PURPOSE AND SCOPE
October 2025
FC Capital Holdings Pty Ltd ACN 630 537 987 of Level 5, 1 York Street, Sydney NSW 2000 (FC Capital, we, us and our) recognises that your privacy is important and needs to be protected. FC Capital is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) and we take these obligations seriously.
This Privacy Policy explains how FC Capital handles the personal information it collects in the course of performing our functions and activities and providing our products and/or services. It is in addition to our Terms of Use and any other terms and conditions applicable to any products and/or services we provide.
When used in this Privacy Policy, ‘personal information’ means any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.
COLLECTION AND USE OF PERSONAL INFORMATION
To provide you with products and/or services, we may need to collect your personal information. The personal information collected will depend on the products and/or services we provide to you so in most cases we will only collect the personal information we need to provide and market our products and services in the context of our day-to-day business.
Additionally, we may collect, hold and use your personal information so that we can:
- • manage our relationship with you;
- • contact you, for example, to respond to your queries or complaints, or if we need to tell you something important; or
- • comply with our legal obligations and assist government and law enforcement agencies or regulators.
We may collect personal information which may include: your name, gender, date of birth, phone numbers, postal and residential addresses, email address, occupation, professional experience and qualifications, financial information and bank account details.
We may collect information about you from third parties, including but not limited to:
- • financial advisers
- • custodians
- • unit registrars and administrators
Where possible, we will collect personal information directly from you (for example, if you contact us, visit our website or purchase our products and/or services).
We may use personal information for the purpose for which it was collected. Occasionally personal information may be used for another purpose if we have your consent or if the reason we want to use it for is sufficiently related to the purpose for which it was initially collected or it could be reasonably expected that we would use it for such a purpose.
From time to time, we may use your personal information to tell you about products or services we think you might be interested in. These products and services may be offered by us, our related companies, our other business partners or our service providers. If you don’t want to receive direct marketing messages or want to change contact preferences you may request not to receive any direct marketing by contacting the sender using the details set out in the communication.
We may collect information about how you access, use and interact with our website. This information may include:
- • the location from which you have come to the site and the pages you have visited; and
- • technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system.
We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.
If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.
INVESTORS
If you hold notes or units in FC Capital, your personal information is used to carry out registry functions. Registry functions include making distribution payments, sending corporate communications, informing you of updates concerning FC Capital and our products and services or your investment, maintaining records and contact details, processing transactions, responding to queries or complaints and to comply with any law or regulation.
Note registers may be maintained by external parties who will be required to have arrangements in place to protect personal information they collect on behalf of FC Capital.
THIRD PARTY LINKS
Our websites and applications may contain links to websites operated by third parties. Those links are provided for your convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. We note that the privacy policies that apply to those websites may differ from this Privacy Policy. You should check those third-party websites for their respective privacy policies and for information on how they handle your personal information.
DISCLOSING PERSONAL INFORMATION
FC Capital is careful about how we use your information and who we share it with. We may share information with employees of FC Capital. We may transfer or disclose your personal information to our related companies. We may also disclose your personal information to third parties who assist us in the operation of our business and/or the provision of our products and services such as custodians and unit registry providers. Personal information could also be disclosed to:
- • service providers, such as your financial adviser. If a financial adviser’s stamp appears on your application form or if you otherwise inform us of having a financial adviser, we may supply your financial adviser with information about your accounts unless you instruct us otherwise in writing;
- • other professional advisors such as accountants, lawyers, consultants and other business advisors as advised to us;
- • mail houses, archive providers, our related bodies corporate, contractors, or other third parties for the purposes specified above;
- • third party service providers, contractors and partners who help us manage our business and deliver our services, including IT service providers who manage our applications, systems and networks and/or provide hosting, storage and maintenance and support services;
- • regulatory authorities or government agencies or bodies where required by law;
- • other third parties where required, or allowed under law, or in connection with legal proceedings; and
- • other third parties where you have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances.
Where we have disclosed personal information to a third party acting on our behalf, we require that those third parties do not use the personal information for their own purposes and that they use, disclose, store and otherwise handle personal information only in a way that is compliant and consistent with this Privacy Policy. Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.
