Privacy Policy

1. Introduction

Ekam Capital Pty Ltd (ABN 74 653 511 338) (referred to in this policy as Ekam Capital, we, us, or our) respects the privacy of individuals and is committed to protecting personal information.

This Privacy Policy explains how we collect, hold, use and disclose personal information in connection with:

• our website
• our investor portal
• investment opportunities offered, managed or administered by Ekam Capital or related entities
• our communications with investors, prospective investors, professional partners and other stakeholders.

This policy is intended to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By using our website, services, or investor portal, you consent to the handling of your personal information in accordance with this Privacy Policy.

2. What Personal Information We Collect

Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable.

Examples include:

• name
• contact details
• financial information
• identification documents
• investment details
• online identifiers such as IP address.

3. Types of Personal Information We Collect

Depending on your interaction with us, we may collect the following categories of personal information.

Identity Information

• name
• date of birth
• nationality
• identification documents (such as passport or driver's licence)

Contact Information

• email address
• phone number
• residential address
• postal address

Investor Information

• investment holdings
• transaction history
• bank account details
• tax residency information
• investor classification (e.g. wholesale or sophisticated investor)

Verification Information

To comply with regulatory obligations we may collect:

• AML/KYC documentation
• beneficial ownership information
• source of funds declarations.

Employment Information

Where individuals apply for employment with us we may collect:

• CVs
• employment history
• references.

Website and Technical Information

When you visit our website we may collect:

• IP address
• browser type
• device information
• pages visited
• referring websites.

4. How We Collect Personal Information

We collect personal information in several ways.

4.1 Directly from individuals

This includes when you:

• complete investment applications
• register for our investor portal
• subscribe to updates or newsletters
• communicate with us
• apply for employment.

4.2 Through third parties

We may receive personal information from:

• financial advisers
• brokers
• professional advisers
• identity verification providers
• service providers assisting with investor onboarding.

4.3 Automatically through website technologies

When individuals use our website we may collect information through:

• cookies
• analytics platforms
• website tracking tools.

5. Purposes for Collecting Personal Information

We collect and use personal information for purposes including:

Investment administration

• processing investment applications
• managing investor records
• administering distributions and transactions
• communicating with investors about their investments.

Regulatory compliance

• complying with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006
• verifying identity
• meeting regulatory reporting requirements.

Communication and investor relations

• sending investment updates
• responding to enquiries
• providing investor communications.

Marketing

Where permitted by law, we may use personal information to send:

• investment updates
• newsletters
• invitations to events.

Individuals may opt out of marketing communications at any time by clicking the unsubscribe link included in our emails or contacting us directly.

Website improvement

• analysing website usage
• improving our services
• maintaining system security.

6. Disclosure of Personal Information

We may disclose personal information to third parties where reasonably necessary for the purposes described above.

These may include:

• trustees
• fund administrators
• registry providers
• custodians
• professional advisers (lawyers, accountants)
• compliance and regulatory service providers
• IT and cloud service providers
• identity verification providers
• marketing service providers
• regulators and government agencies.

We take reasonable steps to ensure that service providers handle personal information in accordance with applicable privacy laws.

7. Overseas Disclosure of Personal Information

Some of our service providers may store or process personal information outside Australia.

These may include providers located in jurisdictions such as:

• United States
• European Union
• other locations where cloud infrastructure providers operate.

Where personal information is disclosed overseas, we take reasonable steps to ensure that those recipients comply with applicable privacy obligations.

8. Security of Personal Information

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

Security measures may include:

• secure cloud infrastructure
• restricted system access
• data encryption where appropriate
• staff confidentiality obligations
• contractual privacy obligations with service providers.

However, no method of transmission over the internet is completely secure.

9. Cookies and Website Analytics

9.1 What are cookies

Cookies are small text files stored on a user's device when they visit a website. Cookies help websites recognise users, remember preferences and collect information about how a website is used.

9.2 Types of cookies we may use

Our website may use the following categories of cookies:

Essential cookies

These cookies are necessary for the operation of our website and enable core functionality such as page navigation and access to secure areas.

Analytics cookies

We may use analytics tools (such as Google Analytics or similar services) to collect information about how visitors use our website. This may include:

• pages visited
• time spent on pages
• referring websites
• general geographic location
• device and browser information.

This information helps us understand website usage and improve website performance.

Functional cookies

These cookies allow the website to remember user preferences and improve the browsing experience.

9.3 Information collected through cookies

Information collected through cookies may include:

• IP address
• browser type
• device type
• pages visited
• time and date of visits
• referring websites.

In most cases this information is aggregated and does not directly identify individuals.

9.4 Managing cookies

Most internet browsers allow users to control cookies through browser settings. Users can choose to block or delete cookies.

However, disabling cookies may affect the functionality of some parts of our website.

9.5 Third-party services

Some cookies may be set by third-party services used on our website, including analytics providers and embedded services. These third parties may collect and process information in accordance with their own privacy policies.

10. Access and Correction of Personal Information

Individuals may request access to personal information that we hold about them.

If personal information is inaccurate, incomplete or outdated, individuals may request correction.

Requests should be made using the contact details provided below.

We may require identity verification before providing access to personal information.

11. Retention of Personal Information

We retain personal information only for as long as necessary for the purposes for which it was collected.

This includes retaining information to comply with:

• legal obligations
• regulatory requirements
• accounting or reporting requirements.

Certain investor records may be retained for extended periods as required by law.

12. Complaints

If you wish to access or correct Personal Information, or make a complaint regarding our handling of Personal Information, you may contact our Privacy Officer:

Privacy Officer
Ekam Capital Pty Ltd

Email: investors@ekamcapital.com.au

We will investigate any privacy complaint and notify you of the outcome.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner:

https://www.oaic.gov.au

13. Notifiable Data Breaches

If Ekam Capital becomes aware of a data breach involving Personal Information that is likely to result in serious harm, we will respond in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

This may include notifying affected individuals and the Office of the Australian Information Commissioner.

14. Your Rights

You may request access to Personal Information we hold about you.

You may also request that we correct any inaccurate information.

Requests can be made by contacting us using the details below.

We may charge reasonable administrative costs for providing access to large volumes of information.

We will respond to requests within a reasonable timeframe.

15. Electronic communications

By using the Investor Portal or providing your contact details to Ekam Capital, you consent to receiving communications electronically.

These communications may include:

• investor reports
• distribution notices
• regulatory notices
• investor statements
• tax information
• service updates.

Electronic communications may be delivered via:

• the Investor Portal
• email
• secure document delivery systems.

You are responsible for ensuring that your contact details remain accurate.

16. Contact and Complaints

If you wish to access or correct Personal Information, or make a complaint regarding our handling of Personal Information, you may contact our Privacy Officer:

Privacy Officer
Ekam Capital Pty Ltd

Email: investors@ekamcapital.com.au

We will investigate any privacy complaint and notify you of the outcome.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner:

https://www.oaic.gov.au

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Any updates will be published on our website or Investor Portal.

Where changes are significant, we will notify you by email or through the portal.