Privacy Policy

Updated: 19 April 2024

This Privacy Policy applies to information collected in Australia by Quotient Capital Pty Ltd (ABN 38 109 490 066), holder of Australian Financial Services Licence (AFSL 280285). It outlines how we collect, handle and safeguard your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Your privacy is important to us, and we are committed to protecting the personal data you entrust to us.

1. What personal information do we collect?

We collect personal information necessary to offer and manage our financial products and services. This may include:

• Your name, date of birth, contact details, tax file number (TFN), Australian Business Number (ABN), and identity verification documents;
• Financial details such as income, assets, liabilities, and investment preferences;
• Information you provide in applications, correspondence, or forms;
• Communications with your financial adviser, broker, accountant, or lawyer;
• Details of your investments and transactional history with us;
• Sensitive information (e.g. criminal or AML/CTF checks) if legally required or with your consent;
• Information about other individuals associated with your investments (e.g. beneficial owners, trustees, directors, authorised signatories).

2. How do we collect your personal information?

We may collect personal information:

• Directly from you, including through application forms, telephone calls, emails, online portals, or face-to-face meetings;
• Through your authorised representatives (e.g. financial adviser or accountant);
• From third-party verification or registry services;
• From our service providers or related entities;
• From public sources or regulatory databases, where necessary for compliance purposes.

3. Consequences of not providing information

If you do not provide requested information, we may be unable to:

• Offer you certain products or services;
• Process transactions or verify your identity;
• Comply with legal obligations (e.g. AML/CTF laws);
• Prevent withholding tax from being deducted at the highest marginal rate.

4. How we use and disclose your personal information

Your information may be used for:

• Administering your investments and fulfilling our contractual obligations;
• Verifying identity and assessing suitability for specific products;
• Communicating with you and your authorised representatives;
• Conducting credit or anti-money laundering checks where applicable;
• Meeting legal, regulatory, and risk management obligations;
• Offering new investment opportunities or updates where permitted;
• Conducting research, analysis, or surveys to improve client service;
• Ensuring products are distributed in accordance with their Target Market Determinations.

We may share your information with:

• Your nominated adviser, broker, or agent;
• Registry and IT providers, auditors, legal firms, and data storage vendors;
• Government authorities or regulators where legally required;
• Digital platforms (e.g. Google, LinkedIn, Meta) for marketing analytics and audience modelling (always encrypted and de-identified).

5. Overseas disclosure

Some data may be accessed or processed overseas by:

• Trusted IT or cloud service providers under contract (e.g. in India, USA, UK);
• Registry providers conducting administrative tasks for Australian investments;
• Platforms such as LinkedIn, Google, and Facebook (via encrypted metadata only);
• All overseas disclosures are conducted under strict security controls and access protocols, with servers hosted or mirrored in Australia where possible.

6. Use of service providers

We engage third parties to perform functions such as:

• Identity verification and AML/CTF screening;
• Cloud storage and IT maintenance;
• Document management and marketing analytics.

All third parties are contractually bound to uphold data security standards and use your information only for the intended purpose.

7. Keeping your information up-to-date

Please notify us of any changes to your contact or personal details. Inaccurate or outdated records may limit our ability to provide services. Changes to your name or identification may require supporting documentation.

We cannot process changes to investment accounts over the phone.

8. Storage and security

Your data is stored securely using a combination of internal systems and trusted external providers. We implement reasonable safeguards to prevent misuse, unauthorised access, loss, or disclosure.

When data is no longer needed, we take steps to de-identify or securely destroy it in accordance with legal requirements.

9. Access and correction

You can request access to the personal information we hold about you, subject to certain legal exceptions. You may also request corrections if the information is inaccurate, outdated or incomplete.

If you disagree with our decision on a correction, you may request that your disagreement be recorded.

10. Identifiers

We do not use government-issued identifiers (e.g. TFNs, Medicare or driver’s licence numbers) as our internal reference. We issue our own unique investor or account identifiers.

11. Anonymity

Where lawful and practical (e.g. general website browsing or enquiries), you may remain anonymous or use a pseudonym. However, we cannot offer financial services without verifying your identity.

12. Direct marketing

We may use your information to inform you about products or services, provided:

• You would reasonably expect us to do so; or
• You have consented; and
• You have not opted out.

You may opt out at any time by contacting us (see section 17).

13. Website & analytics

We may collect anonymous data about your use of our website at www.quotient-capital.com through cookies and similar technologies. This helps us improve site functionality and personalise your experience.

Where you submit forms or request documents online, we will collect identifying information.

We use trusted analytics and ad platforms (e.g. Google Analytics, LinkedIn Insight Tag, Meta Pixel) to assess performance and target advertising. These services may collect metadata (e.g. IP addresses, page views), which is always encrypted and does not personally identify you.

14. Electronic identity verification

To meet our AML/CTF obligations, we may verify your identity using official databases. This may involve matching your details (e.g. name, date of birth, licence or passport number) with government-held records. You may opt out, but this may delay or restrict your ability to invest.

15. Employment enquiries

If you apply for a role with Quotient Capital, we may collect personal or sensitive information from you and referees to assess your suitability. We may also use external agencies for background checks or psychometric testing. You may request your testing data be de-identified if not hired.

16. Contacting Us

If you would like to:

• Access or update your personal information;
• Opt out of marketing communications; or
• Ask a question about this policy,

please contact:

Privacy Officer
Quotient Capital Pty Ltd
Collins Square Tower 5,
727 Collins Street, Melbourne VIC 3008
Email: [email protected]

17. Privacy complaints

If you have a concern about how your privacy has been handled:

1. Contact our Privacy Officer in writing.
2. We aim to resolve complaints within 30 days.
3. If you are not satisfied, you may escalate your complaint to:

Australian Financial Complaints Authority (AFCA)
www.afca.org.au | 1800 931 678

Office of the Australian Information Commissioner (OAIC)
www.oaic.gov.au | 1300 363 992

18. Updates to this Privacy Policy

This policy may be amended from time to time. The latest version will always be available at www.quotient-capital.com.