Privacy Policy

1. Introduction

Yellowfin Asset Management Pty Ltd ("Yellow Fin", "we", "us", or "our") is committed to protecting your privacy and handling your personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and, where applicable, the General Data Protection Regulation (GDPR).

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with us, use our services, or visit our website.

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

• Contact details (name, address, email address, telephone number)
• Identity verification information (date of birth, identification documents)
• Financial information (bank account details, investment history, source of funds)
• Professional information (employment details, professional qualifications)
• Tax information (tax file number, tax residency)
• Investment objectives and risk tolerance
• Transaction and account information

2.2 Sensitive Information

We generally do not collect sensitive information unless required by law or with your explicit consent. Where we do collect sensitive information, we will comply with applicable privacy laws.

2.3 Website Information

When you visit our website, we may automatically collect:

• IP address and browser type
• Pages visited and time spent on our website
• Referring website addresses
• Device information

3. How We Collect Information

We collect personal information:

• Directly from you when you complete application forms, enquiry forms, or communicate with us
• From third parties such as introducers, financial advisers, or other service providers
• From publicly available sources
• Automatically through our website using cookies and similar technologies

4. Purpose of Collection

We collect and use your personal information for the following purposes:

• To provide our financial services and manage your account
• To verify your identity and comply with anti-money laundering and counter-terrorism financing laws
• To assess your suitability for our services
• To communicate with you about your account and our services
• To comply with legal and regulatory obligations
• To improve our services and website
• To respond to enquiries and provide customer support

5. Disclosure of Information

We may disclose your personal information to:

• Related entities and service providers who assist us in providing our services
• Regulatory authorities, including ASIC, the NFA, and the CFTC
• Financial institutions, custodians, and prime brokers
• Professional advisers including lawyers, accountants, and auditors
• Third parties as required by law or court order

We do not sell your personal information to third parties for marketing purposes.

6. Overseas Disclosure

Given our international operations, we may disclose your personal information to recipients located overseas, including in the United States. Before disclosing information overseas, we take reasonable steps to ensure the recipient complies with applicable privacy laws or has equivalent protections in place.

7. Data Security

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. Our security measures include:

• Secure servers and encrypted data transmission
• Access controls and authentication procedures
• Regular security assessments and updates
• Staff training on privacy and security obligations

8. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Financial records are typically retained for a minimum of seven years after the end of our relationship with you.

9. Your Rights

You have the right to:

• Access your personal information held by us
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information (subject to legal requirements)
• Opt-out of direct marketing communications
• Make a complaint about our handling of your personal information

9.1 GDPR Rights (for EU/EEA residents)

If you are located in the European Union or European Economic Area, you may also have the right to:

• Data portability
• Restrict processing of your personal data
• Object to processing based on legitimate interests
• Withdraw consent at any time

10. Cookies

Our website uses cookies to improve your browsing experience and analyse website traffic. You can control cookie preferences through your browser settings. Please note that disabling cookies may affect the functionality of our website.

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites and encourage you to review their privacy policies.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on our website with the updated effective date. We encourage you to review this policy periodically.

13. Contact Us

If you have any questions about this Privacy Policy, wish to access or correct your personal information, or make a complaint, please contact us:

Privacy Officer
Yellowfin Asset Management Pty Ltd
Level 27, 25 Bligh Street
Sydney NSW 2000
Australia

Phone: +61 2 8277 6680
Email: privacy@yellowfinam.com

14. Complaints

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

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Website: www.oaic.gov.au