Central to the success of Sage Capital Pty Ltd (Sage) is our commitment to our clients. We respect and protect the privacy of the personal information of individuals with whom we deal.

This Privacy Policy outlines to you all the ways in which Sage aims to protect your personal information and what sort of personal information we hold about you, for what purposes and how it is collected, held, used and disclosed.

Personal information is any information, including an opinion, that can be used to identify an individual or can be linked to an individual.

By continuing to use the products and services provided by Sage, you consent to us dealing with your information in the manner set out in the Privacy Policy.

The information we collect and hold

Whenever it is reasonable and practical to do so, we collect information about you directly from you. In some cases, we collect personal information from third parties including public sources, our related companies, referrers, brokers, agents, your adviser(s) and our service providers.

We collect personal information about you which is reasonably necessary to:

• Provide you with quality products or services;
• Consider applications and approaches you make to us;
• Maintain your contact details; and
• Fulfil our legal obligations under applicable laws and rules, such as those relating to taxation and Anti-Money Laundering and Counter-Terrorism Financing.

We generally hold personal information relating to:

• The products and services we provide or have provided to you;
• Your financial interests and sometimes your financial position, if you are a customer or potential customer of ours;
• Your name, contact details and identification information (including government-issued tax numbers);
• Records of our interactions with you, including by telephone, email and online; and
• Your enquiries or complaints.

We do not generally collect sensitive information about you unless required by applicable laws or rules.

Sensitive information includes information relating to:

• Race;
• Political or religious beliefs;
• Sexual preferences;
• Criminal convictions;
• Membership of professional or trade associations or unions; and
• Health information.

We may collect health information if assessing certain claims including hardship. We do not use or share that information for any purpose other than as disclosed to the customer when the information was collected.

We may collect information about your affiliation with certain organisations such as professional associations.

How that information is used

We only use and disclose personal information about you for the purpose for which it was disclosed to us or related purposes which would reasonably be expected without your permission. For example, we may use and disclose personal information to process applications, administer and manage our products and services including monitoring, auditing, and evaluating those products and services, model and test data, communicate with you and deal with any complaints or enquiries. We may also use and disclose your personal information (on a confidential basis) in connection with acquisitions, mergers or changes in control of our business or assets.

We may from time to time also use your personal information to inform you of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, we do respect your right to ask us not to do this.

We do not sell personal information to other organisations to allow them to do this.

We may disclose personal information outside Sage:

• As required by relevant laws or rules, such as those relating to Anti-Money Laundering and Counter-Terrorism Financing;
• To service providers who provide services including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, mailing, marketing, research, operational, compliance, investigation, identity verification, maintenance, trustee, securitisation, website and technology services; and
• To your nominated financial adviser or an authorised person with your permission.

In some circumstances the parties with whom we share personal information may operate outside of Australia (this includes locations in the countries listed in the Appendix). Where this occurs, we take steps to protect personal information against misuse or loss.

Keeping information accurate and up to date

We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

Keeping information secure

We use security procedures and technology to protect the information we hold. Access to and use of personal information within Sage seeks to prevent misuse or unlawful disclosure of the information.

If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.

Where the personal information we collect is no longer required, we delete the information or permanently de-identify it.

If there is a suspected or actual data breach which may compromise personal information, Sage will promptly undertake an assessment of the incident. Where relevant, immediate steps will be taken to contain the breach. These steps may include limiting any further access or distribution of the affected personal information, or the possible compromise of other personal information.

If the unauthorised access, disclosure or loss of personal information is likely to cause serious harm to one or more individuals and the likely risk of serious harm has not been prevented by remedial action, Sage will notify affected individuals and the Office of the Australian Information Commissioner as soon as practicable. The notification will include Sage’s identity and contact details, a description of the incident, the kind/s of information concerned and any recommended steps for affected individuals.

Following any data breach incident, Sage will undertake a review process to help prevent future breaches.