If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.
DISCLOSURES TO OVERSEAS RECIPIENTS
We may disclose your personal information to recipients that are located outside Australia.
Those recipients are likely to be located in the Philippines.
KEEPING YOUR PERSONAL INFORMATION SECURED
We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
We may hold your personal information in either electronic or hard copy (paper) form. We retain your personal information in our computer systems and databases (operated by us and/or our external service providers), and in our physical files. We use technologies and processes such as access control procedures, network firewalls, encryption, password protected databases and physical security measures to protect your personal information.
We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.
ACCESSING AND CORRECTING PERSONAL INFORMATION
You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date, complete, relevant and not misleading.
CHANGES TO FC CAPITAL’S PRIVACY POLICY
FC Capital reserves the right to modify or amend this Privacy Policy at any time and we will update any changes to the Privacy Policy on FC Capital’s website. We encourage you to check this Privacy Policy from time to time.
COMPLAINTS
If you wish to make a complaint about the way we have handled your personal information, please contact us using the contact details set out below. We will investigate your complaint. After FC Capital has completed its investigation, we will contact you to advise the outcome. If your complaint is not satisfactorily resolved, you may approach an independent adviser or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action that may be available.
We will take reasonable steps to ensure that the information we collect, use and disclose is relevant, accurate, up- to-date, and complete. In some cases, the accuracy of that personal information largely depends on the details you provide to us. Please keep us up to date with any changes to your personal information. You have the right to ask us what personal information we hold about you and request that changes be made to the information. If you wish to request access to the personal information we hold, you can contact us by email at info@fcapital.com.au.
If we correct personal or sensitive information about an individual which was previously provided to a third party, and the individual requests us to notify the third party of the correction, we will take all reasonable steps to give that notification, unless it is impracticable or unlawful to do so.
We may charge a fee for responding to a request for personal information to cover our reasonable costs in locating and supplying the information. There is no cost for asking for access to information and we will make sure any charges for suppling the information are not excessive.
There are several exceptions in the Privacy Principles that allow us to refuse your request for access to your personal information. The exceptions are summarised in Privacy Fact Sheet 17: Australian Privacy Principles which is available from the OAIC. If we deny a request for access, we will explain why.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, you can ask us to amend it. If you contact us for a correction, we will review the information to ascertain if correction is required and take the appropriate action. In some circumstances, we may not agree that the information should be changed. If this happens, we will provide a reason explaining our decision and we will add a note to the personal information stating that you disagree with it.
CHANGES TO FC CAPITAL’S PRIVACY POLICY
FC Capital reserves the right to modify or amend this Privacy Policy at any time and we will update any changes to the Privacy Policy on FC Capital’s website. We encourage you to check this Privacy Policy from time to time.
WHERE DO I GO TO FIND OUT MORE ABOUT PRIVACY?
Please contact us if you would like to know more about the Privacy Act, or if you would like more information about the way FC Capital uses personal information.
COMPLAINTS
If you think FC Capital has have breached your Privacy, or you wish to make a complaint about the way we have handled your personal information, please contact us using the contact details set out below. We will investigate your complaint. After FC Capital has completed its investigation, we will contact you to advise the outcome. If your complaint is not satisfactorily resolved, you may apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined.
CONTACT DETAILS
If you have any questions, comments, requests or concerns, please contact us at:
- • Email: contact@fccapital.com.au
- • Phone: 1800 307 903
- • Mail: Level 24, 259 George Street Sydney NSW 2000
SPECIFIC RIGHTS FOR EUROPEAN UNION (EU) RESIDENTS ONLY
If you are domiciled in the EU, then you may have additional rights. Some of these rights will only apply in very limited circumstances.
- • You can ask us to confirm if we are using or holding your personal information.
- • You can ask us to delete your personal information. This right applies only in limited circumstances and will not usually apply where it remains necessary for us to use your information for the purposes for which it was collected, we are required by law to retain your information or your information is relevant to a legal dispute.
- • You can ask us to help you move your personal information to other companies, where this is technically possible and only if we have collected and used your data via automatic means.
- • You have the right to be informed and know about any protections that we have in place where we are transferring your data overseas.