Hamilton12 is committed to protecting the personal information of its clients and investors. In the context of the Hamilton12 investment fund, this includes any personal information that Hamilton12 collects and uses in order to make investment decisions and manage the fund. This may include, for example, information about clients' and investors' financial situations and investment preferences and any other personal information we collect during our business. From time to time this information may be shared with third parties such as stock exchanges or other financial institutions as necessary to conduct our business.

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Hamilton12 has implemented appropriate security measures to protect the personal information we collect from unauthorised access, use, or disclosure. We will only retain this information for as long as necessary to fulfil the purposes for which it was collected.

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Clients and investors can access and update their personal information and can make a complaint if they believe that Hamilton12 have not handled their personal information in accordance with the policy or the applicable privacy laws.

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Policy:

At Hamilton12 Pty Ltd (Hamilton12), we recognise the importance of protecting your personal information. We are committed to processing it responsibly and in compliance with applicable data protection laws in all countries in which Hamilton12 operates. Maintaining your trust is paramount to us.

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The Australian Privacy Principles bind Hamilton12 set out in the Privacy Act, which imposes specific requirements on Hamilton12 concerning the handling of personal information. Hamilton12 has implemented procedures to ensure that personal information is handled under the Act. Hamilton12 has issued this policy in compliance with the Act.

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Please read the following policy to understand how Hamilton12 deals with the personal information that it may collect about you from time to time. This policy may change from time to time, so please revisit the policy periodically.

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This Privacy Policy describes Hamilton12’s general privacy practices that apply to the personal information we collect, use and share about consumers and other individuals within our clients, business partners, suppliers, and other organisations with which Hamilton12 has or contemplates a business relationship.

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This Privacy Policy also applies to Hamilton12 websites that link to this Policy but do not apply to those Hamilton12 websites that have their Privacy Policy.   We may provide additional or more specific information on the collection or use of personal information on websites or related to a specific product or service.

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We may supplement this Policy with additional information relating to a particular interaction with you, such as a transaction document or a specific privacy policy when you order or use an online service of Hamilton12.

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If you have questions or complaints regarding our Privacy Policy or practices, please get in touch with the:

Hamilton12 Corporate Privacy Office

Level 5 / 300 Adelaide Street

Brisbane, Queensland 4000 Australia

Email: compliance@hamilton12.com

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Hamilton12 - Personal Information we collect

While providing our products and services, Hamilton12 may collect Personal Information from clients or potential clients. While providing products and services, we may collect:

 

• Personal information including names, addresses and other contact details; dates of birth; and financial information.

• Sensitive information includes government identifiers (such as your TFN), nationality, country of birth, professional memberships, family court orders and criminal records.

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How we collect personal information will primarily be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you. Where possible, Hamilton12 has attempted to standardise the collection of personal information by using specifically designed forms (e.g. our Application Forms).

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We may also collect personal information from other people (e.g. a third-party administrator) or independent sources; however, we will only do so where it is not reasonable and practical to collect the information from you directly.

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To comply with security and legal requirements concerning the operation of our website(s), we collect information about your activities, such as passwords, IP addresses and browser settings. We record this information to provide access to the website's operation. We may use information collected on your use of the Hamilton12 online services to allow us to:

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• Establish statistics about our software products' usage and effectiveness and Hamilton12 Online services.

• Improve and personalise your use and experience of our products and services.

• Tailor our interactions with you.

• Inform our clients on the overall use of our products and services, and improve and develop our products and services.

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We collect information from your visits to our website(s) to help us gather statistics about usage and effectiveness, personalise your experience, tailor our interactions with you, and improve our products and services. We do so using various technologies, including scripts, tags, Local Shared Objects (Flash cookies), Local Storage (HTML5) beacons, and "cookies".

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A cookie is a piece of data that a website can send to your browser, which may then be stored on your computer as a tag that identifies your computer. Cookies can make your subsequent visits to our website more straightforward and more efficient. We may also use the information to improve the website, marketing and product development. You can set your browser to notify you when you receive a cookie, giving you a chance to decide whether or not to accept it. By not accepting cookies, some pages on the website may not display correctly, or you may not be permitted to access certain information. Cookies can be turned off or deleted anytime through your browser settings. A server cannot find a name, email address, or anything about you using cookies.

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Cookies can make your subsequent visits to our website more straightforward and more efficient.  We do not store or collect cookie information.

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While Hamilton12 website(s) at this time do not recognise automated browser signals regarding tracking mechanisms, such as "do not track" instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser. Look under the heading "Tools" (or a similar heading) in your browser for information about controlling cookies. In most instances, you can set your browser to notify you before receiving a cookie, giving you the option to decide whether to accept it. You can also generally set your browser to turn off cookies. Cookies in our software products can be turned off in the product itself. Since cookies allow you to take advantage of some of our websites' features or features of our software products and Hamilton12 Online services, we recommend leaving them turned on. If you block, turn off or otherwise reject our cookies, some web pages may not display correctly, or you will not be able to, for instance, add items to your shopping cart, proceed to checkout, or use any website or Hamilton12 Online services that require you to sign in.

