSL Number [475123] (“Stamford Capital Investments”, “we”, “us” or “our”). By using this website you are accepting all the terms of this disclaimer notice. If you do not agree with anything in this notice you should not use this website.

General Advice Disclaimer

The information provided on this website is general in nature and does not constitute investment advice or personal financial product advice. It does not take into account your investment objectives, particular needs, or financial situation. You should seek independent financial advice before making any investment decision.

Before investing in any financial product, you should carefully consider:

• All relevant information about the financial product, including risks, fees, and ongoing costs;
• Whether the financial product is appropriate for your investment objectives and financial circumstances;
• Any applicable Disclosure Document (including a Product Disclosure Statement or Information Memorandum) prepared by the relevant issuer, which you should read in its entirety; and
• Obtaining independent legal, taxation, and financial product advice from a licensed adviser who is aware of your particular circumstances.
  Stamford Capital Investments is not authorised to provide personal financial product advice, legal advice, or taxation advice, and does not do so.

No Warranty & Accuracy of Information

The contents of this Website are provided for general informational purposes only and are current as at the date of publication. Stamford Capital Investments reserves the right to amend, update, or remove any content at any time without notice.

While Stamford Capital Investments takes reasonable steps to ensure the accuracy and currency of information sourced from reputable sources, it makes no representations or warranties – express or implied – as to the accuracy, completeness, timeliness, or reliability of any information, data, or documents on or accessible from this Website.

Any reference to transactions, case studies, or deal examples on this Website are included solely for illustrative purposes. They are not indicative of overall investment performance. Past performance is not a reliable indicator of future returns. None of Stamford Capital Investments, its directors, officers, employees, advisers, agents, or associates warrant or guarantee the future performance of any financial product, fund, or issuer referenced on this Website.

Forward-Looking & Predictive Information

This website may contain information that is predictive in character or which includes forward-looking statements. Such information may be affected by inaccurate assumptions or by known or unknown risks and uncertainties, and may differ materially from results ultimately achieved. You should not place undue reliance on forward-looking statements or projections.

Past performance is not a reliable indicator of future performance. Any performance comparisons or illustrations are provided for information purposes only and should not be relied upon as a guide to future performance.

Limitation of Liability & Indemnity

To the maximum extent permitted by law, Stamford Capital Investments, its related entities, directors, officers, employees, and agents expressly disclaim all liability (including in negligence) for any loss or damage – whether direct, indirect, special, incidental, consequential, or otherwise – arising from:

• Your access to or use of (or inability to access or use) this Website;
• Your reliance on any information or material contained on this Website;
• Any errors, omissions, or inaccuracies in the content of this Website; or
• Unauthorised access to or alteration of your transmissions or data.
  Such excluded losses include, without limitation, loss of profits, loss of revenue, loss of goodwill, loss of data, business interruption, or any other economic or financial loss.

You agree to indemnify, defend, and hold harmless Stamford Capital Investments and its related parties, directors, officers, employees, and agents from and against all claims, actions, liabilities, damages, costs, and expenses (including reasonable legal fees) arising out of or in connection with your use of this Website or your breach of these Terms.

Jurisdictional Restrictions & Eligibility

The information and services presented on this Website are not directed at, and are not available to, any person or entity in any jurisdiction where the provision or use of such information would be contrary to applicable laws, rules, or regulations, or where Stamford Capital Investments is not authorised to operate.

By accessing this Website, you represent and warrant that you are doing so on your own initiative and that you are responsible for compliance with all applicable local laws and regulations in your jurisdiction. You agree not to use this Website for any unlawful purpose or in any manner that violates these Terms or applicable law.

Financial products described on this Website may not be available or suitable for investors in all jurisdictions. Nothing on this Website constitutes an offer to sell or a solicitation of an offer to buy any financial product in any jurisdiction where such offer or solicitation would be unlawful.

Wholesale & Sophisticated Investor Notice

Certain products, services, and information accessible through this Website are intended solely for wholesale clients or sophisticated investors as defined under Chapter 7 of the Corporations Act. If you do not meet the relevant eligibility criteria, you should disregard and not rely upon any such information.

By accessing restricted areas of this Website, you represent and warrant that you qualify as a wholesale client or sophisticated investor as applicable, and that you understand the risks associated with the types of investments described.