Privacy Policy

Scope

This privacy policy relates to Kalakau Avenue Pty Ltd (ACN 668 312 061) (”Kalakau Avenue”) as an authorised representative of Tanarra Capital Australia Pty Ltd (ACN 114 164 331, AFSL No. 290098).
The policy explains how Kalakau Avenue collects, holds, uses, discloses and protects your personal information. It also explains how you may update your personal information that Kalakau Avenue holds and how you may make a complaint about how Kalakau Avenue has handled that personal information.
By accessing Kalakau Avenue’s website, investing in financial products in Kalakau Avenue funds or investments, or using Kalakau Avenue’s services, you consent to Kalakau venue collecting, holding, using and disclosing your personal information as described in this policy.

Collection of personal information

The information that Kalakau Avenue collects depends on the nature of your interaction with Kalakau Avenue. If you invest in funds or other financial products made available by Kalakau Avenue, personal information about you, such as your name, address, date of birth, contact details (including email address), occupation, bank account information and, potentially, tax file number, is collected through our documents, such as fund application forms and mandate letters and agreements.
When you access Kalakau Avenue’s website, Kalakau Avenue may collect technical and navigational information, such as device type, browser type, internet protocol addresses, pages visited, average time spent, user journeys and demographics and the time and date of access. Such information is collected anonymously and is used by Kalakau Avenue to analyse the efficiency of its marketing and publicity efforts as well as the design and functionality of the website.
Kalakau Avenue may collect your name, investor number, address, phone number, email address and postcode when you complete or sign up to publications available on or through this website or indirectly through emails, forms, face-to-face or electronic meetings, registration and attendance at seminars, business cards, online inquiries and telephone conversations, as well as through the website, blogs and social media channels which may involve the use of cookies. You should be able to control your browser setting to limit or exclude the collection of cookies by Kalakau Avenue; however, if you do so, you may not be able to use certain features of the website. The information is used by Kalakau Avenue to provide you with online access to details of your investments with Kalakau Avenue or to provide you with information, educational material, publicity and marketing material.

Use of personal information

If you invest with a Kalakau Avenue fund or investment, we use your personal information to establish and administer your investment, comply with applicable laws, including the Anti-Money Laundering and Counter-Terrorism Financing Act and Rules and to communicate with you in relation to your investments.
Kalakau Avenue may also use your personal information for the primary purposes for which it was collected, including:

the provision of educational, promotional and marketing material;
the provision of Kalakau Avenue’s services; and
assisting Kalakau Avenue to manage, develop and enhance its services, including this website, Kalakau Avenue reports and publications.

Kalakau Avenue may also use your personal information for other purposes to which you consent or which are required or permitted by law. This may include for a secondary purpose that is related to a purpose for which Kalakau Avenue collected it, and for which you would reasonably expect Kalakau Avenue to use.
If at any time you would like to unsubscribe from receiving future content, surveys, features or other marketing material or communications, Kalakau Avenue includes in all electronic messages a statement to the effect that you, as the recipient, may send an unsubscribe message to Kalakau Avenue using the contact details in that electronic message. Otherwise, you can contact Kalakau Avenue’s privacy officer at any time at the contact details below to unsubscribe or to update your preferences.
Kalakau Avenue does not actively seek to collect sensitive information, such as health information or information about criminal records, unless it is required by law, or for business purposes. If Kalakau Avenue does have to collect sensitive information, Kalakau Avenue will only collect, use and disclose the information in accordance with applicable privacy laws.

Disclosure of personal information

Kalakau Avenue may disclose your personal information (including in certain limited circumstances, your sensitive information) to:

a member of the Kalakau Avenue group (i.e. any related body corporate of Kalakau Avenue Pty Ltd);
Kalakau Avenue’s external service providers that provide investment administration, registry, custody, hosting, data storage or other services;
any entity with which Kalakau Avenue jointly or co-invests;
any external party you authorise, such as a licensed or authorised financial adviser, dealer group or operator of an investor directed portfolio service;
any party where Kalakau Avenue is required or authorised to do so by law; and
Courts and tribunals as well as governmental or regulatory bodies and agencies, such as ASIC, the ATO, AUSTRAC or a law enforcement body or agency.

