Privacy Policy
Eucalypt Estates Pty Ltd ACN 695 804 365 and Eucalypt Accommodation Syndicate No. 1 Pty Ltd ACN 698 959 241, together with any other investment vehicle managed by Eucalypt Estates Pty Ltd (we, us, our), are committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
Eucalypt Estates Pty Ltd is a Corporate Authorised Representative (No. 001323219) of Affirmative Financial Services Pty Ltd, AFSL 331840.
Effective date: 10 September 2026
1. What we collect
We collect personal information that is reasonably necessary to assess and administer investments in the vehicles we manage and to meet our legal obligations. This may include:
your name, date of birth, residential and postal address, email address and telephone number;
identification documents and details, such as a driver's licence or passport;
tax file number, tax residency and related tax information;
bank account details and, where provided, bank statements;
information evidencing your status as a sophisticated or wholesale investor, including an accountant's certificate;
for companies, trusts and other entities: details of directors, trustees, beneficial owners and controlling persons;
whether you or a person associated with you is a politically exposed person;
source of funds or source of wealth information, where required by law;
details of your investment, holdings, transactions and payments; and
records of your communications with us.
2. How we collect it
We collect personal information directly from you, including through the online application form operated by Registry Direct Pty Limited, through electronic signing platforms, and by email or telephone.
With your consent, we also collect and verify information from third-party sources, including electronic identity verification providers (such as GreenID), government document verification services, public registers (such as ASIC and the Australian Business Register), sanctions and politically exposed person screening services, and your nominated advisers.
3. Why we collect it
We collect, hold and use your personal information to:
assess and process your application for securities;
verify your identity and the identity of persons associated with you;
confirm that you qualify as a sophisticated or wholesale investor;
comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Corporations Act 2001 (Cth), taxation laws and other laws that apply to us;
maintain the register of members, which Chapter 2C of the Corporations Act requires to include your name, address and details of the securities you hold;
administer your investment, including payments, distributions, reporting and investor communications;
respond to your enquiries and manage any complaints; and
arrange and manage insurance.
If you do not provide the information we request, we may not be able to process your application or administer your investment.
4. Who we disclose it to
We may disclose your personal information to:
Registry Direct Pty Limited, which operates our share registry and application platform;
identity verification and screening providers;
Affirmative Financial Services Pty Ltd, our Australian financial services licensee, for compliance review and approval of applications;
our solicitors, including in connection with application monies held in trust, and our accountants, auditors and other professional advisers;
financiers, insurers and their advisers;
providers of IT, cloud storage, email, electronic signing and document management services;
regulators and government agencies, including ASIC, AUSTRAC and the Australian Taxation Office, where required or authorised by law; and
any person you have authorised us to deal with, such as a financial adviser or joint holder.
We do not sell personal information. We do not use your personal information for direct marketing without your consent, and you may opt out at any time.
Some of our service providers store or process data outside Australia. Where this occurs, we take reasonable steps to ensure that your information is handled in accordance with the Australian Privacy Principles.
5. Tax file numbers
We collect tax file numbers only for the purposes permitted by taxation law and handle them in accordance with the Privacy (Tax File Number) Rule 2015. You are not required to provide your tax file number, but if you do not, tax may be withheld from distributions at the highest marginal rate.
6. Security and retention
We take reasonable steps to protect your personal information from misuse, interference, loss and unauthorised access, modification or disclosure, including through access controls, secure platforms and encryption where available.
We retain personal information for as long as it is needed for the purposes described above and to meet our legal obligations. Records collected for anti-money laundering purposes are retained for at least seven years after the end of our relationship with you, as the law requires.
7. Access and correction
You may request access to the personal information we hold about you, or ask us to correct it, by contacting us using the details below. We will respond within 30 days. We may need to verify your identity before releasing information, and in limited circumstances we may decline access as permitted by law, in which case we will tell you why.
8. Complaints
If you believe we have handled your personal information inappropriately, please contact us using the details below. We will acknowledge your complaint promptly and aim to resolve it within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at www.oaic.gov.au.
9. Website
Our website may collect limited technical information, such as your IP address, browser type and pages visited, through cookies and similar tools. This information is used to operate and improve the website and is not used to identify you.
10. Changes to this policy
We may update this policy from time to time. The current version will always be available on our website.
11. Contact
Privacy Officer Eucalypt Estates Pty Ltd max@eucalyptestates.com.au +61 439 963 538