1. Purpose of the policy

Equitable Investors Pty Ltd (Equitable Investors) understands the confidentiality of your personal information is important to you. Equitable Investors is committed to protecting the privacy of personal information obtained through its business activities and has practices in place to comply with the Australian Privacy Principles (APPs) and any relevant privacy code registered under the Privacy Act 1988.

Personal information is any information about you that identifies you and/or contains information or an opinion about you. Examples of personal information include your name and/or names used, your date of birth, tax file number, address, employment details, details of your financial circumstances, your financial needs and objectives, your investment history and preferences and your aversion or tolerance to risk.

Equitable Investors has established this Privacy Policy, which seeks to ensure Equitable Investors complies with the Australian Privacy Principles.

2. Why we need your Personal Information and how we use it

Equitable Investors and its trusted partners may collect personal information that is reasonably necessary for, or directly related to, its functions or activities. The "primary purpose" (the dominant or fundamental purpose for which that information is collected) is to establish, manage and provide our products and financial services.

In order to fulfill that primary purpose, information may be required for the purpose of assessing your application and meeting legal and regulatory requirements, such as compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act, the Corporations Act and Australian taxation laws.

Equitable Investors may use and disclose personal information about you so that we may:

• provide you with our products and services;

• to keep you updated in relation to the Fund's development and activities;

• let you know about other products or services we offer, send you information about special offers or invite you to events;

• protect our business and other customers from fraudulent or unlawful activity;

• consider any concerns or complaints you may have;

• comply with relevant laws, regulations and other legal obligations; and

• help us improve the products and services offered to our customers.

Direct Marketing

As noted above, we may also use and disclose your personal information to keep you informed about our financial products and services and those of related companies. When conducting our marketing activities, we may disclose some of that information to our service providers. You can opt out of receiving direct marketing information from us at any time (see the "Contact Equitable Investors about Privacy" section below).

3. What kinds of Personal Information we may collect and hold

The specific types of information we collect and reasons for collection may vary depending on particular circumstances. In general, however, personal information Equitable Investors may collect and hold includes (but is not limited to) the following:

• your name and title;

• contact details (including relevant addresses and telephone numbers);

• identification details, including government-related identifiers (such as date of birth, drivers licence or passport details);

• bank account information;

• financial records;

• tax file number;

• nature of your business activities;

• information received from you that may contain additional personal information, such as family relationships and other business-related connections; and

• qualifications, memberships and other accreditations.

We may also collect certain information that is not directly and specifically provided by you, such as information we may collect when you use our website (e.g. an IP address, browsing patterns, the status of cookies placed on a computer).

We do not collect any personal information other than information reasonably necessary for, or directly relating to, the primary purpose for which Equitable Investors has been engaged or may be engaged, or its other functions and activities.

Sensitive information

Sometimes we need to collect and use sensitive information. Sensitive information includes information or an opinion relating to a person’s racial or ethnic origin, political views or memberships, religious beliefs or affiliations, membership of a professional or trade association or trade union, sexual orientation or practices and criminal record. It also includes information about a person’s health and medical history.

The Australian Privacy Principles set out restrictions about the way sensitive information can be used. Unless you give us your consent, or if we are required or permitted by law, we will only use or disclose sensitive information for the purposes for which it was provided.

4. How we collect Personal Information

Equitable Investors has trusted partners who, on our behalf, are involved in collecting personal information. Equitable Investors and our trusted partners only collect personal information that has been directly provided to us by our clients or prospective clients, associates of clients, our suppliers or potential suppliers, our employees or potential employees, or is otherwise available in the public domain where this information will assist us with the provision of services to our current and prospective clients. Information may have been provided verbally or in writing (including by email or through web forms).

Equitable Investors may from time to time collect personal information concerning an associate of a client or a prospective client (e.g. a spouse or a child) where it is considered unreasonable or impracticable to seek this same information directly from the associate.

By way of example, we may at times seek personal information such as a name, address, date of birth and similar personal information directly from a client in relation to their associate (for example, their spouse, de-facto partner or their children) where we are satisfied that the associate would not object to the provision of that information to us in order for Equitable Investors to provide services involving that associate.

