1. Who are we?

In this Policy, references to "Fundstream Designated Business Group" ("Fundstream DBG") includes "Fundstream Pty Ltd", "Fundstream Asset Management Pty Ltd", "Fundstream Financial Services Pty Ltd", "TC Security 001 Pty Ltd", "Fundstream Holdings Pty Ltd", "Titan Capital Security Pty Ltd", "We", "Us" and "Our" (together "Fundstream DBG") and any other entity forming part of the "Fundstream DBG" group of related entities.

This Policy applies to all current and former employees of "Fundstream DBG", including permanent employees (full-time, part-time, or casual) and temporary employees (agency employees, contractors, casuals and consultants) as well as executives and non-executive directors, any independent board committee members that are not directors and any third parties acting on behalf of "Fundstream DBG".

2. Link to our website

https://fundstream.com.au/

3. Link to our Privacy Policy

https://fundstream.com.au/legal/privacy-policy

4. Our Commitment to Protect Your Privacy

We recognise that your privacy is important to you.

We understand how important it is to protect your personal information.

This document sets out our commitment to you in respect of personal information we hold about you and what we do with that information.

We will only use personal information we collect about you for the purposes we have collected it for, or as allowed under the law.

It is important to us that you are confident that we will treat any personal information we hold about you in a way which ensures protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act 1988 (Cth) (Privacy Act) and any other relevant law, including the Privacy (Credit Reporting) Code 2024 (Credit Reporting Code) issued by the Office of the Australian Information Commissioner (OAIC) to the extent we are required to comply with it.

5. Purpose & Scope

The purpose of this policy is to tell you what personal information "Fundstream DBG" and its related entities may collect in their business activities, how the information collected may be used or stored, and is intended to provide you with details of actions taken by us to safeguard your information.

We are committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act) including the Privacy (Credit Reporting) Code.

Any references to our products or services includes our financial services, credit activities investments and our secured loans.

6. Collection of Personal Information

Generally, we only collect personal information that is reasonably necessary for, or directly related to, one or more of the functions and activities of our business.

For example, we may request that you provide your personal information when you instruct us to provide services, acquire products, invest with us or otherwise interact with us (e.g. via our websites).

There may be other occasions when we collect personal information about you, search results obtained when verifying a customer's identity or from other sources, such as from our related entities, a publicly maintained record or from an information services provider.

We may also share personal information about you with our related entities.

The types of personal information we collect may include the following:

  1. Name, gender, date of birth.
  2. Contact information such as residential address, email address, phone number(s) and IP address.
  3. Information in identification documents (e.g. Driver's License or Passport).
  4. Bank account details.
  5. Information about Directors, Shareholders, Beneficiaries and Beneficial owners.
  6. Tax file number(s), tax residency status and other government held information, including issued identification numbers.
  7. Personal questions to form and answer security questions.
  8. Information about which of our websites and webpages you visit and which forms and documents are downloaded.
  9. Financial, asset and investment related information.
  10. Publicly available sources, including social networks, where we may derive or form an opinion by analysing data collected from these sources.

We do not collect or hold sensitive information, such as racial or ethnic origins, religious affiliation, political opinions, or criminal record.

We may hold information about your health, only when it concerns your loan and/or investment (e.g. if a Power of Attorney is relied on).

Personal information held by us is not organised by government related identifiers.

7. Collection of Sensitive Information

If you are making a hardship application, we may also ask you about and seek to collect information about any medical conditions you may have that we believe may be relevant to that application.

8. How we Collect Personal Information

Generally, we will collect your personal information directly from you, for example when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a form, questionnaire or survey or when you use our website or our social media.

Sometimes it may be necessary for us to collect your personal information from a third party. For example, we may collect your personal information from a publicly available record or from your personal representative. We may also collect personal information about you from your use of our website and information you provide to us through the registration process on our website.

9. Providing Personal Information about Someone Else

If you provide us with someone else's personal information, you should only do so if you have their authority or consent to provide us with their personal information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy.

10. Holding Personal Information

We may hold personal information in both hard copy and electronic formats.

We also engage third parties to host electronic data (including in relation to the services we provide on our behalf).

We may also have legal requirements which govern how long we retain documents and information and data breach incidents. For example, under Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) legislation, certain records must be retained for seven years.

We will endeavour to ensure that personal information is kept as current as possible and that irrelevant data is deleted or made anonymous as soon as reasonably practicable.

However, personal information may be retained for varying periods of time to comply with legal and regulatory obligations or any other legitimate business reason.

In the event you cease to be a client of ours, personal information we hold about you will be maintained for at least as long as we are required to comply with legislative record retention requirements. After that time, we may destroy your personal information or put it beyond use (e.g. de-identify the personal information so it cannot be used to identify you).

