Privacy Policy

This Privacy Policy outlines the ongoing obligations of Giant Leap Capital Services Pty Ltd as trustee for Giant Leap Capital Services Trust ABN 31 361 256 265 (Giant Leap) in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the APPs may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au.

Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy.

What is Personal Information and why do we collect it?

Personal Information means information or an opinion, whether true or not and whether recorded in material form or not, about an individual who is identified or reasonably identifiable.

What types of Personal Information do we collect?

Examples of Personal Information we may collect include, but is not limited to:

your name;
your contact details, including email addresses, street addresses, phone and facsimile numbers;
when investing or applying to invest in one of our funds:
your date of birth and gender;
your financial information;
data and documents you provide to us and which are required for Anti Money Laundering and Counter Terrorism Financing (AML/CTF) checks;
your passport and other identification documents;
government identifiers;

when you pitch your company to us for investment or we invest in your company:

your gender;
your career history, personal and professional references, resume and qualifications;
details of your business or prospective business, including registration details, financial information and pitch decks;
links to your website/LinkedIn profile;
information you provide to us including through feedback;
your preferences or opinions;

when you apply for employment with us:

your date of birth and gender;
your employment history and qualifications;
your financial details (if required);
your visa and/or employment status;
any information we need to onboard you, including background checks or any other information we are required to collect by law;

when you visit our Website:

details of the device you have used to access any part of our Website, including carrier/operating system, connection type, IP address, browser session and geo-location data, network data, statistics on page views and sessions and browsing behaviour;
information about your access to and use of our services, including through the use of internet cookies; and

any other personal information requested by us or provided by you or a third party.

This Personal Information is obtained in many ways including funding applications through the website and email correspondence. We don’t guarantee website links or policy of authorised third parties.

Why do we collect Personal Information?

The purposes for which we collect, hold and use your personal information may include:

to deliver our products or services to you;
administering the Giant Leap funds and other investment products and financial services offered by Giant Leap;
providing information and reports to investors;
to confirm your identity in compliance with AML/CTF laws;
to provide you with information about our products, services, functions, events or activities;
in connection with your attendance at or participation in events or activities conducted by Giant Leap or our partners;
to manage our relationship with you, evaluate our business performance and build our customer base;
to enable you to subscribe to our mailing lists or newsletters or follow our social media pages, including but not limited to LinkedIn;
to respond to your requests and seek your feedback;
to facilitate our internal business operations, including fulfilment of any legal and regulatory obligations and monitoring, analysing and improving the performance and functionality of our Website and investigating breaches of or enforcement of any legal terms applicable to our services; and
to manage risk and protect Giant Leap from fraud by verifying your identity and helping to prevent fraudulent use of our services.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

Sensitive Information

Sensitive Information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. Sensitive Information is a subset of Personal Information that is afforded a higher level of protection under the APPs.

Sensitive information will be used by us only:

for the primary purpose for which it was obtained;
for a secondary purpose that is directly related to the primary purpose; and
with your consent; or where required or authorised by law.

We may also collect Sensitive Information on an individual’s racial or ethnic origin for the purpose of reporting on the diversity targets set out in Giant Leap’s Diversity, Equity and Inclusion Policy (available here). Any such Sensitive Information collected for this purpose will be deidentified and anonymised before being collated at an aggregate level, and only the anonymised aggregated information may be made public.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties.

If we receive information about you from a third party, we will protect it as set out in this Privacy Policy. We do not routinely disclose personal information to third parties unless:

you have consented;
you would reasonably expect us to use or disclose your personal information in this way;
we are authorised to do so by law; or
the Personal Information has been de-identified and anonymised prior to release and is presented in an aggregated form.

This may include disclosing personal information to our employees, contractors and related entities, as well as third parties who supply services to us to assist us in performing our administration functions and in fulfilling our legal and regulatory obligations (e.g. legal and accounting firms, data storage systems and certain SaaS providers). For clarity, we do not sell, trade or rent your Personal Information to third parties without your consent.

If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Our Website may contain links to other parties’ websites. We do not have any control over those websites, and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Disclosure of Personal Information

Your Personal Information may be disclosed:

where you have consented to the use or disclosure;
where you would reasonably expect us to use or disclose your personal information in this way; or
where we are authorised to do so by law; or
where the Personal Information has been de-identified and anonymised prior to release and is presented in an aggregated form.

To whom may we disclose your Personal Information?

We may disclose your Personal Information to:

our employees, contractors and related entities;
third party service providers for the purpose of enabling them to provide their services to us, including (without limitation) IT service providers, legal and regulatory partners, marketing or advertising providers, professional advisors and payment systems operators;
our portfolio entities or persons where we are introducing you to them;
the readers of our Small Steps newsletter or Website blog, where you have been profiled or featured in an article, in respect of your name and professional history ;
our existing or potential agents or business partners;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
third parties to collect and process data, such as Google Analytics; and
any other third parties as required or permitted by law, such as where we receive a subpoena.

Sharing of Personal Information outside of Australia

Giant Leap operates primarily in Australia. In order to provide our services effectively, we may need to share some of your Personal Information with organisations outside of Australia. Sometimes, we may need to ask you before this happens. At this stage, our current list of overseas countries includes, without limitation and subject to change, the United Kingdom and the United States of America.We may store your information in a cloud or other types of networked or electronic storage. As electronic or networked storage may be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is held in this way, disclosures may occur in countries other than those listed.

In certain circumstances, your Personal Information may be shared with the Australian Taxation Office or the Australian Securities and Investments Commission which will then exchange this information with similar overseas regulatory bodies as a result of Australia’s participation in the Common Reporting Standard and Foreign Account Tax Compliance Act. Your Personal Information may also be shared with NSW Fair Trading and Consumer Affairs Victoria where required by law.

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. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

Security of your Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing. Giant Leap will not charge any fee for your access request.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Policy updates

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Website. We recommend you check our Website regularly to ensure you are aware of our current Privacy Policy.

Privacy Policy complaints and enquiries

If you have any queries or complaints about our Privacy Policy please contact us at:

11-15 Albert Street, Richmond, 3121

enquiries@giantleap.com.au

If you wish to make a complaint, you may do so by providing your written complaint to the contact details above. Where possible, the complaint should include enough information to help us resolve it. We will investigate and respond to your complaint in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response to a complaint and you are in Australia, you may lodge a complaint with the Office of the Australian Information Commissioner.