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Hamilton12 - Use of Information in the Social Computing Environment

Hamilton12 provides social computing tools on some of its Web sites to enable online sharing and collaboration among members who have registered to use them. These may include forums, wikis, blogs and other social media platforms.

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You may be asked to provide certain personal information when downloading and using these applications or registering to use these social computing tools. Registration information will be subject to and protected under this Privacy Policy, except for the information automatically made available to other participants as part of your profile. These applications and tools may also include supplemental privacy Policies with specific information about collection and handling practices. Read those additional policies to understand what the tools and applications may do.

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You should be aware that your content on social computing platforms may be made broadly available to others inside and outside Hamilton12. Any content you post, such as pictures, information, opinions, or any other type of personal information you make available to other participants on these social platforms or applications, is not subject to this Privacy Policy. Instead, such content is subject to the Terms of Use of those applications or platforms, any additional guidelines and privacy information provided with their use, and the process by which you can remove your content. Please refer to those Terms of Use to better understand your, Hamilton12's, and other parties' rights and obligations concerning such content.

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Hamilton12 – Storage and Security of Personal Information

Personal information is stored in various formats, including on databases, laptop computers and hard copy files. The security of your personal information is paramount to Hamilton12. Hamilton12 takes reasonable steps to ensure there is no misuse, loss, unauthorised access, modification or disclosure to protect your personal information. These steps include:

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• Restricting access to information on our databases on a need-to-know basis.

• Implementing ICT systems, policies and procedures to protect personal information storage on our computer networks.

• Undertaking due diligence concerning third-party service providers who may have access to personal information, including customer identification providers and cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.

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We store your personal information for as long as is needed to fulfil the purposes outlined in this Privacy Statement. Following this time, it is either anonymised (where permitted by applicable law), deleted or destroyed.

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Hamilton12 – Use and Disclosure of Personal Information

To offer you an improved and consistent customer experience when interacting with us or for other purposes outlined in this Privacy Statement and where permitted by law, we may combine the information that we collect via our Website(s) with additional information we hold about you (such as information about your use of our products and services).

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We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or a secondary purpose that you would reasonably expect or to which you have consented. Our uses of personal information include but are not limited to the following:

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• Providing you with one or more of our financial services or products;

• To assess your application for a financial product or service; and/or

• To communicate with you about the products and services that we offer.

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We may also need to collect personal information to comply with our legal obligations, such as the AML/CTF laws, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

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It may be necessary for Hamilton12 to disclose your personal information to certain third parties to assist us with one or more of our functions or activities. This may include organisations providing fund administration or custodial services under an arrangement with us.

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We only collect sensitive information reasonably necessary for one or more of these functions or activities if we have the consent of the individuals to whom the sensitive information relates or if the collection is necessary to lessen or prevent a serious threat to life, health or safety or another permitted general situation.

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Hamilton12 will only use personal information for the purposes it is given or for purposes directly related to one or more of our functions or activities. Hamilton12 may disclose your personal information to government agencies and other recipients from time to time only if one or more of the following apply:

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• you have consented;

• you would reasonably expect us to use or disclose your personal information in this way;

• we are authorised or required to do so by law;

• disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or public saftey;

• where another permitted general situation applies;

• disclosure is reasonably necessary for law enforcement-related activity.

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Children

Unless otherwise indicated, our websites, products and services are not intended for use by children under the age of 16.

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Disclosure of your personal information to overseas recipients

We may disclose personal information about an individual to overseas organisations that help us provide our services in certain circumstances, such as when storing information with a “cloud service provider” which stores data outside of Australia. We will, however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:

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• we have the individual’s consent (which may be implied);

• we have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy Principles or a similar privacy regime;

• we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or

• we are taking appropriate action in relation to suspected unlawful activity or serious misconduct.

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Notification of Changes

If we make any material changes to this Privacy Policy, we will notify you via notification on our website, and as otherwise required by applicable law.

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Your Rights

You can request to access, update or correct your personal information. You also have the right to object to direct marketing. You can access the request process by writing to: compliance@hamilton12.com

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You may have additional rights pursuant to your local law applicable to the processing. For example, suppose the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and your personal information is processed based on legitimate interests. In that case, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.

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Right to Lodge a Complaint

We will make all efforts possible to investigate your complaint, and advise you of the outcome as soon as possible. Your complaint can also be taken to the Office of the Australian Information Commissioner, who can be contacted at:

Office of the Australian Information Commissioner (OAIC)

Level 3 / 175 Pitt Street

Sydney NSW 2000

Visit oaic.gov.au

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If you have a question related to this Privacy Policy, please get in touch with us at:

Hamilton12 Corporate Privacy Office

Level 5 / 300 Adelaide Street

Brisbane QLD 4000

Email: compliance@hamilton12.com