Privacy Statement

Caprock Limited (ACN 098 630 972, AFS Licence No. 330742) (referred to below as Caprock Limited, we, us, our) maintains a policy of strict confidence concerning any Personal Information you provide to us (Privacy Policy). The meaning of Personal Information is discussed in 1 below. This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) and the National Privacy Principles (Privacy Act) Our Privacy Policy applies to the collection, storage, use and disclosure of your Personal Information. We have formulated our Privacy Policy on an" FAQ "-style basis to assist in your understanding of our Policy. 1. What Personal Information do we collect? "Personal Information" means information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. We may obtain Personal Information to provide you with our services and products or to manage our relationship with you. The types of Personal Information we may collect include your full name, contact details (such as your residential address, telephone number and email address), date of birth, tax file number, your financial details and interests and the products and services we have provided to you. We collect Personal Information when you: • visit the Website to read or download information; • contact one of our directors or employees by telephone or email; • make an enquiry about our products or services; or become one of our clients. Sometimes, we may need to collect Personal Information about individuals who are not our customers (for example, business contact details of a company representative with whom we deal or your representative or agent, such as your accountant). Generally, we will not collect sensitive information about you (such as your race, political or religious beliefs or your health) unless for some reason we need to do so in order to provide you with our products or services. If we do need sensitive information, we will seek your consent when we collect the information (unless an exemption applies). 2. How is Personal Information collected and stored? This depends on how you deal with us and the products and services you might request from us. We may collect Personal Information about you from an application form or verbally if you call us or speak directly with our staff. In addition, if you access our website, this will mean that we will collect Personal Information electronically. Some of our pages on the Website use "cookies", which are small files that may be placed on your hard disk for record-keeping purposes. Cookies helps us remember who you are and may collect and store your server address, the date and time of your visit, the pages viewed and any downloads made. Cookies can make your subsequent visits to the Website simpler and more efficient. We may also use the information to assist in improving the Website, marketing and product development. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. (However, by not accepting cookies, some pages on the Website may not display properly or you may not be permitted to access certain information.) A server cannot find out a name or email address, or anything about you by using cookies. Cookie information is not stored or collected by us. Once we receive information from you, via email or any other means, the information is stored in a secure environment. Caprock Limited takes reasonable steps to protect the Personal Information it holds from loss and unauthorised access, destruction, use, modification or disclosure. 3. How do we use Personal Information collected by us? We use Personal Information only for the purposes for which it was collected. These purposes are: • providing you with the relevant products or services requested; • managing our relationship with you; • managing and administering your investments; • communicating with you about your investments; • if you have requested it, sending you information about us and our products and services; • developing our products and services; • marketing and research; • statistical purposes; • improving the content of the Website; • general internal purposes; • to help us manage, develop and enhance our services, including our applications; and • general product development. If you would like to stop receiving communications from us, please contact our Privacy Officer (details below). If it is no longer necessary for us to have your Personal Information, we will take reasonable steps to destroy it in a secure manner or remove identifying features from it. This is subject to any legal obligation we have to keep Personal Information for a specific period of time. 4. Will Personal Information be disclosed? Personal Information collected from you will only be used to send commercial electronic messages if express or inferred consent has been obtained. Our Privacy Policy is designed to maintain the confidentiality of all Personal Information held by us and prevent its misuse. Our Privacy Policy is designed to maintain the confidentiality of all Personal Information held by us and prevent its misuse. In some circumstances, however, Personal Information may be disclosed outside Caprock Limited. For example: • for legal reasons, disclosures may need to be made to law enforcement agencies, government agencies, courts or external advisors; • in some circumstances, Personal Information is disclosed to third parties where this is related to the supply of our products or services. If we make disclosures of this kind, you will be advised of these disclosures at the time you request us to supply you with our products or services. • Some of these organisations are located overseas in Sri Lanka. Personal Information may be disclosed to third parties to whom we contract out specialised functions, such as software suppliers, mailing houses and printing companies. If so, we take steps to ensure that those contractors comply with the Privacy Act, and are authorised only to use Personal Information in order to perform the functions required by us. 5. How do I access and correct my Personal Information? Under the Privacy Act, you have a right to seek access to information which we hold about you. However, there are some exceptions to this. You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. Our policy is to consider any requests for access or correction in an appropriate and timely fashion. In order to provide you with access to your Personal Information, we ordinarily would provide you with a hard copy print-out of the relevant Personal Information from our current databases, or with photocopies of records which are held only on current paper files. If you have any questions about this Privacy Policy, if you wish to complain about how we have handled Personal Information about you, or if you wish to access or correct your Personal Information, please contact our Privacy Officer. See paragraph 10 below for the Privacy Officer's contact details. 6. What about Security and Transborder Data Flow? As mentioned we will use reasonable steps to maintain a secure system for storing Personal Information. Technological and operational policies and procedures are in place to protect Personal Information from misuse and loss and from unauthorised modification or disclosure. However, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information transmitted to us (e.g. by email) and you do so at your own risk. Personal Information will not be transferred overseas unless there is a reasonable belief that it will be collected, used or disclosed by the recipients in accordance with this Privacy Policy. 7. Do you use Government Identifiers? We do not use tax file numbers, Medicare numbers or any other Government identifier for the purposes of identifying clients with products or services. The only circumstances in which we may collect such information is where we are required by law to do so. 8. What about the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 In order to comply with this legislation, in most cases, we must now obtain, verify and record Personal Information that verifies clients who wish to invest using our services. The Personal Information collected for this specific purpose includes your full name, date of birth and residential address. We are obliged by law to store this information for a minimum of seven years. The Personal Information collected for the purposes of this legislation will not be disclosed to any third party unless: • we have obtained your consent and informed you of the recipients of your Personal Information to, or • if we are obliged to disclose your Personal Information by law. 9. What about links and references to Third Party Websites? The Website may contain links and references to third party websites. We encourage you to read the privacy policies on these third party websites as they may differ from ours. 10. How do I contact your Privacy Officer? Please contact our PRIVACY OFFICER if you: * have any questions about this Privacy Policy; • would like us to stop sending you COMMUNICATIONS; • wish to make a complaint about how we have handled your Personal information; or • would like to access or correct your Personal Information held by us. OUR PRIVACY OFFICER can be contacted at: GROUP LEGAL AND COMPLIANCE legal@caprock.com.au Caprock Pty Limited, LEVEL 2, 222 PITT STREET, Sydney NSW 2000 Australia