Reach AlternativesIM Ltd t/a Reach Alts (ACN 657 758 006)
Originally published: 1 November 2022
Version: 4.0
Last updated: 1 November 2025.
Overview
Reach Alternatives IM Pty Ltd (ACN 657 758006) trading as Reach Alts (Reach Alts, we, us, our)respects your privacy and is committed to protecting your personal information.
We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
This Privacy Policy explains how we collect, use, disclose and protect your personal information when you:
· visit or use our public website at https://www.reachalts.com.au/ (the Website);
· register for and use our online investment platform and investor portal at https://www.invest.reachalts.com.au/ (the Platform); or
· otherwise interact with us, including in connection with any investment.
By providing personal information to us(including via the Website or Platform), you agree to the handling of your personal information as described in this Privacy Policy.
1. What personal information we collect
1.1 The types of personal information we collect about you will depend on how you interact with us. It may include the types of information set out in clauses 1.1 to 1.4.
1.2 For Website visitors and marketing contacts, we may collect:
(a) name, email address, phone number and organisation;
(b) your role, areas of interest and preferences (for example, asset classes and strategies);
(c) communications you send us (for example, enquiries and feedback); and
(d) information about your interactions with our Website and emails (see clause 10).
1.3 For Platform Members and investors, we may collect:
(a) full name, date of birth and contact details;
(b) residential and/or business address;
(c) details of your investment entity or structure (for example, company, trust or SMSF), including directors, trustees, ultimate beneficial owners and authorised signatories (including certain documentation i.e. IDs, trust deeds and amendments, bank statements, powers of attorney, statutory declarations, among others);
(d) information to assess whether you are a wholesale client or otherwise not a retail client;
(e) tax and regulatory information (for example, Tax File Numbers where permitted, FATCA/CRS details);
(f) financial information relevant to your investment (for example, bank account details for distributions or redemptions); and
(g) information about your investments with us (for example, applications, holdings, distributions and capital calls).
1.4 For identity verification and AML/CTF purposes, we may collect:
(a) identification document details (for example, driver licence, passport, birth certificate, Medicare card or national ID card);
(b) copies of identification documents (where necessary);
(c) information from sanctions, politically exposed persons (PEP) and adverse media screening; and
(d) information required under anti-money laundering and counter-terrorism financing (AML/CTF) laws.
1.5 We may verify the information referred to in clause 1.4 using electronic identity verification services, including the Australian Government’s Document Verification Service (DVS) via our service provider GBG ANZ Pty Ltd (and equivalent services in other jurisdictions where relevant).
1.6 We may also create or derive information about you, including:
(a) internal notes, recordings and transcripts from your interactions with us or with ourWebsite or Platform;
(b) risk assessments and AML/CTF assessments;
(c) records of communications and instructions; and
(d) information about your use of the Platform (for example, login activity and access to data rooms).
2. How we collect personal information
2.1 We may collect personal information directly from you, including when you:
(a) visitor use the Website or Platform;
(b) complete online forms, applications or profile information;
(c) signup for newsletters, events or other marketing communications; or
(d) communicate with us by email, phone, video call or in person.
2.2 We may collect personal information from your professional advisers, such as financial advisers, accountants and lawyers, where you have authorised this or it is otherwise reasonable in the circumstances.
2.3 We may collect personal information from third-party service providers, including:
(a) identity verification providers (such as GBG and the DVS and equivalent services);
(b) fund administrators, custodians and registry providers; and
(c) payment and embedded finance providers, including Airwallex.
2.4 We may collect personal information from public sources and regulators, including:
(a) ASIC, the Australian Business Register (ABR) and other corporate registries; and
(b) public sanctions lists and similar public databases.
2.5 If you provide personal information about another individual (for example, a director, trustee, beneficiary or beneficial owner), you must ensure that:
(a) the individual is aware that you have provided their information to us;
(b) the individual is aware of the contents of this Privacy Policy; and
(c) you are authorised to provide their information to us.
3. Why we collect and use your personal information
3.1 We collect, hold, use and disclose personal information for purposes including those set out in clauses 3.2 to 3.5.
3.2 ForWebsite and marketing purposes, we may use your personal information to:
(a) operate, maintain and improve the Website;
(b) respond to enquiries and provide information about our business, products and services;
(c) send newsletters, updates and marketing communications (you may opt out at anytime); and
(d) analyse Website usage and the effectiveness of our communications.
