July 2025
Longreach Alternatives Ltd (‘Longreach’) respect your right to privacy and is committed to protecting your personal information. Longreach is bound by the Australian Privacy Principle (‘APPs’) outlined in the Privacy Act 1998 (Cth) (‘Act’), which legislates the privacy protection framework that governs the collection, use, disclosure, integrity, correction, and transfer of personal information by organisations. This Privacy Policy (‘Policy’) outlines the guidelines for how Longreach complies with the APPs.
Purpose
This policy outlines the guidelines in place to help manage and oversee privacy of personal information and its use as it relates to Longreach Alternatives’ operations, licence, and regulatory requirements in accordance with the APPs. Personal information is any information or opinion about an identified individual who is reasonably identifiable whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. By providing Longreach your personal information, you consent to the use, disclosure and otherwise handling of your personal information in accordance with this Policy, as updated from time to time.
Collection
Subject to legislative requirements, Longreach will only collect and hold personal information that is only reasonably necessary for the business relationship with you including collecting information from you as an investor, client, supplier, contractor, service provider, or job applicants.
Dependent on the nature of Longreach’s business relationship with you, the product and/or service offering we provide or receive will determine the types of information collected. If you are an investor or client, we may collect the following information:
- Name;
- Residential and/or postal address;
- Date of birth;
- Email address;
- Employment information;
- Financial details (including banking and investment details);
- Government issued identification numbers (e.g., tax file numbers, etc.);
- Citizenship;
- Contact details (e.g., mobile phone number, etc.);
- Identification details (e.g., passport); or
- Other information that Longreach considers necessary in offering products and/or service offerings
In regard to Longreach’s recruitment process, the following information may be collected:
- Information provided on the engagement of the employee, including CVs;
- Employment contracts;
- Employment history;
- Employment references;
- Background checks;
- Citizenship;
- Information on the training of the employee, including academic qualifications;
- Employee personal and emergency contact details;
- Professional or trade association, or trade union membership;
- Employee taxation, banking, or superannuation affairs; and
- Other information that Longreach considers necessary to the recruitment process.
Personal information may be collected in a variety of methods including:
- Directly from you (via in person, telephone, letter, facsimile, email, application form that may be physical or digital);
- Indirectly from nominated agent (e.g., financial advisers, agents, attorneys, recruitment firms, etc.);
- Indirectly from third parties (e.g., government databases for the purposes of complying with ‘Know Your Customer’ requirements).
Note that Longreach exercises extreme care in relation to the collection or disclosure of sensitive information. Such information can only be collected if you provide explicit consent, either orally or in writing, and the information is reasonably necessary for one or more of Longreach’s functions or activities. Such personal sensitive information includes:
- Racial or ethnic origin;
- Political opinions and/or associations;
- Religious beliefs;
- Trade and/or professional associations;
- Sexual preferences;
- Criminal records; and
- Health information (including biometric and genetic information).
Longreach has the capability to collect information about the use of the Longreach managed websites. This information may include:
- Number of users/visitors;
- When they visit;
- How they navigate through the pages;
- Which pages are visited;
- Amount of time spent looking through the website.
Additionally, similar statistical information is also collected when Longreach distributes other electronic material such as marketing information on Longreach product and service offerings. By using this website, you agree to the collection and use this information.
You are not required to give us the information that Longreach requests. However, if you do not provide the information we request, or if the information provided is incomplete or inaccurate, this may prevent or delay in the processing of your application or claim, prevent Longreach from contacting you, or impact on taxation treatment of your account.
Use and Disclosure
When it is requested to collect personal information from you, Longreach will inform you on the purposes for which it is collected. The information may be used to:
- Verify identity;
- Provide products and/or service offerings;
- Answer enquiries and provide information on Longreach products and service offerings;
- Establish and manage accounts and/or investments with Longreach;
- Implement investment instructions, process contributions, transfer monies, or pay benefits;
- Report investment performance of your account on periodic basis;
- Inform on most recent information by providing marketing information and materials pertaining to other products and/or service offerings provided by Longreach;
- Conduct market research;
- Prevent fraud and financial crime in relation to the products and/or service offerings provided to you;
- Comply with Longreach’s internal policies and procedures;
- Comply with laws, regulations, rules, standards, directions, notices, or requests from regulatory bodies or government agencies;
- Process applications for employment;
- Investigate and respond to complaints;
- Establish, exercise or defend legal rights or for the purpose of legal proceedings;
Note, Longreach may need to disclose your personal information to another person, organisation, or external party. However, Longreach will only disclose the information allowed by law, and will obtain your express or implied consent, or where we are obliged to by law. Personal information may be disclosed to the following third parties:
- Longreach’s related body corporate, any organisations involved in providing, managing, or administering Longreach products and service offerings (e.g., responsible entities, trustees, custodians, administrators, unit registry services, actuaries, external dispute resolution bodies, and insurers);
- Any individual acting on your behalf, or who has been nominated by you to receive certain information (e.g., financial advisers, broker, solicitor, accountant, executor, administrator, trustee, guardian, or attorney);
- Longreach’s IT service providers who store data;
- Regulatory bodies, government agencies, law enforcement bodies, courts, and other parties Longreach is authorised by law to disclose to;
- Any financial institution nominated by you;
- Auditors;
- External dispute resolution bodies; and
- Other parties where you have given your consent.
