Privacy
Policy

1. Introduction

Eldium Funds Management Pty Ltd ("Eldium", "we", "our" or "us") is committed to protecting your privacy and handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy explains how we collect, use, disclose and protect personal information.

2. Information We Collect

We may collect personal information including:

• Name and contact details
• Date of birth
• Identification documents
• Tax and residency information
• Financial and investment information
• Employment and income details

Where required by law, we may collect other sensitive information, including information required for AML/CTF compliance.

3. How We Collect Information

We may collect information:

• Directly from you
• Through application forms and onboarding processes
• Through advisers or intermediaries acting on your behalf
• Through our website and investor portal
• From service providers, verification providers and public sources where permitted by law

4. Why We Collect Information

We collect personal information to:

• Assess and process investment applications
• Administer investments and investor accounts
• Provide reporting and communications
• Verify identity and satisfy AML/CTF obligations
• Improve our services and platform
• Comply with legal and regulatory requirements

5. Disclosure of Information

We may disclose personal information to:

• Bolt Capital Pty Ltd as trustee and service provider
• Registry and administration providers
• Technology and cloud service providers
• Professional advisers
• Regulators, government agencies and law enforcement bodies
• Our group companies, including Eldium Pty Ltd
• Other parties where authorised by you or required by law

6. Overseas Disclosure

Eldium primarily stores and processes data within Australia. Certain technology providers may provide support services from overseas jurisdictions. Where personal information is disclosed outside Australia, Eldium will take reasonable steps to ensure such disclosures comply with the Australian Privacy Principles.

7. Data Security

Eldium maintains administrative, technical and physical safeguards designed to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Further information regarding Eldium's internal information security practices is maintained under separate internal policies.

8. Data Retention

Personal information will be retained for as long as reasonably necessary to fulfil the purposes for which it was collected and to satisfy legal, regulatory, accounting and recordkeeping obligations. In many cases, records relating to investments and investor onboarding are retained for at least seven years.

9. Access and Correction

You may request access to personal information we hold about you and request corrections if information is inaccurate, incomplete or out of date. Requests should be directed to contact@eldium.com.

10. Notifiable Data Breaches

If Eldium becomes aware of an eligible data breach under the Notifiable Data Breaches scheme, we will comply with applicable notification obligations, including notifying affected individuals and the Office of the Australian Information Commissioner where required.

11. Cookies and Analytics

Our website and platform may use cookies, analytics tools and similar technologies to improve functionality, security and user experience.

12. Changes to this Policy

This Privacy Policy may be updated from time to time. The current version will be available on our website.

13. Contact Us

For privacy enquiries or complaints, please contact: contact@eldium.com

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).