Last updated: March 2026

1. Introduction

Colter Bay Capital FM Pty Ltd ("we", "us", "our") is committed to protecting the privacy of your personal information. This Privacy Policy explains how we collect, use, disclose, and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. Information We Collect

We may collect the following types of personal information:

Name and contact details (email, phone, address)
Company or business name
Financial information relevant to investment eligibility
Identification documents for verification purposes
Communication preferences
Website usage data and analytics

3. How We Collect Information

We collect personal information:

Directly from you when you contact us, submit forms, or apply to invest
From third parties such as accountants or financial advisors with your consent
Through our website via cookies and analytics tools
From publicly available sources

4. How We Use Information

We use your personal information to:

Respond to your enquiries and provide information about our services
Process investment applications and verify investor eligibility
Provide ongoing investor communications and reporting
Comply with legal and regulatory obligations
Improve our website and services
Send you marketing communications with your consent

5. Disclosure of Information

We may disclose your personal information to:

Service providers who assist with our operations (e.g., fund administrators, auditors)
Professional advisors (lawyers, accountants)
Regulatory authorities where required or authorised by Australian law, including the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO), and the Australian Transaction Reports and Analysis Centre (AUSTRAC)
Related entities within our corporate group

We will not sell or rent your personal information to third parties for marketing purposes.

Overseas Disclosure

We may disclose personal information to the following overseas recipients in connection with providing our services:

Resend Inc. (Delaware, USA) — transactional email delivery
Upstash Inc. (USA) — rate limiting and security infrastructure
Cloudflare Inc. (USA) — website hosting and content delivery

These disclosures are made in accordance with Australian Privacy Principle 8. By using our services, you consent to the disclosure of your personal information to these overseas recipients. We take reasonable steps to ensure overseas recipients handle your personal information in accordance with the Australian Privacy Principles.

6. Data Security

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorized access, modification, or disclosure. This includes physical security measures, secure electronic storage, and access controls.

Notifiable Data Breaches

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988.

7. Your Rights

You have the right to:

Request access to your personal information
Request correction of inaccurate information
Request deletion of your information (subject to legal requirements)
Opt-out of marketing communications
Make a complaint about our handling of your information

You may request access to or correction of your personal information by contacting us at info@colterbaycapital.com.au or our postal address. We will respond to access requests within 30 days. If you are dissatisfied with our handling of your request, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

8. Cookies, Technical Data & Analytics

We use the following technical measures for security and compliance:

A signed HTTP cookie (cbc_wholesale_verified) to verify wholesale investor status, containing: verification status, timestamp, pathway, and hashed IP/user-agent data. This cookie expires after 24 hours.
Session storage (cbc_wholesale_gate) for client-side gate state during your browser session.
IP address and user-agent logging for security auditing and rate-limiting purposes.

We do not currently use third-party analytics tracking. You can control cookie preferences through your browser settings.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on our website.

10. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Email: info@colterbaycapital.com.au
Location: Sydney, Australia