Privacy Policy

1. Our Policy

1.1 This is the Privacy Policy for Sydney Wyde Mortgage Management Limited ABN 19 090 567 150, Australian financial services licence and Australian credit licence No. 245506 (Sydney Wyde) and applies to all companies in the Sydney Wyde group and our related businesses including the Sydney Wyde Mortgage Fund ARSN 108 342 123and the SWIMM Pooled Mortgage Fund ARSN 090 880 890 (we, us or our).

1.2 This Privacy Policy applies to us in our capacity as responsible entity, mortgagee and fund manager, trustee, custodian and administrator of the various schemes and other investments to which we are a service provider as well as in our personal capacity.

2. Your Privacy

2.1 Your privacy is important to us and we are committed to managing your personal information responsibly and in accordance with our legal obligations including the requirements of the Privacy Act 1988 and with theAustralian Privacy Principles. These laws and principles regulate, among other things, the way we collect, use, disclose, keep secure, and give you access to your personal information.2.2 This Privacy Policy sets out the type of information we collect and how we collect, store, use and disclose your personal information. We recommend that you read it carefully.

2.3 You are not required to provide us with your personal information, but if you do not do so we may not be able to provide you with our products or services.

2.4 If you apply for or accept any of our products or services or otherwise provide us with your personal information, you agree to your information being collected, held, used and disclosed as set out in this PrivacyPolicy. We may revise this Privacy Policy from time to time by placing the revised Privacy Policy on our websites or otherwise notifying you of the change.

3. What kind of information do we collect?

3.1 In order to provide our products and services, including establishing and administering your invest mentor loan, providing general financial advice and providing information about our products and services, and to comply with relevant legislation, we may collect the following information: (1) full name, date of birth, gender and contact details including telephone, address, e-mail and facsimile;(2) a copy of your driver licence and/or passport or other identification documentation for the purpose of verifying identity and to ensure compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act and/or other legislation and regulations regarding identification verification, and tax reporting and withholding;(3) your tax file number (TFN) and bank account details for the purpose of administering investor accounts and tax reporting and withholding;(4) taxpayer identification number used outside Australia, information and documentary evidence about place of birth, residency and citizenship for the purpose of compliance with intergovernmental agreements regarding international tax information sharing and taxation and taxation information reporting legislation of Australia and other jurisdictions;(5) investor contribution details and investment choice;(6) details about authorised signatories on your investments or accounts with us;(7) detailed contact information about your financial adviser;(8) in relation to applications for loans or other financial accommodation, details of your assets and liabilities, your financial affairs and credit history; and(9) copies of any relevant trust deeds, partnership agreements or constitutions, which may be relevant to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act.

3.2 If you are applying for finance or you are a guarantor in respect of a finance application, we may also collect information which is used to assess your eligibility to be provided with finance (or act as guarantor) and this may include any finance or guarantee that you have outstanding. This information may include:(1) your assets and liabilities;(2) your employment details and proof of earnings and expenses;(3) the ages and number of your dependants and cohabitants; and/or(4) the length of time at your current address.

3.3 It may, on occasion also be necessary to obtain other details, including information relating to powers of attorney or for probate and estate administration.

4. How do we collect and hold personal information?

4.1 We may collect your personal information in various ways including by telephone, our website, from documents or correspondence, by facsimile and by email. Wherever practicable, we will collect information about you from you personally.

4.2 However, it may be necessary at times to collect information about you from other external sources, such as:(1) a financial adviser or broker;(2) authorised representatives, such as executors or administrators; and(3) identification verification service providers;(4) if you are applying for finance or have a finance facility with us.

4.3 If you use our website, our web server (i.e. the computers that house our website) has the capacity to collect the following types of information for statistical purposes:(1) the number of users who visit the website;(2) the number of pages viewed; and(3) traffic patterns.

4.4 This is anonymous statistical data and no attempt is made to identify users or their browsing activities. This data is used only to evaluate our website performance and to improve the content we display to you.

4.5 Other information, such as browser type, is included in a ‘cookie’ that is sent to your computer when you complete certain tasks on our website. A cookie contains bits of information that enables our servers to identify and interact efficiently with your computer. Cookies are designed to provide a better, more customised website experience, and to make it easier for you to use our website. You can configure your computer to accept or reject cookies.

4.6 All personal information we collect will be held securely and in accordance with this Privacy Policy.

4.7 Your information is protected from unauthorised access through the use of secure passwords, user logins or other security procedures. Developments in security and encryption technology are reviewed regularly.4.8 Where necessary, we will remind you that the Internet is an insecure medium.

