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Privacy & Legal

Privacy Policy

1835i Group Pty Ltd ABN 43 647 702 716 (1835i, us, we, our) takes your privacy seriously and is committed to responsible privacy practices. We seek to comply with our obligations under the Privacy Act 1988 (Cth) (Privacy Act).  This Privacy Policy describes how we collect, use, disclose, store, and handle your personal information.

What is personal information?

In this Privacy Policy, 'personal information' has the meaning set out in the Privacy Act.  In general terms, personal information is information (whether fact or opinion) about an individual who is identified or reasonably identifiable.

Some types of personal information are designated as 'sensitive information', which are subject to additional protection under the Privacy Act.  For example, these can include information about your health.

What types of personal information do we collect?

The types of personal information we collect about you will depend on the purpose for which the personal information is collected.  This can include:

- if you contact us about a product, service, partnership, business or venture – your name, mailing or street address, email address, and telephone number(s), any personal information provided as part of your pitch to us and any details you provide related to an idea you may have about a such a product, service, solution, partnership, business or venture;

- if you have requested to receive news about events – your name, mailing or street address, email address, and telephone number(s);

- if you have contacted us to make a complaint, provide feedback, submit an enquiry, request a call-back – your name, mailing or street address, email address, and telephone number(s);

- in the case of prospective employees or contractors – information contained in your application or résumé, recorded during any interview, or obtained through any pre-employment checks, and government-issued identifiers such as tax file numbers;

- in the case of prospective investors or founders – information contained in your enquiry or in your résumé, recorded during any interview, or obtained through any pre-employment checks, and government-issued identifiers such as tax file numbers; and

- in the case of our investors, suppliers and distributors – your name, mailing or street address, email address, and telephone number(s).

Sensitive information

Generally, we will not collect sensitive information about you. However, in certain circumstances, we may need to collect limited sensitive information.  If we need to as part of the work we do, we will ask your permission and only use it for that purpose.

How do we collect personal information?

We collect your personal information directly from you, including when you:

- access or use our websites;

- sign up to receive news and events;

- enter surveys, competitions, promotions or requesting information or material from us;

- make inquiries about us or our products or services or otherwise communicate with us by email, by telephone, in person, via a website, via our social media channels (e.g. LinkedIn, Twitter, Facebook) or otherwise; and

- apply to work with us or are engaged by us as a contractor.

Where it is reasonable and practicable to do so, we will only collect personal information about you from you directly and not from third parties.  In limited circumstances, we may collect personal information about you from e.g. publicly available sources (such as the Internet) and from third parties (such as mutual contacts, or if someone makes a purchase on your behalf, or your referees provided during the recruitment process if you apply for a job with us).  We may also collect personal information through third parties such as our service providers and through promotional and marketing activities.

We also use the following technologies to collect technical information and general analytics:

- cookies, which are data files that are placed on your device and often include an anonymous unique identifier.  For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org;

- log files, which track actions occurring on our websites; and

- web beacons, tags, and pixels, which are electronic files used to record information about how you browse our websites.

By using our websites, you are consenting to the use of these technologies in accordance with this Privacy Policy.

Can you choose not to disclose your personal information?

If you contact us to make a general enquiry about us or our business, you do not have to identify yourself or provide any personal information.  Alternatively, you can also notify us that you wish to deal with us using a pseudonym. 

However, if we are not able to collect personal information about you, we may not be able to provide you with the information or assistance you require.  For example, we will not be able to send you information you have requested if you have not provided us with a valid email address or telephone number.

How do we use your personal information?

In general, we use your personal information for purposes connected with our business.

