Privacy Policy

Regal Partners Limited (ACN 129 188 450) (collectively with its related bodies corporate, Regal Partners) is committed to respecting your privacy and protecting the security of your personal information. Regal Partners complies with the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles (the APPs) under that Act. We take the protection of your personal information very seriously.

By providing personal information to us, you consent to us collecting, holding, using and disclosing it in accordance with, and for the purposes specified in, this Privacy Policy and any arrangements that apply between us.

You are not required to provide personal information to us. However, if you do not provide us with all the information we request, the services we provide to you may be affected.

Overview

This Privacy Policy outlines:

the types of personal information we may collect;
how we collect and handle personal information;
the purpose of collection, use and disclosure of personal information;
our storage and security practices for personal information;
how we report data breaches;
how you can gain access to your personal information and seek correction if required; and
how you may complain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or concern will be handled.

Personal information we may collect

In this Privacy Policy, ‘personal information’ means any 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. It does not include information that is de-identified (anonymous data).

Regal Partners collects personal information that is reasonably necessary for Regal Partners to conduct its business, communicate with you, consider any investment applications and/or approaches that you make to us and/or provide you with appropriate services. The types of personal information that Regal Partners may collect include:

Personal Information: your full name, residential address, email address, telephone numbers, place and date of birth, contact details, copies of identification documentation, source of funds, nature of your business, if you are an entity such as a corporation or trust, your governing documents and details related to certain of your direct and indirect members and authorised signatories, your income, net assets or other relevant information related to your status as a wholesale investor, your country of residence, information relating to your status as a US investor, your tax file number (TFN) (or other international tax numbers and residency details), your bank account details and banking details.
Sensitive information: Regulatory and other laws may also mandate us to collect additional information from or about you, for example, membership of a political association, membership of a professional or trade association, information about your background or criminal record. Unless the collection of the sensitive information is required or authorised under an Australian law, Regal Partners is required to obtain your consent before it collects any such sensitive information from you.

In respect of listed investment companies, listed investment trusts, funds or individually managed accounts managed or advised by Regal Partners, personal information including your bank account details and TFN are collected by the relevant share or unit registries or administrators and may be provided to Regal Partners. Please refer to the privacy details of the relevant share or unit registry or administrators on how they manage the privacy of this information.

How we collect personal information

We may collect personal information about you via:

any messages or comments you submit to Regal Partners via its websites, through ‘Contact Us’ webpage (or equivalent enquiry webpages) and via email;
application forms, identification documentation or other documents that you may complete or provide to Regal Partners;
face to face meetings, interviews and telephone conversations;
attending our investor presentations or conferences;
publicly available information;
subscriptions to, or purchasing, marketing databases;
any written information provided by you to us (whether in physical or electronic form);
information that we receive from third parties, including share registries, administrators, custodians, brokers or from your legal, tax or financial advisers (where you have authorised them to provide this information to Regal Partners); or
an employment application with Regal Partners.

Links and cookies

Regal Partners websites may contain links to other websites. Such websites are responsible for their own privacy practices, and you should review the respective privacy policies or statements of those websites.

Regal Partners may use ‘cookies’ (a packet of information placed on a user’s computer by a website for record keeping purposes), web beacons or similar technologies to collect de-identified information about traffic at our websites (including your visits to our websites). The information collected to conduct such analysis is anonymous and is for the purpose of improving your experience browsing our websites.

For example, such technologies may collect anonymised details about your operating system, browser type, Internet Protocol address, pages accessed, documents downloaded, any previous visits, any referring website, including dates and times.

You may disable these technologies on your internet browser. However, if you disable cookies in your browsers, our websites may not operate as they should.

Unsolicited personal information

We may be provided with personal information without having sought it through our usual means of collection. This is known as ‘unsolicited information’ and is often collected by:

misdirected postal mail;
misdirected electronic mail (including emails and other electronic messages);
employment applications sent to us that are not in response to an advertised vacancy; or
additional information provided to us which was not requested.

