Privacy Policy
Privacy
Sandon Capital is committed to protecting your privacy in accordance with the law. We have a policy concerning any personal information we hold about you and the following is a summary. Our policy is available free on request.
Personal information is information or an opinion that identifies, or could reasonably identify, an individual.
Why do we collect personal information?
We collect personal information so we can provide products and services, respond to enquiries and complaints, communicate with you, administer our business relationships, and comply with legal and regulatory obligations.
We may also use personal information to monitor, evaluate and improve our products and services, conduct research and analytics, provide information about our services and products (including marketing communications, which you can opt out of), and support our business operations and communications.
We usually collect personal information directly from you (for example, through forms, applications, subscriptions, enquiries, events and ongoing communications), but we may also collect information from related sources, publicly available sources (where lawful and fair), service providers, advisers, brokers, or the Trustee and its service providers where relevant.
If you do not provide information we reasonably require, we (or others) may not be able to provide you with requested products or services.
If you would like to opt out of communications, update or correct your information, or make a privacy complaint, please contact us.
What personal information do we ask for?
The types of personal information we may collect include your name, contact details (such as address, phone number and email), website activity, email interactions, event attendance, correspondence and other interactions with Sandon Capital.
Depending on the circumstances, the Trustee, Registry or its service providers (rather than Sandon Capital) may collect and hold additional information relating to fund or share investments under their own privacy policies.
If you choose not to provide information needed to fulfil a request for a particular product or service, we may not be able to provide that product or service.
Our disclosure and information practices
We collect personal information by fair and lawful means and aim not to be unreasonably intrusive.
We may share personal information with our staff, contractors, related entities and third-party service providers who help us operate our business and provide services (for example, technology providers, professional advisers and other service providers). They are required to handle personal information confidentially and protect it from misuse, interference and loss, and from unauthorised access, modification and disclosure.
Use of AI tools
We may use artificial intelligence and large language model (AI) tools to support business functions including analysing engagement or investor data. This may involve entering personal information into AI tools. Where we use AI tools with personal information, we apply controls, including limiting use to authorised staff, using the minimum personal information necessary (and de-identifying information where practicable), and using business/enterprise tools configured for security and confidentiality rather than public or free AI tools.
AI tools are used for decision support only. Our staff remain responsible for reviewing outputs for accuracy and appropriateness before use. We do not currently rely on fully automated decision-making (including profiling) that produces legal or similarly significant effects based solely on automated processing of personal information.
We may also analyse information we hold to generate insights (for example, contact segments, engagement scores or communication labels) to improve communications and services. Where those insights can be linked to an individual, we treat them as personal information.
Overseas disclosure
Some third-party service providers we use may be located in, or operate from, countries outside Australia. As a result, personal information may be stored, processed or accessed overseas (including via cloud and technology providers).
Before disclosing personal information overseas, we take reasonable steps to ensure overseas recipients handle the information appropriately, including through due diligence, contractual protections and security measures. In some cases, it may not be practicable to identify all countries in which information may be located.
How do we store your personal information?
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification and disclosure.
Personal information may be stored in physical and electronic systems, including with reputable cloud and other IT service providers. We use physical, technical and organisational safeguards, including access controls and secure storage arrangements.
No method of transmission or storage is completely secure, and we cannot guarantee the security of information transmitted to or by us, including via the internet. However, we continuously work to protect personal information and improve our security practices.
We also take reasonable steps to destroy or permanently de-identify personal information that we no longer need, where lawful and reasonable to do so.
What else?
You can request access to personal information we hold about you, and ask us to correct it if it is inaccurate, incomplete or out of date (subject to legal exceptions).
In most cases we need to identify you (for legal, regulatory and security reasons). Where lawful and practicable, you may deal with us anonymously or using a pseudonym.
If you ask us to stop marketing to you, we will do so. We may still retain certain personal information where required or permitted by law.
From time to time we may inform you of products and services we think may be relevant to you. Please let us know if you do not wish to receive these communications.
We have processes for identifying, assessing and responding to actual or suspected data breaches involving personal information. We will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as required by law.
How do we use cookies and web analytics?
Sandon Capital may use cookies to provide a better website experience. Cookies are small pieces of data stored on your device that help us understand how visitors use our website (for example, pages visited, how users navigate the site and where visitors came from).
We may use cookies and analytics to:
- improve website functionality and user experience,
- understand traffic and content engagement trends, and
- support marketing and website content decisions.
We may use website usage information (including aggregated and analytics data) for marketing and audience development purposes. Some of this information may be processed by third-party analytics or advertising providers.
You can configure your browser to accept or reject cookies, although some site features may not function properly if cookies are disabled.
Third party websites
Sandon Capital’s website may contain links to external websites. These sites are not covered by this privacy statement. You should review the privacy policies of those third-party websites before using them.
Complaints
We aim to meet high standards, but we understand there may be times when you wish to make a complaint about how your personal information has been handled.
If you have a privacy complaint, please contact us first and we will try to resolve the issue promptly.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or on 1300 363 992.
Contact us
Contact our Privacy Officer if you have questions, and including to:
- discuss this policy or request a copy,
- opt out of communications,
- access, update or correct personal information we hold about you, or
- complain about a privacy issue.
You can reach our Privacy Officer here:
- email: info@sandoncapital.com.au
- phone: +61 2 8014 1188