This Privacy Policy sets out how the following entities (referred to in this document as we, us or our) generally collect, hold and manage personal information about you in the ordinary course of our business and in relation to the delivery and maintenance of our investment platform, TEN13:
• Transition Level Investments Pty Ltd;
• TEN13 Holding Pty Ltd;
• TEN13 Nominee Pty Ltd;
• TEN13 Management Pty Ltd
Types of information collected
We may collect and hold personal information about you, that is, information that can identify you, and is relevant to us understanding your business or a particular enquiry.
We will also collect personal information about you including your name, address, phone number, email address and any information required for financial services compliance including Anti-Money Laundering (AML) / Counter-Terrorism Financing (CTF) purposes when you register your interest to invest in TEN13.
Method of collection
Personal information will generally be collected directly from you through the use of any of our standard online forms, over the internet, via email, in person, or through a telephone conversation with you.
There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
Internet users
If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Our website uses cookies. The main purpose of cookies is to identify users and to prepare customised web pages for them. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor usage of our website and to create a personal record of when you visit our website and what pages you view so that we may serve you more effectively.
Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
How we hold your personal information
We hold your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take reasonable measures to ensure that your personal information is stored safely to protect it from interference, misuse, loss, unauthorised access, modification or disclosure, including electronic and physical security measures.
Purpose of collection
We will collect, use and hold your personal information if it is reasonably necessary for us to consider an investment in your company.
However, we may also collect, hold and use personal information for the purposes of:
• onboarding you to our investment platform, TEN13;
• communicating with you in relation to deals hosted on TEN13;
• facilitating your investment or generally updating you on your investments through TEN13;
• providing you with promotional material or information about TEN13 or other services that we, our related entities and other organisations that we have affiliations with, offer that may be of interest to you;
• facilitating our internal business operations, including the fulfilment of any legal requirements;
• analysing our business needs with a view to developing new or improved services.
We may disclose personal information about you to:
• third parties, including software companies who may hold your information in different regions around the world, who assist us in operating our business, and these service providers may not be required to comply with our Privacy Policy; and
• other organisations with whom we have affiliations so that those organisations may provide you with information about services.
Disclosure of personal information overseas
Where in accordance with this Privacy Policy, we disclose your personal information to third parties who reside outside Australia, you agree and acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.
Failure to provide information
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking, including services relating to TEN13.
Access and correction
You may access the personal information we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access).
If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
Complaints and feedback
If you wish to make a complaint about a breach of the Australian Privacy Principles or a privacy code that you think applies to us, please contact us using the details below and we will take reasonable steps to investigate the complaint and respond to you.
If you have any queries or concerns about our privacy policy or the way we handle your personal information, please contact our privacy officer at:
PO Box: PO Box 906, Fortitude Valley, Queensland 4006
Email address: info@transitionlevel.com
Website: https://www.transitionlevel.com/
For more information about privacy in general, you can visit the Office of the Information Commissioner’s website at www.oaic.gov.au.
If you wish to make a complaint about the collection, use or disclosure of your personal information, please contact our privacy officer, and we will work with you to resolve the issue.
If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Information Commissioner.
To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.