We collect personal information that is reasonably necessary to operate the Platform and provide our services. This may include:

• Identity information – name, date of birth, residential address, and government-issued identity documents (for KYC/AML verification).
• Contact information – email address, phone number, and postal address.
• Investor tiering information – financial information, accountant certificates, trust deeds, SMSF trust deeds, and other documents used to confirm wholesale investor status under s708 of the Corporations Act 2001 (Cth).
• Platform activity – expressions of interest submitted, offers viewed, and account preferences.
• Technical information – IP address, browser type, device type, and usage logs collected automatically when you use the Platform.

We collect personal information directly from you where practicable. In some cases, we may collect information from third parties – for example, identity verification providers, custodians, or publicly available sources.

We use your personal information to:

• verify your identity and assess your eligibility as a wholesale investor;
• provide you with access to the Platform and its features;
• process and manage expressions of interest and coordinate investment documentation;
• communicate with you about your account, the Platform, and relevant opportunities;
• comply with our legal and regulatory obligations, including AML/CTF laws;
• improve the Platform and our services; and
• send you information about Volt Capital's services where you have consented to receive it, or where we are otherwise permitted to do so.

We will not use your personal information for any purpose that is unrelated to the above without your consent, unless required or authorised by law.

We may disclose your personal information to:

• Service providers – identity verification providers, custodians, cloud hosting providers, and IT service providers who assist us in operating the Platform;
• Offer issuers – where you have submitted an expression of interest in a specific offer, and only to the extent necessary to facilitate that interest;
• Regulatory and law enforcement bodies – where required or authorised by law, including AUSTRAC, ASIC, and other applicable regulators; and
• Professional advisers – lawyers, accountants, and auditors, subject to confidentiality obligations.

We do not sell your personal information to third parties. We do not use or disclose your personal information for direct marketing purposes without your consent, or as otherwise permitted by the APPs.

Some of our service providers may be located outside Australia. Where we disclose personal information to overseas recipients, we take reasonable steps to ensure they handle it in a manner consistent with the APPs.

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification, or disclosure. These steps include encryption of data in transit and at rest, access controls, and regular security review.

However, no data transmission over the internet is guaranteed to be completely secure. While we strive to protect your personal information, we cannot warrant the absolute security of any information you transmit to us.

When we no longer need personal information, and we are not required by law to retain it, we will take reasonable steps to destroy or de-identify it.

You have the right to request access to the personal information we hold about you, and to request that we correct it if it is inaccurate, out of date, incomplete, irrelevant, or misleading.

To make an access or correction request, please contact us using the details below. We will respond within a reasonable timeframe and in accordance with the APPs. In some cases, we may not be able to provide access – for example, where providing access would be unlawful or where doing so would unreasonably impact on the privacy of another individual. Where we refuse access or correction, we will tell you why in writing.

If you believe we have breached the APPs or an applicable privacy code, you may lodge a complaint with us in the first instance. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

The Platform may use cookies and similar technologies to operate correctly, remember your preferences, and analyse how the Platform is used. We do not use third-party advertising cookies.

You can control cookie settings through your browser. Disabling cookies may affect Platform functionality.

We may update this Privacy Policy from time to time. We will notify registered members of material changes by email and update the “Last updated” date above. Continued use of the Platform after the effective date of any change constitutes your acceptance of the updated policy.

If you have any questions, concerns, or complaints about this Privacy Policy or how we handle your personal information, please contact our Privacy Officer:

Volt Capital Pty Ltd
[●] [Address pending]
New South Wales, Australia
Email: privacy@voltcapital.asia