Also, our website may use cookies to identify site users and their interests and to track usage of the site. Cookies are small pieces of text stored on a computer that help us to know which browser the operator is using, where they have been on the site and any web sites to which they may link in order to use some of our features. By acceptance of our cookie, the user will be permitted access to certain pages of the site without having to log in each time they visit. A user who does not accept the cookie from the site may not be able to access certain areas of the site. We may also log IP addresses, or the location of computers on the internet to help diagnose problems with our server and to administer the site. You may adjust the security settings in your web browser to limit the collection of such information.

Please note that information about companies is not personal information. However the principles will apply to an individual who is carrying on a business as a sole trader.

Anonymity or Pseudonymity

If you wish to remain anonymous or to use a pseudonym when dealing with Equitable Investors, we may be able to provide you with limited information or services, such as general details about our products. However, it will often be impracticable for us to provide you with our products or financial services if you wish to remain anonymous or use a pseudonym as we are generally not permitted to issue a financial product to a person without first collecting their personal information.

5. Notification of the collection of Personal Information

When we are provided with personal information about an individual from a third party, we seek to ensure the individual is aware of certain matters, such as:

• Equitable Investors' identity and contact details;

• the fact that the information has been collected and the circumstances and purpose;

• if the collection was required or authorised under law or court/tribunal order;

• consequences of not having collected the information; and

• the information provided in this Privacy Policy

6. Disclosure of Personal Information

Personal information is not disclosed to a third party unless the disclosure is necessary to support the delivery of the client services for which Equitable Investors has been, or is expected to be, engaged, or is required by law.

The types of organisations we might disclose your personal information to include the Australian Taxation Office (ATO), our custodian, fund administrators, financiers, accountants and auditors, legal advisers, information technology providers and other professionals. Sometimes the law may require us to disclose personal information to government bodies such as the ATO or the Australian Transaction Reports and Analysis Centre (AUSTRAC).

Should it be necessary for Equitable Investors to forward personal information to third parties outside the firm, we will make every effort to ensure that the confidentiality of the information is protected.

Overseas disclosures

We may disclose personal information to recipients that are located outside Australia in some circumstances. Any disclosure of personal information to overseas recipients will be in accordance with our Privacy Policy. These recipients may be located in the following countries: the Philippines.

We may store electronic records locally in Australia or on secure "cloud" storage provided by operators with appropriate security regimes in place.

In the event that personal information is disclosed to overseas recipients, Equitable Investors will take all reasonable steps to ensure that any personal information is secure and treated in accordance with the Australian Privacy Principles.

7. How we store your Personal Information

Equitable Investors will take all reasonable steps to protect against the loss, misuse and/or alteration of the information under its control, including through appropriate physical and electronic security strategies. Only authorised Equitable Investors personnel and trusted third parties are provided access to personal information, and these parties are required to treat this information as confidential. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will destroy or de-identify these records.

We may store electronic records locally in Australia or on secure "cloud" storage provided by operators with appropriate security regimes in place.

8. Accuracy of Personal Information

Equitable Investors will take all reasonable steps to make sure that any personal information collected, used or disclosed is accurate, complete and up to date.

If a person believes that the information we hold is inaccurate or out of date, they may contact our Privacy Officer and we will update the relevant information accordingly.

9. Access to Personal Information

Under the Australian Privacy Principles, a person has the right to request access to any personal information that we may hold about them and to advise us if the information should be corrected. The Australian Privacy Principles set out the circumstances when we can refuse those requests. If we do refuse a request, we will provide the person with a written notice that sets out the reasons (unless it would be unreasonable to provide them).

Subject to our right to refuse access, Equitable Investors will provide the person with a report that lists any personal information that we may hold.

Our policy is to provide written acknowledgement of our receipt of any request for access to personal information or a request for correction of personal information within seven days of the request being received. We will then provide a written response within 30 days of our receipt of the request.

10. Contact Equitable Investors about Privacy

If you wish to make an enquiry about your personal information at Equitable Investors, or make a complaint because you believe that we may have breached the Australian Privacy Principles or a privacy code that applies to us, please contact us in one of the following ways:

• email our nominated Privacy Officer at privacy@equitableinvestors.com.au

• write to The Privacy Officer, Equitable Investors Pty Ltd, PO Box 18106, Melbourne, Victoria, 3001

We will respond to each request within a reasonable time.

If a party has lodged a complaint with Equitable Investors and is not satisfied with our response, they may contact The Office of the Australian Information Commissioner.