11. Purpose for Collecting, Holding, Using & Disclosing Personal Information

We collect, hold and use personal information for a number of purposes including the below:

  1. To provide you with requested investment or credit-related services.
  2. To respond to your other requests or queries.
  3. To provide you with information about our products or services.
  4. To operate our business and any company, managed investment scheme, trust or syndicate, including entering details on a register of members and performing compliance reviews or audits.
  5. To maintain contact and keep you informed of our services, updates, industry developments and events.
  6. To verify your identity, including under Anti-Money Laundering and Counter-Terrorism Financing laws and regulations, which involve disclosure of your personal information to service providers, government or regulatory bodies, credit agencies or other information holders and repositories.
  7. For administrative purposes, including processing applications, distributions and payment transactions.
  8. For recruitment purposes and matters relating to the employment of our personnel, providing internal services or benefits to our staff.
  9. When engaging service providers, contractors or suppliers relating to the operation of our business.
  10. To manage any conflict of interest.
  11. For seeking your feedback or to conduct surveys.
  12. To meet any legal or regulatory obligations (e.g. providing the Australian Taxation Office (ATO) with tax file numbers).
  13. As part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business or entering into an alliance, joint venture or referral arrangement.
  14. To perform internal statistical analysis, including of our databases and website.
  15. For any other business-related purposes.

If you do not provide us with the personal information we have requested, we may not be able to complete or fulfil the purpose for which such information was collected, including providing you with the services or products we were engaged to perform.

12. Disclosure of Information to Third Parties

Depending on the product or service you have requested from us, we may disclose your personal information to third parties but only to the extent reasonably necessary to provide services to you or reasonably related to functions that those third parties need to perform.

These parties could include:

  1. External professional service providers engaged by us such as:
    1. Portfolio management services (i.e. FinPower)
    2. Custodianship of investment assets (i.e. TBA)
    3. Legal services (i.e. Summer Lawyers, Parsons & Partners etc.)
    4. Valuation Services (e.g. JPM Valuers, Ray White Valuation Services etc)
    5. Accounting services (TBA)
    6. Auditing services (Deloitte)
  2. Organisations and document issuing authorities able to provide verification of your identity (e.g. Equifax).
  3. Organisations who offer or manage mortgage or finance brokers (including "Aggregators") for the purpose of monitoring and supervising our compliance with relevant credit laws and standards.
  4. Mailing, printing or other service providers.
  5. An external dispute resolution agency, tribunal or court in connection with any dispute.
  6. Government agencies or other person where we are required by law to make disclosure (e.g. responding to a valid statutory notice or court subpoena).
  7. A person or business in relation to an actual or proposed acquisition, disposition, merger or our entry into an alliance, joint venture or referral arrangement.
  8. When you have provided consent for the disclosure.

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

  1. The person or organisation receiving your information has a commitment to protecting your personal information at least equivalent to ours.
  2. You have otherwise consented to us making the disclosure.

13. How You can help keep Your Information Secure

You can keep your personal information secure by ensuring any password you use to access our systems is kept strictly confidential and by logging off when you have finished using a shared computer.

We will not be responsible for any access or change made to your personal information occurring as a result of you disclosing your password to a third party or through unauthorised access.

14. Information Storage & Security

We take security measures to ensure that any personal information we hold (including credit information) is protected from misuse, loss and unauthorised access, modification or disclosure, including physical security measures (e.g. security passes and keys to enter our offices and storage of files in lockable cabinets) and technology security measures (e.g. restriction of access, firewalls, encryption, passwords and anti-virus technology).

We store personal information in our computer databases and on paper.

We may also utilise third party storage providers (e.g. internet or cloud-based storage), which store data in an overseas country (e.g. United States, North America, Asia, European Union or any other country in which the provider or its affiliates, subsidiaries or service providers maintain facilities).

In the event that your personal information is held in an overseas country, the information will not be protected by the Australian Privacy Principles. By providing your details, you consent to your information being disclosed and held in this manner.

As part of our information security framework, we undertake periodic privacy audits, compliance reviews, and monitoring activities to evaluate the effectiveness of our privacy practices, validate the secure storage and transmission of personal information, and ensure continued compliance with the Australian Privacy Principles and applicable regulatory obligations.

15. Automatic Collection of Personal Information

Cookies and other technologies are used by us on our websites and through email to automatically collect certain types of information. The collection of this information allows us to customise your online experience, market products and services to you, improve the performance, usability and effectiveness of our online presence and to measure the effectiveness of our marketing activities.

If you register or log into our website and provide information about your preferences, we may use your information to personalise your user experience.

If you register or log into our website using a third-party account, we may collect any information you have permitted the third-party service to share (e.g. your name and email address) depending on the privacy settings you have set with the third-party service and their privacy policy.

16. IP Addresses

An IP address is a number assigned to your computer whenever you access the internet. It is not linked to personally identifiable information.

We may use IP addresses to analyse trends, administer the website, track user's movement, and gather broad demographic information.

17. Cookies

A 'cookie' is a small text file that is placed on your computer or internet-enabled device whenever you visit our website. This allows the website to remember your computer or device and serves a number of purposes.

As an example, online retailers use cookies to track items in a user's shopping cart while they explore the different pages on the website. Without cookies, each time you click on another link, the cart would reset to zero. This could make buying anything online very difficult.

The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser settings to either refuse to accept all cookies or to notify you when you have received a cookie.

