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Effective Date: April 2025 | Last Updated: April 2025
Exto Partners Pty Ltd (ABN 38 104130 636, AFSL No. 478994) (“Exto Partners”, “we”, “us”, or “our”) is committedto protecting the privacy of individuals who interact with our website atextopartners.com (the “Site”). This Privacy Policy explains how we collect,use, disclose, and manage your personal information in accordance with thePrivacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
By using the Site, you acknowledgethat you have read and understood this Privacy Policy.
Exto Partners Pty Ltd is anAustralian specialist alternative asset manager focused on secondary marketinvestment in late-stage unlisted global technology companies. We areauthorised to provide financial product advice, deal in financial products, andprovide custodial and depository services to wholesale clients only under AFSLNo. 478994.
We collect personal informationthat you provide directly to us and information gathered automatically when youuse the Site. This may include:
Contact form submissions:
• Your name, email address,phone number, and the content of your enquiry.
Investor enquiries and KYCdata:
• Identity verificationdocuments (e.g. passport, driver’s licence), financial position details, taxfile numbers, and information required to comply with our obligations under theAnti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and applicableKYC regulations.
Email newsletter sign-ups:
• Your name and email addressfor the purposes of distributing fund updates, investment commentary, andmarket insights.
Analytics and cookies:
• Technical data collectedautomatically including IP address, browser type, pages visited, time spent onpages, and referral source. This is collected via cookies and similar trackingtechnologies (see Section 7).
We use the information we collectfor the following purposes:
• To respond to enquiriessubmitted via our contact form.
• To assess eligibility andonboard wholesale investors in accordance with applicable law.
• To conduct identityverification and comply with our AML/CTF and KYC obligations.
• To send fund updates,investment commentary, and market communications where you have opted in.
• To monitor and improve theperformance and functionality of the Site.
• To comply with our legaland regulatory obligations as an AFSL holder.
We do not sell your personalinformation. We may disclose your information to:
• Our professional advisers,including lawyers, auditors, and compliance consultants, bound byconfidentiality obligations.
• Regulatory bodies,including ASIC and AUSTRAC, where required by law.
• Third-party serviceproviders (e.g. technology platforms, custody providers, fund administrators)engaged to assist with our operations, under appropriate data protectionarrangements.
• Other parties where youhave consented to disclosure, or where disclosure is otherwise required orpermitted by law.
Where we disclose personalinformation to overseas recipients, we take reasonable steps to ensure thatthose recipients handle your information in accordance with the APPs orequivalent standards.
We implement reasonable technicaland organisational measures to protect personal information from unauthorisedaccess, loss, misuse, or disclosure. However, no method of transmission overthe internet is completely secure, and we cannot guarantee absolute security.
We retain personal information foras long as necessary to fulfil the purposes described in this Policy, or asrequired by applicable law (including the seven-year record-keeping obligationsapplicable to AFSL holders). Investor KYC records are retained in accordancewith AML/CTF legislative requirements.
Our Site uses cookies and similartracking technologies to analyse traffic and improve user experience. Cookiesare small files placed on your device. You may disable cookies via your browsersettings; however, some functionality of the Site may be affected.
We use analytics tools (such asGoogle Analytics) that collect anonymised data about Site usage. This data isaggregated and does not identify you personally.
Where you have opted in to receiveour newsletter or investment commentary, we will use your contact details forthat purpose. You may unsubscribe at any time by clicking the unsubscribe linkin any communication or by contacting us directly. We will process your requestpromptly.
Under the Privacy Act 1988 (Cth),you have the right to:
• Request access to thepersonal information we hold about you.
• Request correction ofinformation that is inaccurate, incomplete, or out of date.
• Make a complaint if youbelieve we have breached the APPs.
To exercise any of these rights,please contact us using the details in Section 11. We will respond to accessand correction requests within a reasonable timeframe (generally 30 days).
If you have a complaint regardinghow we have handled your personal information, please contact our PrivacyOfficer in the first instance. If you are not satisfied with our response, youmay escalate your complaint to the Office of the Australian InformationCommissioner (OAIC) at www.oaic.gov.au.
For privacy-related enquiries,access requests, or complaints, please contact:
Exto Partners Pty Ltd
Privacy Officer
Email: info@extopartners.com
Website: extopartners.com
We may update this Privacy Policyfrom time to time. The current version will always be available on our Site.Material changes will be notified via the Site or by direct communication whereappropriate. Your continued use of the Site following any update constitutesacceptance of the revised Policy.
This PrivacyPolicy applies to Exto Partners Pty Ltd (ABN 38 104 130 636, AFSL No. 478994).Exto Partners is authorised to deal in financial products and provide financialproduct advice to wholesale clients only. This document does not constitutefinancial product advice.