Kalakau Avenue uses third party investment administrators and registries to support the administration of Kalakau Avenue funds and other investments. Kalakau Avenue has contractual arrangements with these service providers to ensure they comply with privacy laws when dealing with your personal information.
Kalakau Avenue may provide links to websites operated by third parties. Kalakau Avenue makes no representations or warranties in relation to the privacy practices of any third party or third-party website and Kalakau Avenue is not responsible for the privacy policies or the content of any third party or of any third-party website. If you visit a third-party website, including through a link on this website, the third-party website will be governed by its own terms of use, including privacy policies.

Accessing and correcting personal information

If you require access to, or wish to update or correct your personal information, please contact Kalakau Avenue’s privacy officer at privacy@kalakauavenue.com
If you believe that your personal information that Kalakau Avenue holds is inaccurate, incomplete or out-of-date, you should contact Kalakau Avenue’s privacy officer at the above details to correct the information. Kalakau Avenue will require you to verify your identity and to specify what information you wish to have access to.
Kalakau Avenue will endeavour to promptly update any personal information that is inaccurate, incomplete or out-of-date. If Kalakau Avenue does not agree that the personal information is inaccurate, incomplete or out-of-date, Kalakau Avenue will notify you in writing of the reasons to refuse any correction or update. Kalakau Avenue will also notify you of what you can do if you are not satisfied with Kalakau Avenue’s response.

Protecting personal information

Kalakau Avenue will take reasonable steps to protect your personal information that we hold from misuse, loss, unauthorised access, interference, unauthorised modification or unauthorised disclosure.
Kalakau Avenue has physical, electronic and procedural safeguards to protect such personal information, for example by use of physical security and restricted access to electronic records. Access to information stored electronically is restricted to Kalakau Avenue employees whose job purpose requires access. Kalakau Avenue also requires all employees to maintain the confidentiality of client information except as otherwise required by law.

Eligible data breach

Kalakau Avenue’s service providers are required to notify Kalakau Avenue of any unauthorised access to, or disclosure or loss of, personal information.
In such a circumstance, Kalakau Avenue performs an assessment to determine if there has been an ‘eligible data breach’ whereby the access or disclosure of the personal information is likely to result in serious harm to the individuals to whom the information relates. If Kalakau Avenue determines there has been an ‘eligible data breach’, then the individuals affected will be notified as soon as practicable of the details of the breach and the recommended steps to take in response to it. If required, Kalakau Avenue will also inform the Office of the Australian Information Commissioner at the same time.

Privacy related complaints

If you have any questions about privacy-related issues or wish to complain about a breach of your privacy or the handling of your personal information by Kalakau Avenue, please contact Kalakau Avenue’s privacy officer (details above).
Kalakau Avenue may ask you to lodge your complaint in writing
Any complaint will be investigated by the privacy officer and you will be notified of the making of a decision about your complaint as soon as is practicable after it has been made, usually 90 days.
If Kalakau Avenue is unable to resolve your complaint satisfactorily or your concerns about Kalakau Avenue’s handling of your personal information, you can contact the Office of the Australian Information Commissioner:

GPO Box 5218 Sydney NSW 2001 Email: enquiries@oaic.gov.au | Tel: 1300 363 992 | Website: www.oaic.gov.au

Updates to this policy

Kalakau Avenue will review this policy from time to time to take account of new laws and technology, changes to Kalakau Avenue’s operations and practices, and the changing business environment.
The most current version of this policy is located at kalakauavenue.com/privacy-policy and can also be obtained by contacting Kalakau Avenue’s privacy officer at the above address.