Some of the specific purposes for which we use your personal information are as follows:

- to provide our products and services to our customers or to receive goods or services from third parties;

- to review and consider concepts and other commercial arrangements about a product, service, solution, partnership, business, investment or venture which you have contacted us about;

- to improve the products and services which we provide;                

- to manage and administer any investments we have with third parties, including portfolio companies for the purpose of governance, reporting or any other regulatory requirement;

- to enable the proper operation and functionality of our website;

- to verify your identity (for example, if you request access to the personal information we hold about you);

- to consider you for a job at 1835i (whether as an employee or contractor) or other relationships with us;

- to communicate with you and to address any issues or complaints that we or you may have regarding our relationship or provide any relevant customer support;

- for direct marketing purposes (see the "Direct marketing" section below); and

- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

We may also use or disclose your personal information for e.g. our administrative, marketing (including direct marketing), survey and research purposes, investment related proposals and for other purposes to which you have consented, or as otherwise permitted or required by law.

Technical information and general analytics is used for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are on our websites, and to improve our websites and our products and services.

To whom do we disclose personal information?

We may disclose your personal information to third parties in connection with the purposes described above (see the "How do we use your personal information?" section above).

This may include disclosing your personal information to the following types of third parties:

- our related companies;

- any existing or potential investor in any fund managed by us or any portfolio company of a fund managed by us;

- any potential third party acquirer of our business or assets, and advisors to that third party;

- our professional advisers (such as lawyers, accountants or auditors) and insurers;

- our employees, contractors and third party service providers who assist us in performing our functions and activities e.g. payment systems operators and financial institutions, cloud service providers, data storage providers, shipping companies, telecommunications providers and IT support services providers;

- organisations authorised by us to conduct promotional, research or marketing activities;

- third parties to whom you have authorised us to disclose your information (e.g. referees); and

- any other person as required or permitted by law.

If we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information.

Direct marketing communications

We will only send you direct marketing communications (either through mail, SMS or email), including offers any news or events, where you have consented to do so.

You may opt-out of receiving direct marketing communications at any time by contacting us or by using opt-out facilities provided in the direct marketing communications.

Does personal information leave Australia?

We store personal information in servers located in Australia as well as through third party service providers located overseas, such as in Singapore.  We may disclose your personal information to overseas recipients, such as to e.g. our investors, and service providers located overseas, in order to support our technology and operational teams. 

Except where an exception applies under the Privacy Act or other relevant legislation, we will take commercially reasonable steps to ensure that overseas recipients to whom we disclose personal information do not breach the Australian Privacy Principles stated in the Privacy Act in relation to such information.

How do we protect your personal information?

We will take reasonable precautions to protect your personal information from misuse, loss, or unauthorised access, modification or disclosure.  However, as the Internet is inherently insecure, we cannot guarantee the security of transmission of personal information you disclose to us online.  Accordingly, you transmit your personal information to us online at your own risk.

Please notify us immediately if you become aware of any breach of security. 

How long do we keep your personal information?

Generally, we will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this Privacy Policy) unless a longer retention period is required by law or if it is reasonably necessary for us to comply with our legal obligations, resolve a dispute or maintain security.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us.  We will provide access to that information in accordance with the Privacy Act, subject to any exemptions that may apply.  We may charge an administration fee in limited circumstances.  

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting us.

What is the process for complaining about a breach of privacy?

If you have any questions, concerns or complaints about our collection, use, disclosure or management of your personal information, please contact us in writing using the contact details below. We will make inquiries and your complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.

If you are unsatisfied with the outcome, we will advise you about further options including, if appropriate, review by the Privacy Commissioner within the Office of the Australian Information Commissioner.

Local exemptions and inconsistency with law

Where local laws allow for an exemption to compliance with certain legal obligations (for example, the employee records exemption in Australia), we may rely on such an exemption.

This Privacy Policy will not apply to the extent that it is inconsistent with any applicable law.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time at our discretion.  Amendments to this Privacy Policy will be posted on our websites.  Your continued dealings with us, for example use of its websites, products or services, will signify your agreement to this Privacy Policy as amended.

How to contact us

If you have a query, concern or complaint about the manner in which your personal information has been collected or handled by us or would like to request access to or correction of the personal information we hold about you, please contact using the details provided below:

Justin Greenstein

Attention: Chief Operating Officer

Level 41, 55 Collins Street Melbourne, VIC, 3000

justin@1835i.com

Last updated: 19 July 2021