Unsolicited information obtained by us will only be held, used and/or disclosed if it is considered personal information that could have been collected by usual means or if the collection would be reasonably expected by you. If that unsolicited information could not have been collected by usual means or the collection would not reasonably be expected by you, then we will destroy, permanently delete or de-identify the personal information as appropriate.

Purpose of collection, use and disclosure of personal information

Regal Partners collects your personal information primarily for the purposes of:

providing you with the financial service or products you have sought from us and reasonably related secondary purpose;
processing applications (including identifying you and confirming your eligibility to invest in the product or to utilise the service);
managing and administering your investments;
providing services to you;
providing you with investment related communications;
if you are applying for employment with us through our website or otherwise, to assess, process and manage your application for employment;
handling any complaints you may have;
to develop and notify you about new features, products and services we may offer; and
any other purpose permitted under applicable laws and regulations.

Regal Partners will only use or disclose your personal information:

for the purpose for which you provided it or for a related purpose that would be reasonably expected by you;
where you have consented to the use or disclosure;
to the extent that Regal Partners is required or permitted to do so by law, including to comply with anti-money laundering and counter-terrorism financing, FATCA/CRS, taxation or any other regulatory reporting requirements; or
we reasonably believe that the use or disclosure is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

We may disclose your personal information to:

any member of Regal Partners;
regulators to the extent required or permitted by law; and
other companies and individuals who assist us in providing services or who perform functions on our behalf (such as administrators and custodians), (each a Recipient).

These Recipients may be located or operate overseas and therefore your information may be held outside Australia.

Regal Partners has contractual arrangements in place with its service providers which are designed to ensure that your personal information is kept confidential and secure. Unless you have provided your consent to a disclosure after being expressly informed that the protections of the Act will not apply, Regal Partners will take all reasonable steps to not disclose an individual’s personal information to overseas recipients unless we have satisfied ourselves that the overseas recipient does not breach the APPs, or a similar privacy regime in relation to the information. By providing us with your personal information, you accept that we may make disclosures to overseas recipients on this basis.

Direct marketing

Regal Partners may also use your personal information to keep you informed of our services, events and investment opportunities. We may contact you by mail, telephone, email or SMS to keep you informed. We will always give you the opportunity to ‘opt out’ of receiving any information and may, subject to the nature of the information provided, seek specific consent.

We may also use personal information collected from third parties for the purposes of direct marketing if you have consented, or it is impracticable to obtain your consent. In such cases, we will provide you with the ability to ‘opt out’ of these communications.

Please contact us via investorrelations@regalpartners.com if you do not wish to be contacted for these purposes.

Regal Partners does not sell personal information to other companies or individuals and will not disclose your personal information to any third-party marketing company.

Storage, security and integrity of personal information

Regal Partners regards the security of your personal information as paramount and takes reasonable steps to protect the security of personal information that it holds. Regal Partners also takes reasonable steps to protect such information from misuse, loss and unauthorised access, modification or unlawful disclosure.

If Regal Partners determines that it was not entitled to collect the personal information when it was collected or if required by applicable laws, Regal Partners will take reasonable steps to destroy the personal information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.

Your personal information is stored in secure physical and electronic storage facilities (including paper-based files and computer databases). Personal information is protected from misuse and loss and from unauthorised access by such measures as (including but not limited to):

use of physical security, network security, password protection, restricted access depending on staff role and responsibilities;
ensuring staff comply with internal policies and procedures; and
confidentiality agreements in place to bind staff and third-party providers (eg share registry, administrators, custodians).

Electronic records are maintained by a cloud hosting service provider or other third-party storage or server provider. All such personal information is maintained within the effective control of Regal Partners. We have arrangements which require third party service providers to maintain the security of the information and we take reasonable steps to protect the privacy and security of that information. However, we are not liable for any unauthorised access or use of that information.

Regal Partners websites may contain links to other third-party websites. We do not control, and are not responsible for, third-party websites or any of their content, and when you visit these websites, they will be governed by their own terms of use (including privacy policies). Please review their terms of use and privacy policies.

