Introduction

This Privacy Policy details how we protect your privacy and how we comply with the requirements of the Privacy Act 1998 (Cth) and the 13 Australian Privacy Principles (“APPs”).

This policy also describes:

1. who we collect information from;

2. the types of personal information collected and held by us;

3. temporary ban from certain spaces or forums;

4. permanent ban from certain spaces or forums;

5. removal of responsibilities (e.g. replacement of the investor director or board observer from the board);

6. termination of employment; and

7. report to legal authorities.

Who do we collect personal information from?

In the course of providing our products and services, Tribe Global Ventures Pty Ltd may collect personal information from clients, or potential clients.

What types of personal information do we collect?

In the course of providing products and services, we may collect and hold information that is reasonably necessary for the performance of our functions and activities, including maintaining a unitholders’ registry of investor details. This information may include Personal Information such as:

1. names, addresses and other contact details;

2. dates of birth;

3. financial information;

4. your nationality and country of birth;

5. career history including areas of expertise;

6. data required for AML/CTF purposes; and

7. government identifiers (such as your TFN where necessary and relevant, although you may decline to quote your TFN).

We may collect Sensitive Information about you, with your consent. Sensitive Information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. Provided you consent, your sensitive information may only be used and disclosed for purposes you have consented to or which are directly related to the primary purpose for which the sensitive information was collected, including:

1. for the purpose of us maintaining a comprehensive company file;

2. for the purpose of data compilation or analysis for internal purposes; and

3. in an anonymised format for the purpose of data compilation or analysis to share with third parties. Sensitive information may also be used or disclosed if required or authorised by law.

How we collect and hold your personal information

How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.

Where possible Tribe Global Ventures Pty Ltd has attempted to standardise the collection of personal information by using specifically designed forms (e.g. our Application Forms). However, given the nature of our operations we often also receive personal information by email, online forms, letters, notes, over the telephone, in face-to-face meetings and through financial transactions. We may also collect personal information from other people (e.g. a third party administrator) or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly.

We may use cookies on our website from time to time. Cookies are text files placed in your computer & browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our website with personal information, this information may be linked to the data stored in the cookie. We may use web beacons on our website from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We hold your personal information:

1. in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers;

2. only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any application legal reporting or document retention requirements; and

3. using industry standard security methods and best practices to protect your personal information from unauthorised access, modification or disclosure and from misuse, interference and loss. Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

How we use your personal information

We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.

Our uses of personal information include but are not limited to:

1. providing you with one or more of our financial services or products including to assess your application for a financial product or service;

2. fulfilling our legal and regulatory obligations;

3. connecting people within our community;

4. performing our related administrative and organisational functions and tasks; and/or

5. to communicate with you about the products and services that we offer.

When we disclose your personal information

We may disclose your personal information, only if one or more of the following apply:

1. you have consented;

2. you would reasonably expect us to use or disclose your personal information in this way;

3. we are authorised or required to do so by law;

4. where a permitted general situation under the APPs applies.

This may include disclosure of your personal information to our employees, contractors and related entities, as well as third parties who supply services to us to assist us in performing our administrative functions and in fulfilling our legal and regulatory obligations (e.g. legal and accounting firms, data storage systems and certain SaaS providers). We will take reasonable steps to ensure that they handle your personal information in the same way that we do and in accordance with the Privacy Act and the APPs.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

We may provide links to third party websites. Any information provided to the third-party website is outside Tribe Global Ventures’ control and not subject to this Privacy Policy.

Disclosure of your personal information to overseas recipients

In certain limited circumstances, such as where there are foreign indicia on your account, your personal information may be shared with the Australian Tax Office and/or ASIC which will then exchange this information with similar overseas regulatory bodies as a result of Australia’s participation in the Common Reporting Standard and Foreign Account Tax Compliance Act. We may also, in accordance with this Privacy Policy, disclose your personal information to other third parties who reside outside Australia. In this instance, we will take reasonable steps to ensure that the third party recipient does not breach the Australian privacy laws.

Your rights of access, correction and restriction

You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us in the manner outlined below. You may also contact us if any of the details you have provided change or if you believe that the information we have about you is not accurate, complete or up-to-date. If we do not agree to provide you with access or to amend your personal information as requested you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision and you may seek a review of our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.

You may also request that we restrict the use of your personal information for direct marketing purposes by contacting us using the contact details below. Alternatively, to unsubscribe from our email database or opt-out of communications (including marketing communications) you may use the opt-out facilities provided in the communication.

How to contact us

If you have any queries or complaints about our collection, use or storage of your personal information (including a complaint relating to any failure by us to comply with our obligations under the credit reporting provisions of the Privacy Act 1988 (Cth) or under the Credit Reporting Privacy Code), or if you wish to exercise any of your rights in relation to your personal information, please contact our Privacy Officer: aaron@tribeglobal.vc.

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Your right to make a complaint

We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information. If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner or Australian Financial Complaints Authority (AFCA):

• Office of the Australian Information Commissioner

• GPO Box 5218, Sydney NSW 2001

• Telephone: 1300 363 992

• Mail: GPO Box 5218 Sydney NSW 2001

• Fax: +61 2 9284 9666

• Email: enquiries@oaic.gov.au

Changes to our privacy and information handling practices

This Privacy Policy is subject to change at any time.

If you have any queries or complaints about our collection, use or storage of your personal information (including a complaint relating to any failure by us to comply with our obligations under the credit reporting provisions of the Privacy Act 1988 (Cth) or under the Credit Reporting Privacy Code), or if you wish to exercise any of your rights in relation to your personal information, please contact [email] and address your email to The Privacy Officer. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information. If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner or Australian Financial Complaints Authority (AFCA):

Office of the Australian Information Commissioner

GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Mail: GPO Box 5218 Sydney NSW 2001
Fax: +61 2 9284 9666
Email: enquiries@oaic.gov.au