You may also delete cookies from your device at any time. If you refuse to accept cookies, you may not be able to access or use all of the features available on our website.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our website and geographic origin of visitor trends, and not to identify individual visitors.

18. Location Based Tools

We may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

19. Social Media

Our website may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any "Fundstream DBG" social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

20. Links to Third Party Websites

Our websites may contain links to third parties' websites.

Those other websites are not subject to our privacy policy and procedures.

You will need to review those websites to view a copy of their privacy policy. We do not endorse, approve or recommend the company, product or service provided on or associated with the external link.

21. Your Choices

You have several choices regarding your use of our websites.

In general, you are not required to provide personal information when you visit our websites. If however, you apply to receive information about our services, events and updates, wish to acquire products or services or apply for a job, provision of certain personal information will generally be required.

22. Children

We understand the importance of protecting children's privacy, especially in an online environment.

Our website is not intentionally designed for or directed at children under the age of 18.

It is our policy to never knowingly collect or maintain information about anyone under the age of 18.

23. Request Access to your Personal Information

Australian privacy law gives you a general right to request access to your personal information, including credit information, subject to some limited exceptions permitted or required by law.

Such requests must be made in writing to our Privacy Officer.

If we decline your request for access, we will provide a written explanation to you for the refusal.

Upon confirmation of your identity, we may provide you with access to information by either providing you with copies of the information requested or allowing you to inspect the information. We may charge reasonable costs for providing you access to your personal information.

We will not provide you with access to personal information which would reveal any confidential formulae or the detail of any in-house evaluative decision-making process but may instead provide you with the result of the formulae or process or an explanation of that result. See below at 28 for details on how to lodge a request for access to your personal information.

We may have the right to refuse your request for access to your personal information if we have a valid reason. Some valid reasons include:

  1. Our reasonably formed belief that giving you access may have an unreasonable impact on the privacy of other individuals.
  2. Your request is frivolous or vexatious.
  3. Where otherwise required or permitted by Australian federal or state or territory law to refuse or limit access.

24. Request a Correction to Personal Information

It's important that you make sure that the personal information we hold about you is accurate, up-to-date and complete. If you believe that any personal information we have collected about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you have the right under Australian Privacy Law to request a correction or amendment. If a correction or amendment is required by you, please contact our Privacy Officer and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act.

As noted above under heading "Holding Personal Information", we may be required to comply with legislative document retention requirements, in which case we may be able to correct but not always legally amend or delete particular information during this period.

25. Complaints about the handling of Personal Information

We at "Fundstream DBG" strive to provide our customers with the highest standard of service. If you are dissatisfied with how your personal information is being handled by "Fundstream DBG" please first contact our Complaints Officer using the contact details below:

  1. Email
    Fundstream Complaints Officer
    privacy@fundstream.com.au
  2. Post
    Fundstream Complaints Officer
    Fundstream Pty Ltd
    Suite 3, Level 13,
    55 Clarence Street
    Sydney NSW 2001
  3. Phone
    1300 669 800

"Fundstream DBG" will endeavour to resolve the dispute within 10 business days.

If "Fundstream DBG" cannot resolve the dispute within 30 days, we will notify you in writing.

If an issue has not been resolved to your satisfaction within 30 days, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC) if you are not satisfied with our response to, or the handling of your privacy related complaint.

The Office of the Australian Information Commissioner (OAIC)
Web address: https://oaic.gov.au/
Mail: GPO Box 5218 Sydney NSW 2001
Phone: 1300 363 992 (11 am to 5 pm Tuesday to Thursday)

26. Office of the Australian Information Commissioner

We are required to comply with the Privacy Act 1988, which contains the Australian Privacy Principles. A summary of the Australia Privacy Principles, a copy of the Privacy Act and additional information about privacy is available on the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/

27. Changes to this Policy

Our Privacy Policy may change from time to time, to reflect our current privacy practices or changes in the law. Our websites will always have the current version of our Privacy Policy. Before providing us with personal information, please review the Privacy Policy on our website.

28. Our Contact Details

Should you wish to contact us in regard to "Fundstream DBG's" Privacy Policy generally, including but not limited to the below examples:

  1. Detail the personal information you would like access to.
  2. Note that you have an inquiry in relation to "Fundstream DBG's" Privacy Policy.
  3. Note that you would like to notify us that you no longer wish to receive marketing material from us.
  4. Note that you would like to access or correct your personal information.
  5. Note that you would like to make a complaint about our handling of your personal information (please refer to point 25 above … Complaints about the Handling of Personal Information).

You are required to submit your request in writing and include the following (minimum) information:

  1. Your name and contact details (phone number & email address).
  2. Detail the personal information you would like access to.
  3. How you would like to access the personal information (e.g. receive a copy by email, or post, or collect/view in person).
  4. Authority for another person or organisation to access the personal information on your behalf.

Fundstream DBG Group Privacy Officer
Fundstream Pty Ltd
Suite 3, Level 13,
55 Clarence Street
Sydney NSW 2000
Phone: 1300 669 800
Email: privacy@fundstream.com.au

Last updated:  24th July 2025





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