How you can access or correct your information

You can contact us as set out below to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

Dealing with us anonymously or under a pseudonym

You can deal with us anonymously or you may use a pseudonym where it is lawful and practical to do so. For example, you may enquire about our products or request a copy of our disclosure documents. However, we regret that we will not be able to offer you the product or services if we cannot identify you.

Dealing with Sage online

When you visit the Sage website you will browse anonymously unless you have accessed the website from a personalised communication from Sage.

For all visitors to our web site, we use cookies to collect anonymous information such as the server your computer is logged on to, your browser type (for example, Internet Explorer, Chrome or Firefox), and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also derive the general geographic area associated with an IP address.

If you are an anonymous visitor, the information we collect is not capable of personally identifying you.

Once you have accessed our website from an e-mail or other personalised communication sent to you, we may be able to identify you. If we have identified you, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our website, irrespective of how you access our sites (e.g. by clicking a link in an advertisement or from a third party website). In addition, we may combine that information about your use of the Sage website with certain other online and offline information we have about you in order to tailor your online experience and provide you with further information. If you would prefer not to be identified you can delete the cookies and reconfigure the cookie preferences on your internet browser (see below).

Cookies

A 'cookie' is a packet of information placed on a user's computer by a website for record keeping purposes. Cookies are generally used on the Sage site to:

• Collect identifiable information about your use of our website - if we have identified you as a result of you accessing our website from an e-mail or other personalised communication sent to you.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences).

If you disable the use of cookies on your web browser or remove or reject specific cookies from the Sage website then you may not be able to gain access to all of the content and facilities on that website.

Changes to the Privacy Policy

We can make changes to our privacy policy and the processes and systems relating to how we handle your personal information, from time to time, and for any reason. We will update this policy to reflect any changes.

Contact us

If you have any questions regarding our privacy policy or handling of information, please direct your enquiry to privacy@sagecap.com.au or contact us by phone on (07) 3009 7650 or 1800 940 599. Please mark communications to the attention of our Privacy Officer. Where you contact us seeking resolution of your privacy concerns, we will respond to let you know who will be handling your matter and when you can expect a further response. If your concerns are not resolved to your satisfaction, you may have rights to escalate your complaint to a regulatory authority. You may contact the Office of the Australian Information Commissioner on the privacy hotline: 1300 363 992.

Before you contact the Office of the Australian Information Commissioner, we recommend that you first try to resolve your concern with us.

Your rights if you are in the EU

Since your data is controlled and processed by us, you have certain rights as provided for in the General Data Protection Regulation. In particular:

• The right to be informed how personal information is processed. You have the right to be informed how your personal information is being collected and used. If we require your consent to process your personal information you can withdraw consent at any time. If you withdraw consent, we may not be able to provide certain products or services to you. The right to withdraw only applies when the lawful basis of processing is consent.
• The right of access to personal information. You can access your personal information that we hold by contacting us.
• The right to rectification. You have the right to question any personal information we have about you that is inaccurate or incomplete. If you do, we will take reasonable steps to check the accuracy and correct it.
• The right to erase. You have the right to ask us to delete your personal information if there is no need for us to keep it. There may be legal or other reasons why we need to keep your personal information and if so, we will tell you what these are.
• The right to restrict controlling and processing. You have the right to ask us to restrict our use of your personal information in some circumstances. In this situation we would not use or share your personal information while it is restricted. This is not an absolute right and only applies in certain circumstances.
• The right to data portability. In some circumstances you have the right to request we provide you with a copy of the personal information you have provided to us in a format that can be easily reused.
• The right to object. In some circumstances you have the right to object to us processing your personal information.
• The right to lodge a complaint with a supervisory authority. You have the right to complain to the regulator if you are not happy with the outcome of a complaint.

Policy updated June 2024

APPENDIX – Disclosure to other countries

Personal information may be disclosed to third parties in jurisdictions including: Canada, Luxembourg, Singapore, Malaysia, Hong Kong, India, Philippines, Ireland, Netherlands, Malta, Isle of Man, Cayman Islands, United Kingdom and the United States of America.