The use and disclosure of the information is only conducted for the purpose for which it was collected for. It will not be disclosed for other purposes.
Marketing
Longreach may use or disclosure your personal information to inform you about, and develop, products and service offerings that may suit your investment capabilities or other opportunities you may be interest in. You can contact us at any time if you no longer wish to do so.
Outsourcing
Longreach may disclose your personal information to external organisations and parties that assist in the provision of products and/or service offerings. Additionally, we may seek expert advice from time to time to improve operational processes and systems e.g., IT systems and infrastructure. Note, these organisations are bound by confidentiality agreements as well as the APPs.
Third Party Sites
The Longreach website contains links to other sites, which are controlled by other third parties. Visitors to the Longreach site should consult the privacy policies of these sites, and please be aware that Longreach does not accept responsibility for their use of information about you.
Protecting Personal Information and Website Security
Longreach takes all reasonable steps to ensure your personal information is protected from misuse, interference, loss, from unauthorised access, modification, or disclosure. The storage of information is monitored and maintained only on Longreach approved systems and applications (including computers systems, emails, networks, etc.) that have been assessed with levels of due diligence both internally and via external service providers, and backed with information system security safeguards and protocols which adhere to industry standards. Access to the information is restricted to Longreach employees, directors, third party contractors who require the information to perform their services.
In regard to the Longreach website, Longreach takes care to ensure the personal information provided is protected. The website has security systems and protocols in place, including the use of firewalls and data encryption. It is noted that there are inherent security risks in transmitting or transferring information through the internet. You should consider and assess the potentials risks when deciding whether to use our online services (including website). If you do not wish to transmit information through the Longreach website, there are other methods in which information can be provided to Longreach.
Eligible Data Breach
In the event where any unauthorised access, disclosure, or loss of your personal information has occurred, Longreach will notify you. Additionally, Longreach’s third-party service providers are required to notify us of such event. In these circumstances, Longreach will perform an internal assessment to determine whether an ‘eligible data breach’ had occurred where any unauthorised access, disclosure, or loss of personal information where the access, disclosure or loss is such that it is likely to result in serious harm to any impacted individuals to whom the information relates.
If it is determined that an ‘eligible data breach’ had indeed occurred, Longreach has the requirement to notify the impacted individuals as soon as practicable, detailing the nature of the breach, any immediate actions taken, and the recommended response to the breach. Longreach will also notify the Office of the Australian Information Commissioner (OAIC).
Access and Correction of Information
You are able to request access to or correct personal information by raising the matter with Longreach, noting certain exemptions and conditions subject to law may apply to access requests. Factors affecting a right to access include:
- Access may pose a serious threat to life or health of any individual;
- Access would have unreasonable impact on the privacy of other individuals;
- The request is frivolous or vexatious;
- Information relates to existing or anticipated legal proceedings between Longreach and the individual, and would not be accessible by the process of discovery in those proceedings;
- Giving access would reveal intentions of the organisation in relation o negotiations with the individual in such a way as to prejudice those negotiations;
- Giving access may be unlawful;
- Denying access is required or authorised by or under Australian law or a court/tribunal order;
- Suspicion that unlawful activity, or misconduct of a serious nature, that relates to Longreach’s functions or activities has been, is being or may be engaged in and would be likely to prejudice the taking of appropriate action in relation to the matter;
- Likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
- Reveal evaluative information generated within Longreach in connection with commercially sensitive decision-making process.
In the event where Longreach is unable to comply with your request to provide your personal information, Longreach will inform you with an explanation of the reasons why. You may request Longreach to provide the source of the personal information Longreach holds, which will be provided to you unless it is impractical or unreasonable to do so.
You have the right to request corrections of any information Longreach holds about you if you believe it is inaccurate, incomplete, out-to-date, irrelevant or misleading. If Longreach disagrees that the corrections you have supplied are correct and refuse to correct the personal information, Longreach is required to provide a written notice to that effect and a statement if requested.
Government Identifiers
Longreach only uses and discloses your government agency identifiers (e.g., tax file numbers) when legally required to do so. Longreach is not permitted and does not adopt government identifiers as an identifier of any individuals (other than Australian Business/Company Numbers).
Destroying Information
Longreach ensure that any personal information that is no longer necessary for a legitimate business function or activity will be destroyed or permanently de-identified. Destruction of records containing personal information is done by secure means. Ordinarily, for information about a particular account, Longreach will destroy the information after 7 years from the day you close the account. All information stored in electronic form that is no longer required will be deleted from the Longreach system.
Complaints
If you believe that Longreach is in breach of the privacy obligation requirements (including APPs), a complaint may be raised to Longreach. The complaint must be in writing in accordance with the Act, and addressed to the Compliance Officer. From the receipt of your written complaint, the Compliance Officer has 30 calendar days to respond.
If you and Longreach cannot resolve the complaint amongst both parties, the complainant may refer the matter to the OAIC on 1300 363 992 (see www.oaic.gov.au) .
Contact Us
If you have any questions about this Policy, have concerns, or would like to make a complaint about Longreach’s collection, use or management of your personal information, or wish to access or correct your personal information, please contact the Longreach Compliance Team at compliance@longreachalternatives.com.
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