3.3 For Platform, investment and services purposes, we may use your personal information to:
(a) assess your eligibility for a Platform account and for access to particular information or opportunities;
(b) provide the Platform and related services to you and your investment entity;
(c) enable you to view information memoranda, legal documents and data room materials;
(d) process applications, capital calls, redemptions, distributions and other investment-related transactions;
(e) administer investments, including reporting to you and your advisers; and
(f) maintain accurate records of your investments and instructions.
3.4 For identity verification, AML/CTF and risk management purposes, we may use your personal information to:
(a) verify your identity (and the identity of related parties) using internal processes and external services (including the DVS);
(b) conduct AML/CTF, sanctions, fraud and PEP checks;
(c) monitor transactions and activity for suspicious behaviour; and
(d) comply with legal and regulatory obligations in Australia and other relevant jurisdictions.
3.5 For business operations and legal compliance purposes, we may use your personal information to:
(a) manage our relationship with you and administer our business;
(b) train staff and improve internal processes and systems;
(c) handle enquiries, complaints and disputes;
(d) comply with our obligations to regulators, law enforcement agencies and courts; and
(e) protect our rights, property, operations and the security and integrity of our systems.
3.6 We may also use personal information for:
(a) related secondary purposes that are within your reasonable expectations; and
(b) any other purpose for which you have given your consent,
or as otherwise permitted or required by law.
4. Identity verification and the DVS
4.1 We may use the DVS (and similar services) to verify your identity. This may involve:
(a) providing your identification details (for example, name, date of birth, document number and expiry date) to our service provider GBG, which acts as our information match agent; and
(b) GBG submitting those details to the issuer or official record holder of the relevant document (for example, an Australian or New Zealand government agency).
4.2 The agencies described in clause 4.1 use the information only to check whether the details match their records. They do not provide us with a copy of the underlying government record. We receive a result indicating, for example, that the details matched, did not match or that an error occurred.
4.3 By submitting identification information to us (including via the Website, thePlatform or any third-party interface we use), you:
(a) confirm that you are authorised to provide the information; and
(b) expressly consent to us, GBG and the relevant government agencies or record holders using and disclosing the information as described in this clause 4, and in any collection notices we provide, for the purposes of identity verification, AML/CTF, fraud prevention and compliance with our legal and regulatory obligations.
4.4 If you do not wish to use electronic verification (including the DVS), you must contact us using the details in clause 13. We will discuss alternative methods of verifying your identity. These alternatives:
(a) maybe less convenient;
(b) may take longer to complete; and
(c) may limit or prevent your access to certain services or your ability to invest.
4.5 Identity and AML/CTF checks (including electronic checks) may be performed on an ongoing basis.
4.6 If you provide New Zealand identity documents, you acknowledge and agree that your details may be checked against the relevant New Zealand government records via an electronic information-matching service operated by or through our service providers, for the purposes described in this clause 4.
4.7 You may withdraw your consent to electronic verification at any time by contacting us. However, if you wish to invest or remain invested, withdrawal of consent may affect your ability to invest or remain invested.
5. Disclosure of personal information
5.1 We may disclose your personal information to third parties where reasonably necessary for the purposes set out in this Privacy Policy, including to:
(a) our related bodies corporate;
(b) fund trustees, responsible entities, general partners and managers associated with investments;
(c) fund administrators, custodians, registry providers and auditors;
(d) identity verification providers (including GBG and equivalent services), the DVS and other government agencies or record holders;
(e) payment and embedded finance providers, including Airwallex and its related bodies corporate and banking or financial partners, in connection with opening and operating your wallet (“Connected Accounts”), and processing payments, foreign exchange and related services;
(f) your nominated professional advisers (for example, financial advisers, accountants and lawyers), where you have authorised this;
(g) our IT, cloud hosting, data storage and cyber-security providers;
(h) marketing, analytics and communications service providers;
(i) insurers, professional advisers (for example, legal, tax and compliance advisers) and auditors; and
(j) courts, regulators, law enforcement agencies and government agencies where required or authorised by law.
5.2 Where we disclose your personal information to a third party, we will take reasonable steps to ensure that the recipient handles your personal information in a manner consistent with this Privacy Policy and the APPs.
6. Overseas disclosures
6.1 Some of the third parties to whom we disclose personal information (including cloud hosting providers, identity verification providers and payment or embedded finance providers such as Airwallex) may be located outside Australia, or may store or access personal information outside Australia.
