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Privacy Policy

1. Overview

Senjin Capital Pty Ltd (ABN 13678372006) (“Senjin Capital”, “we”, “our”, “us”) respects your privacy and is committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy outlines how we collect, use, disclose and manage personal information provided to us in the course of our business, including through our website, in providing financial services, and during our interactions with clients, investors, and other stakeholders.

2. What Personal Information We Collect

We only collect personal information that is necessary for our functions and activities as a fund manager providing financial services to wholesale clients. The types of personal information we may collect include:

  • Full name
  • Date of birth
  • Contact details (email address, phone number, mailing address)
  • Financial and investment information
  • Identification documents (for AML/CTF compliance)
  • Tax file number (TFN) – only if legally required and with appropriate security measures
  • Information provided through our website or communications

We generally do not collect sensitive information unless required by law (e.g., AML/CTF obligations) or where you consent.

3. How We Collect Personal Information

We collect personal information through a variety of means, including:

  • Directly from you (e.g., application forms, telephone calls, emails)
  • Through our website (e.g., via contact forms or cookies)
  • From third parties (e.g., service providers, financial advisers, or regulatory bodies)
  • From publicly available sources

4. Purpose of Collection

We collect personal information for the following purposes:

  • Assessing and processing applications for investment
  • Administering client accounts and transactions
  • Conducting compliance and regulatory reporting, including AML/CTF obligations
  • Communicating with clients, service providers and regulators
  • Managing and improving our services and operations
  • Any other purpose permitted or required by law

5. Disclosure of Personal Information

We may disclose your personal information to third parties including:

  • Custodians, administrators, registries, and fund service providers
  • Financial advisers or representatives (where authorised)
  • Auditors, legal and other professional advisers
  • Regulatory authorities such as ASIC, AUSTRAC or the ATO
  • Overseas recipients (for example, service providers located in Japan or where we invest in Japanese equities)

Where personal information is disclosed to third parties, we take reasonable steps to ensure they comply with privacy obligations.

6. Cross-border Disclosure

While Senjin Capital primarily operates in Australia, some of our service providers or counterparties may be located overseas, including Japan. We will take reasonable steps to ensure that any overseas recipients handle your personal information in a manner consistent with the APPs.

7. Data Security

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. This includes:

  • Secure physical and electronic storage systems
  • Access controls and authentication protocols
  • Confidentiality obligations for staff and service providers

8. Access and Correction

You may request access to, or correction of, the personal information we hold about you by contacting us (details below). We will respond within a reasonable time and in accordance with the Privacy Act.

9. Complaints

If you have a concern or complaint about how we have handled your personal information, please contact us using the details below. We will investigate your complaint and respond as soon as reasonably practicable.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au

10. Website and Cookies

Our website may use cookies and tracking technologies to improve functionality and user experience. This information is generally de-identified and used in aggregate form.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The current version will be made available on our website.

12. Contact Us

For any privacy-related questions or concerns, please contact:

Senjin Capital Pty Ltd
Email: investors@senjincap.com
Phone: +61 404 841 693
Address: Level 17, 9 Castlereagh Street, Sydney, NSW 2000, Australia