By providing us with your personal information by any means of electronic communication, you accept that such information will be transmitted at your own risk as the security of such information cannot be guaranteed and the internet by nature is not a secure environment.

Regal Partners takes reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed under the Act. Under the Corporations Act 2001 (Cth) (Corporations Act), we are obliged to retain financial records for at least 7 years after the transactions covered by the records are completed. Accordingly, client records are retained for the period required (being at least 7 years) to allow us to satisfy our obligations under the Corporations Act.

Reporting notifiable data breaches

We will take appropriate and prompt action if we have reasonable grounds to believe that a data breach (where personal information is lost or subjected to unauthorised access, modification, disclosure, or other misuse or interference) may have, or is suspected to have, occurred.

Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, and if there is an eligible data breach, notifying affected individuals and the Office of the Australian Information Commissioner.

Accessing and correcting personal information

If you wish to contact us to request access to the personal information Regal Partners holds about you, or if you have any questions regarding this privacy policy, you may contact us via investorrelations@regalpartners.com.

We will provide you with access to any personal information we hold about you (subject to certain legal exceptions). We will endeavour to respond to your request for access to your personal information within 30 calendar days, or as required by law. If a legal exception applies and we decide not to provide you with access to any personal information we hold about you, we will advise you of the reasons for our decision. Your right to access your personal information may be limited if:

we believe that giving you access may endanger the life, health or safety of any individual;
access would have an unreasonable impact on the privacy of others;
the request is frivolous or vexatious;
the information relates to commercially sensitive material or decision-making processes;
access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function or negotiations with you;
legal dispute resolution proceedings where a third party has given us health information about in confidence; and/or
denying access is required or authorised by or under law.

Regal Partners endeavours to ensure that the personal information it holds is accurate, up to date and complete. To assist us, please make sure that the information you provide to us is accurate, up to date, and complete. You should promptly contact us via investorrelations@regalpartners.com and request a correction if you consider the information we hold about you is inaccurate, incomplete, out of date or misleading. We can update certain information over the phone or via email, however certain circumstances may require signed instruction of the requested updates for security reasons.

If we are satisfied that any personal information we hold about you is inaccurate, out of date or incomplete (having regard to the purpose for which it is held), we will take such steps (if any) as are reasonable in the circumstances to correct that personal information. This may include notifying third parties to whom we have disclosed that personal information. If we do not agree that the personal information we hold about you is inaccurate, incomplete, out of date, misleading or not relevant, you may ask that we attach a statement to this effect to our record.

We do not impose any charges for requesting access to your personal information. However, we may charge an administrative fee for giving you access, which will be dependent on the cost of:

staff searching for, locating and retrieving the requested information, and deciding which personal information is relevant to the request;
staff reproducing and sending the personal information;
the postage and material involved in giving access; or
using an intermediary, if necessary.

If we propose to charge a fee for giving access, we will give you an estimate of the fee and an opportunity to confirm you still want access to the information. Our fee (if any) will not be excessive.

How to contact us

You can contact us about this Privacy Policy or about your personal information at the following contact details:

Phone: +61 2 8197 4358
Email: investorrelations@regalpartners.com
Mail: Regal Partners Limited
Level 46, Gateway
1 Macquarie Place
Sydney NSW 2000

If practical, you can contact us anonymously (ie without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or assistance you might otherwise receive.

Privacy concerns or complaints

If you have any concerns or complaints about your privacy, please contact us in writing via investorrelations@regalpartners.com as soon as possible. Regal Partners will use its best endeavours to resolve your concern or complaint within a reasonable time, and we may seek further information from you in order to provide you with a full and complete response.

If we are unable to satisfactorily resolve your concern or complaint, you can contact the Office of the Australian Information Commissioner (OAIC) by using their contact details at www.oaic.gov.au. The OAIC has the power to investigate and make a determination.

Updates to this Policy

This Privacy Policy may be updated at any time, and without notice.

Any changes to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on our websites. Please check our websites to view our current Privacy Policy.

Last updated: 20 October 2025