Fortitude Investment Partners – Privacy Policy
Effective Date: June 2025
Introduction
Fortitude Investment Partners Pty Ltd and its related bodies corporate (together, "Fortitude", "we", "our" or "us") are committed to protecting the privacy of individuals and managing personal information in an open and transparent way in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy outlines how Fortitude collects, holds, uses and discloses personal information in connection with its operations as a private equity investment manager.
1. What information we collect
We may collect the following types of personal information:
· Name, contact details, date of birth and identification details;
· Financial and investment details;
· Employment and background information (for due diligence);
· Details of service providers, contractors, and business contacts;
· Information required for anti-money laundering (AML) and know-your-client (KYC) checks; and
· Any other information required or authorised by law.
2. How we collect personal information
We collect personal information in a number of ways, including:
· Directly from you via forms, applications, emails or phone calls;
· From your authorised representatives or agents;
· Through our service providers, including fund administrators and compliance providers;
· From publicly available sources or third-party databases; and
· Automatically through our website or secure portals (cookies, metadata).
3. How we use personal information
We collect, hold and use personal information for purposes including:
· Managing our investment activities and investor relations;
· Assessing investment opportunities and conducting due diligence;
· Meeting our legal and regulatory obligations, including under AML/CTF laws
· Administering our internal operations (e.g. HR, IT, finance); and
· Engaging with service providers and suppliers.
4. Disclosure of personal information
We may disclose personal information to third parties including:
· Fund administrators, custodians and unit registry services;
· IT service providers and data storage providers;
· Legal, financial, and compliance advisers;
· Prospective investors (on a need-to-know basis); and
· Government agencies and regulators as required by law.
All third parties are subject to confidentiality obligations.
5. Overseas disclosure
Some personal information may be disclosed to service providers located outside Australia, including cloud storage or software services. Where this occurs, we take reasonable steps to ensure the recipient complies with privacy standards equivalent to the APPs.
6. Data security
We implement physical, administrative and technical safeguards to protect personal information from misuse, interference, loss, and unauthorised access or disclosure. This includes:
· Secure servers and encrypted storage;
· Role-based access controls; and
· Ongoing cyber risk assessments and monitoring.
7. Data retention
We retain personal information only for as long as necessary for the purposes described in this policy or as required by law. Where no longer required, data is securely destroyed or de-identified.
9. Access and correction
You may request access to personal information we hold about you and request corrections if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading. Please contact our Privacy Officer using the details below.
10. Making a complaint
If you have a concern about how we have handled your personal information, you can contact our Privacy Officer. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).
11. Changes to this Policy
We may amend this Privacy Policy from time to time. The most recent version will be available on our website or on request.
12. Contacting us
Privacy-related inquiries or requests should be directed to:
The Privacy Officer
Fortitude Investment Partners
Email: privacy@fortitudeinvest.com.au