Santé Capital Privacy Policy

1. Introduction

Sante Capital Management Pty Limited (“Sante“, “we“, “our” or “us” in this Privacy Policy) is an Australia-based private markets investment manager.

We respect the privacy of the personal information you may provide to us when we deal with you. The way we manage your personal information is governed by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) established under the Privacy Act.

For the purposes of this Privacy Policy, “personal information” has the meaning given to it in the Privacy Act, which is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether the information or opinion is recorded in a material form or not. Examples of personal information include an individual’s name, address, telephone number and date of birth.

This Privacy Policy explains how we handle any personal information we hold about you. Please note that this Privacy Policy is to be read subject to any overriding provisions of law or contract.

2. Collecting personal information

2.1 What kinds of personal information do we collect?

The kinds of personal information we may collect include but are not limited to:

your full name (current and former (if any)) and date of birth;
your personal and business contact details (including your address, landline or mobile telephone numbers, fax number and e-mail address);
your employment details (including your company name, job title and business sector);
banking and tax details (including your tax file number and ABN if applicable);
personal information provided when you commence a business relationship with us;
personal information provided if you seek employment with us;
contact and identification details of any third party whom you have authorised to negotiate or provide your personal information on your behalf (including any agents or attorneys appointed by you under a power of attorney);
any correspondence between you and us; and
any other personal information provided to us when you make an inquiry, request information, correspond with us or lodge a complaint.

2.2 How do we collect personal information?

Where possible, we always try to collect personal information directly from you, for example when you:

request information or contact us through our website (for example, by telephone, in writing or emails);
provide to us your contact details, business card or documents containing your personal information (such as contracts, forms or public records or identification information for the purposes of confirming your identity or conducting “know your customer” checks under the Anti-Money Laundering and Counter terrorism Financing Act 2006 (Cth)); or;
meet with us in person.

We may also obtain your personal information from third parties we deal with, such as:

our related bodies corporate;
our shareholders;
the companies we invest in;
your business partners;
our professional advisers (for example, our insurers, auditors, lawyers, accountants and consultants);
your authorised agents or attorneys;
any other organisation with whom we do business; and
with your consent (express or implied) – other entities.

Where we collect personal information from third parties you refer to us, we will assume, and you will ensure, that you have made that third party aware of the referral and the purposes of collection, use and disclosure of the relevant personal information

2.3 Dealing with us anonymously

For certain transactions, you have the option of dealing with us anonymously or by using a pseudonym (for example, if you contact us asking for general information). However, it is generally not possible for us to enter into a business relationship or carry out commercial transactions with you without your personal information.

3. Why do we collect, hold, use and disclose your personal information?

We collect, use and disclose your personal information to carry out our commercial activities, operations and to provide the services, products and information you request.

In particular, we may collect, use and disclose your personal information so that we can:

respond to your requests or inquiries and provide you with any publications, information or other services requested by you;
assess your application for employment;
maintain and administer your business or other relationship with us (for example, updating and maintaining our records);
communicate with you during the course of your business or other relationship with us;
administer, support, improve and develop our business activities and services;
notify you about important changes or developments to our functions, activities, services or our website;
carry out any other activities which relate to or arise out of any investments or requests made by you;
if you lodge a complaint with us – process and respond to your complaint;
do anything which you authorise or consent to us doing; or
take any action we are required or authorised by law to take.

If you do not provide us with your personal information, it may not be possible for us to carry out these functions and activities.

4. Disclosing your personal information

We may disclose your personal information to:

our related bodies corporate;
our shareholders;
our business partners and service providers (such as contractors who provide website, IT, marketing, administration and other services to support us);
suppliers we engage for data processing and other administrative and support functions;
our professional advisers (for example, our insurers, auditors, lawyers, accountants and consultants);
your authorised agents or attorneys;
financial institutions (for payment processing);
any entity to whom we are required or authorised by law to disclose your personal information (for example, the Australian Taxation Office, law enforcement agencies and government and regulatory authorities such as AUSTRAC); and
with your consent (express or implied) – other entities.

The above entities may in turn disclose your personal information to other entities as described in their respective privacy policies or notices.

5. Dealing with Sante online

This Privacy Policy applies to your use of our website (www.santecapital.com.au) and any personal information that you may provide to us via our website.

When you visit our websites, we and/or our contractors may collect certain information about your visit.

Examples of such information may include:

Cookies – Cookies are small data files which we may store on your computer when you connect to our website to enable our server to collect certain information from your web browser. Cookies and other similar technology make it easier for you to log on to and use the website during future visits. It also allows us to monitor website traffic, to identify your computer when you visit this website, to personalise the content of the website for you and to enable you to both carry out transactions and have access to information about your account. Allowing us to create a cookie does not give us access to the rest of your computer and we will not use cookies to track your online activity once you leave our site. Cookies are read only by the server that placed them, and are unable to execute any code or virus; and
Site visit information – we collect general information about your visit to the Santé website. The information we collect is not used to personally identify you, but instead may include your server address, the date and time of your visit, the pages you accessed and the type of internet browser you use. This information is aggregated and used for the purposes of system administration, and to prepare statistics on the use of our website.