5. For what do we use personal information?

5.1 Generally, we only use and disclose information for the purpose for which it was disclosed to us or related purposes which would reasonably be expected. Those purposes include:(1) to establish and administer your investment or account and your relationship with us;(2) for communication purposes including surveys and questionnaires;(3) to comply with our record-keeping, reporting, and tax obligations;(4) to protect legal rights and comply with legal obligations including, but not limited to, record-keeping, reporting, taxation withholding, and client identification requirements under applicable laws which may include the following legislation: Corporations Act 2001, Income Tax Assessment Act, Anti-Money Laundering and CounterTerrorism Financing Act, and the Privacy Act 1988;(5) to prevent fraud and abuse and to maintain the integrity of our business systems and infrastructure;(6) for quality assurance and training purposes;(7) to enable us to provide information about new and existing products and services that will enhance our relationship with you. However, we do respect the right of individuals to ask us not to do this; and(8) to handle any relevant enquiries or complaints.

5.2 We may be required by law to disclose personal information. For instance, we may be required to provide details to:(1) Australian Government regulators such as the Australian Securities and Investments Commission, theAustralian Taxation Office, the Australian Transaction Reports and Analysis Centre and to other regulatory or government entities;(2) the Australian Financial Complaints Authority (AFCA) or other external dispute resolution service;(3) as required by a court order (including in family law matters);(4) other regulatory or governmental entities outside of Australia.

5.3 In order to meet our clients’ needs and provide some services, such as administration of accounts and mailing of investor distribution statements, it may be necessary to release information or provide access to external service providers, for instance:(1) to any organisations involved in providing, managing or administering our products systems or services such as custodians, registries, administrators, mail houses and software and information technology providers;(2) to auditors, consultants and other professional advisers;(3) to your financial adviser;(4) to a legal personal representative, attorney or any other person who may be entitled to receive the proceeds from your investment or account with us;(5) to other financial institutions who hold an account in an investor’s name, for example, where amounts have been transferred to or from that account;(6) to authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to an investment or account.

5.4 If you are a borrower or guarantor, we may disclose your personal information and other credit related information (such as interest payment and principal repayment history, default history, recovery proceedings and information on arrears):(1) to prospective funders or other intermediaries in relation to your finance requirements;(2) to other organisations that are involved in managing or administering your finance such as lenders’ mortgage insurers, trade insurers and credit reporting bodies (see our Statement of Notifiable Matters for further information on our obligations in relation to credit reporting bodies).

5.5 Information about you or your dealings with us is not and will not be sold to any other company, individual, or group.

6. Can you access and amend your personal information?

6.1 You may request access to any personal information we hold about you. Generally, if it is incorrect, we will correct it at your request.

6.2 Your right to access is subject to some exceptions allowed by law. We will notify you of the basis for any denial of access to your personal information.

7. Can you complain?

7.1 Yes. If you have a complaint about a breach of this Privacy Policy including the manner in which we have collected, held, used, disclosed, kept, or given people access to your personal information, then you may make a complaint to us using the contact details set out below. You will need to provide us with sufficient details regarding your complaint and any supporting evidence.

7.2 Your complaint will be referred to our Privacy Officer who will investigate the issue and determine the steps we will take to resolve your complaint. We may ask you to provide additional information.

7.3 We will notify you in writing of our determination, generally within 30 days. If you are not satisfied with our determination or you do not receive a response within 30 days, you can contact us to discuss your concerns and you can refer the complaint to the Office of the Australian Information Commissioner www.oaic.gov.au

8. Will your personal information be sent overseas?

8.1 We do not anticipate that we will need to disclose personal information to overseas recipients. However, we may use cloud storage to store some or all personal information we hold about you. The cloud storage and the IT servers may be located in or outside of Australia.

9. Are copies of this Privacy Policy available?

9.1 Yes. A copy of our current Privacy Policy (this document) is available from us free of charge as follows:(1) you can download a copy in document format from our website www.swmm.com.au;(2) you can request a copy be emailed to you by emailing your request to tim@swmc.com.au;(3) You can telephone us and request a copy be mailed or emailed to you by calling (02) 9369 3175(+612 9369 3175 for international callers);(4) You can write to us and request a copy be mailed or emailed to you. Our postal address is:PO Box 840 Bondi Junction NSW 1355