Privacy policy
We handle your data with the same rigour we apply to capital.
- Siare respects your privacy and handles personal information with institutional care.
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- We collect only what we need to serve you as an investor, borrower, or partner.
- Your data is encrypted, stored securely, and never sold to third parties.
Information we collect
We gather personal details when you request information, submit an application through the Investor Portal, or engage with our platform. Depending on your dealings with us, this may include your identity and contact details; wholesale, sophisticated or professional investor eligibility evidence (such as accountant's certificates); bank account, holdings and transaction information; tax information including your TFN, ABN and country of tax residency; identification documents required under the AML/CTF Act; and details of any authorised adviser or representative.
We also collect technical information through cookies and analytics to understand how you use our website and to improve your experience. This includes your IP address, browser type, pages visited, and time spent on site.
How we use your information
Your data enables us to assess and process applications, verify your identity and investor eligibility, establish and administer your investment — including maintaining the register, processing distributions and withdrawals, and unit pricing — and meet our obligations under the Corporations Act, taxation laws and the AML/CTF Act. With your consent or as permitted by law, we may also tell you about other investment opportunities we offer. If you choose not to provide your TFN or ABN, we may be required to withhold tax from distributions at the highest marginal rate.
We analyse aggregated data to refine our offerings and enhance platform performance. We never use your information for marketing purposes without your explicit consent.
Who we share your data with
We share information with the Fund's trustee (Bardin Capital) and our related bodies corporate; with service providers who help us operate the Fund, including the fund administrator (Ascent Fund Services) and registry provider (Registry Direct); with your authorised representatives such as your accountant or financial adviser; and with regulators and government authorities including ASIC, the ATO and AUSTRAC where required or authorised by law.
We may disclose information when required by law, regulation, or court order. We work only with providers who meet our security standards and contractual obligations.
Data security and retention
We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access. Our registry provider maintains security controls including encryption in transit and at rest, multi-factor authentication, role-based access, audit logging and regular penetration testing. We retain personal information only as long as necessary for the purposes described or as required by law, after which it is destroyed or de-identified.
We retain your data for as long as necessary to fulfil our obligations and comply with legal requirements. Once no longer needed, we securely delete or anonymise it.
Your rights
You have the right to access, correct, or request deletion of your personal information. You can opt out of non-essential communications at any time. You may lodge a complaint with the Office of the Australian Information Commissioner if you believe we have mishandled your data.
To exercise these rights, contact our Privacy Officer at privacy@siare.com.au. We will respond within a reasonable period. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or 1300 363 992.
Cookies and tracking
We use cookies to remember your preferences and track site usage. You can disable cookies in your browser settings, though this may limit functionality.
We do not use cookies for targeted advertising or behavioural tracking beyond our own platform.
International transfers
The Fund's registry and records are hosted in Australia (Sydney region). Some service providers or their sub-processors may be located, or store data, outside Australia — where personal information is disclosed overseas, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles.
Changes to this policy
We may update this privacy policy to reflect changes in our practices or legal requirements. We will notify you of material changes by email or by posting a notice on our website.