6.2 The countries in which these recipients are likely to be located may include:
(a) NewZealand;
(b) countries in the Asia–Pacific region;
(c) the United States; and
(d) the United Kingdom,
although the specific locations may change over time as our service providers change their infrastructure.
6.3 When we disclose personal information overseas, we will take reasonable steps to ensure that the overseas recipient:
(a) does not breach the APPs in relation to the information; or
(b) is subject to a law or binding scheme that is overall at least substantially similar to the protections under the APPs,
or that another exception under the Privacy Act applies (for example, where you have expressly consented to the disclosure).
7. Data security and retention
7.1 We take reasonable steps to protect the personal information we hold from:
(a) misuse, interference and loss; and
(b) unauthorised access, modification or disclosure.
7.2 Measures we may use to protect personal information include:
(a) secure physical and electronic systems and controls;
(b) limiting access to personal information to staff and service providers who need it to perform their duties;
(c) multi-factor authentication and other security controls for access to the Platform and our systems;
(d) internal policies and staff training on privacy, cyber-security and data handling; and
(e) incident response and data breach response procedures in line with our Data Breach Notification Policy.
7.3 We retain personal information for as long as necessary for the purposes described in this Privacy Policy, or as required or permitted by law (for example,AML/CTF record-keeping obligations).
7.4 When personal information is no longer required, we will take reasonable steps to destroy or de-identify it, subject to any legal obligations.
8. Data breaches
8.1 If we become aware of a data breach involving personal information, we will follow our Data Breach Notification Policy. That policy sets out how we assess and respond to data breaches, including when we may notify affected individuals or regulators, having regard to any data breach notification obligations that apply to us.
9. Website analytics, cookies and third-party sites
9.1 When you visit our Website or Platform, we may collect certain information automatically, including:
(a) your IP address, browser type and operating system;
(b) the pages you visit, the time and date of your visit and the referring website; and
(c) information about how you interact with our Website, Platform and emails.
9.2 We may use the information described in clause 9.1 in aggregated or de-identified form for analytics, security, troubleshooting and to improve our Platform, Website and services.
9.3 We may use cookies and similar technologies (for example, pixels and local storage) on the Website and Platform. Cookies are small text files stored on your device that help identify your browser, recognise you between visits and remember your preferences.
9.4 We may use cookies to:
(a) operate and secure the Website and Platform;
(b) analyse usage and performance;
(c) customise content; and
(d) serve more relevant marketing content (including via third-party services such as Google Ads).
9.5 Most browsers allow you to block or delete cookies. If you do so, some parts of theWebsite or Platform may not function properly.
9.6 The Website and Platform may contain links to websites or services operated by third parties. We are not responsible for the privacy practices or content of those websites or services. We recommend that you review the privacy policies of any third-party sites you visit.
10. Access to and correction of your personal information
10.1 You may request access to the personal information we hold about you.
10.2 You may request correction of any personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.
10.3 To make a request under clause 10.1 or 10.2, you should contact us using the details in clause 13. We may ask you to. verify your identity before we provide access or make corrections.
10.4 We will respond to your request within a reasonable time.
10.5 In some cases, we may refuse access or correction where permitted or required bylaw (for example, where providing access would unreasonably impact the privacy of others or would be unlawful). If we refuse your request, we will tell you why and how you can complain.
10.6 We may charge a reasonable fee to cover the administrative costs of providing access, but we will not charge you simply for making a request.
11. Complaints
11.1 If you have any concerns or complaints about how we have handled your personal information, you should contact us using the details in clause 13 and provide details of your concern or complaint.
11.2 We take privacy complaints seriously. We will:
(a) acknowledge your complaint;
(b) investigate the circumstances; and
(c) respond to you within a reasonable time (usually within 30 days).
11.3 If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) using the contact details available at www.oaic.gov.au.
12. Changes to this Privacy Policy
12.1 We may update this Privacy Policy from time to time to reflect changes in our practices, the law or our services.
12.2 The updated Privacy Policy will be posted on our Website and will take effect from the date it is posted (or any later date specified in the updated Privacy Policy).
12.3 We encourage you to check our Website periodically to ensure you are aware of our current Privacy Policy.
13. Contact us
13.1 If you have any questions about this Privacy Policy, or wish to:
(a) request access to or correction of your personal information; or
(b) make a complaint about how we have handled your personal information, you can contact us using the details in clause 13.2.
13.2 Our contact details are:
(a) By post:
Reach Alts
Level 1, 39 Martin Place
Sydney NSW 2000
Australia
(b) By email:
contact@reachalts.com.au