Our websites may contain links to other websites which do not belong to us and are not covered by this Privacy Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may be different from ours.

6. Data storage, retention, security and location of your personal information

We will take reasonable steps to protect your personal information from loss, misuse, interference, unauthorised access, modification or disclosure. We may store your personal information in different forms, including in hardcopy and electronic form. We have implemented policies, procedures and systems to keep your personal information secure.

We may be required by law to retain certain information for a set period of time. Once this period of time expires, or we no longer need to hold your personal information, we will take reasonable steps to destroy, delete or de-identify your personal information in a secure manner.

7. Overseas disclosure of personal information

We may disclose your personal information to for the purpose of complying with FATCA which may be located in overseas countries, including United States of America and New Zealand.

Where we disclose your personal information to an entity located overseas, we will take reasonable steps to ensure that the overseas recipient of your personal information handles your personal information in accordance with the Privacy Act.

8. Access and correction

To effectively conduct business with you, it is important that the personal information we hold about you is complete, accurate and current. At any time while we hold your personal information, we may ask you to tell us of changes to your personal information.

8.1 Correcting personal information

You can request us to update or correct your personal information if you believe that the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading or otherwise needs to be corrected or updated. Our contact details are provided below. We will respond to a request to correct your personal information within a reasonable period after the request is made.

If we refuse to correct your personal information, you may request that we associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.

8.2 Accessing your personal information

You can also request access to the personal information we hold about you by contacting us using our details provided below. We will respond to a request for access within a reasonable period after the request is made, either by giving you access to the personal information requested, or by notifying you of our refusal to give access.

We will not charge you an application fee for making a request to access the personal information we hold about you or for making any corrections to your personal information.

However, we may charge a reasonable fee to cover our costs of providing you with access to your personal information, for example, if you make multiple requests for information, where your request relates to a large volume of information, or we incur third party costs in providing you with access.

We may request to verify your identity before responding to any request.

If we decide not to provide you with access to or correct your personal information, we will give you reasons for our decision.

9. Lodging a complaint

If you have a complaint about how we handle your personal information (including how we dealt with any requests to correct or access your personal information), please contact us at the contact details below.

Please note that we may ask you to lodge your complaint in writing.

We will acknowledge receipt of your complaint as soon as possible after receiving your complaint in writing. We will investigate your complaint and provide you with a response within a reasonable timeframe.

If you are not satisfied with how your complaint is handled by us, then you can lodge a formal complaint with the Office of the Australian Information Commissioner at:

Telephone: 1300 363 992 (if calling from outside Australia: +61 2 9942 4099)
Post: Office of the Australian Information Commissioner, GPO Box 5288, SYDNEY NSW 2001
Fax: +61 2 6123 5145
Website: https://www.oaic.gov.au/privacy/privacy-complaints

10. Contacting Us

If you wish to contact us regarding our handling of your personal information or any of the matters covered in this Privacy Policy, please contact us through info@santecapital.com.au:

• by post at: Santé Capital Management Pty Limited, Level 5, 275 George Street, Sydney NSW 2000

• by email: through the ‘Contact Us’ page on our website https://www.santecapital.com.au

We welcome your questions and any suggestions you may have about our Privacy Policy.

11. Changes to this Policy

Santé reserves the right to revise or supplement this Privacy Policy from time to time. The updated version of this Privacy Policy will be posted on our website www.santecapital.com.au and will be effective from the date of posting.

This Privacy Policy was last updated on 11 July 2023.

DISCLAIMER

Nothing in this web site constitutes an invitation or an offer for the purchase, subscription for or sale of any securities. The contents of this website have been prepared to provide general information only and may not necessarily be, and no warranty is given that it is, accurate, complete or current. No person should act or fail to act on the basis of anything contained on this web site. This site and its contents are protected by copyright. You must not copy, modify, transmit or distribute the material at this site without the consent of Santé Capital Management Pty Limited.

This site may contain hypertext links, frames and other references to other parties and their web sites. We cannot control the contents of those other sites, and make no warranty about the accuracy, currency or suitability of the material located on those sites. To the maximum extent permitted by law Santé Capital Management Pty Limited and its related bodies corporate and their officers and employees disclaim any liability to any person arising out of any action or failure to act by that person, in accessing, downloading, using or relying on any materials from this web site.

The internet and the world wide web are unsecured, public networks. There is a risk that information sent to or from this site may be intercepted, corrupted or modified by third parties and that files obtained from or through this site may contain viruses or other defects. In using this web site and material from it, you assume these risks and responsibility for any loss or damage caused, directly or indirectly, by these risks.

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