Privacy Policy

1. About This Policy

Arnhem Capital Pty Ltd ("Arnhem Capital", "we", "us" or "our") is committed to protecting your personal information and complying with our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy explains how we collect, use, disclose, and manage personal information in connection with our website at arnhemcapital.com.au and our business activities.

By submitting information to us through our website or otherwise engaging with us, you consent to the collection, use, and disclosure of your personal information as described in this Policy.

2. What Personal Information We Collect

We may collect the following types of personal information:

• Your name
• Email address
• Organisation or company name
• Any other information you provide voluntarily in the body of a message or enquiry
• Technical data such as IP address, browser type, and pages visited (collected automatically via analytics)

We only collect personal information that is reasonably necessary for our business functions. We do not collect sensitive information (as defined in the Privacy Act) unless you choose to provide it and we have your consent.

3. How We Collect Personal Information

We collect personal information in the following ways:

• Directly from you — when you submit an enquiry through our contact form, send us an email, or otherwise contact us
• Automatically — through cookies and analytics tools when you visit our website (see Section 7)

Where practicable, we collect personal information directly from you. If we receive your information from a third party, we will take reasonable steps to notify you.

4. How We Use Your Personal Information

We use personal information for the following primary purposes:

• Responding to your enquiries and communicating with you about our services
• Considering your suitability as an investor, co-investor, or business partner
• Sending you information about our activities or investment opportunities, where you have consented
• Improving our website and services
• Complying with our legal and regulatory obligations

We will not use your personal information for any secondary purpose without your consent, except where permitted by the Privacy Act (for example, where required by law or to prevent a serious threat to health or safety).

5. Disclosure of Personal Information

We do not sell, rent, or trade your personal information. We may disclose your personal information to:

• Service providers — third parties who assist us in operating our website or business (such as IT providers, cloud hosting providers, and CRM or workflow automation tools), who are required to handle your information securely and in accordance with our instructions
• Professional advisers — lawyers, accountants, and auditors who are bound by confidentiality obligations
• Regulators and authorities — where required or authorised by law

Some of our service providers may be located overseas (for example, cloud infrastructure providers operating in the United States or European Union). Where we disclose personal information to overseas recipients, we take reasonable steps to ensure those recipients handle your information in a way that is consistent with the APPs.

6. Data Security

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These measures include secure data storage, access controls, and encrypted communication channels.

If we no longer need your personal information and are not required by law to retain it, we will take reasonable steps to destroy or de-identify it.

No data transmission over the internet can be guaranteed as completely secure. While we strive to protect your personal information, we cannot guarantee the absolute security of information transmitted to us electronically.

7. Cookies and Analytics

Our website may use cookies and similar tracking technologies to improve your browsing experience and collect aggregate analytical data about website usage. This data is used to understand how visitors interact with our site and to improve its content and performance.

You can disable cookies through your browser settings. Note that disabling cookies may affect the functionality of certain parts of our website.

8. Access and Correction

You have the right to request access to the personal information we hold about you, and to request that we correct any information that is inaccurate, out of date, incomplete, or misleading.

To make such a request, please contact us using the details in Section 10. We will respond within a reasonable timeframe and in accordance with our obligations under the Privacy Act. In some circumstances we may be unable to provide access (for example, where doing so would affect the privacy of another individual), and we will explain why if that is the case.

We do not charge a fee for making an access or correction request.

9. Complaints

If you believe we have breached the Australian Privacy Principles or your privacy rights, please contact us in the first instance using the details below. We will investigate your complaint and respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

10. Contact Us

For any privacy-related queries, access requests, correction requests, or complaints, please contact us at:

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The current version will always be available at arnhemcapital.com.au/privacy-policy. We encourage you to review this page periodically.