PRIVACY STATEMENT

1. INTRODUCTION & BACKGROUND

Impact Investment Group Pty Ltd ACN 139 328 108 (IIG or the Company) is a leading Australian Impact Investment fund manager, advisor and co-investor. Established in early 2013, IIG has originated investments in commercial real estate, renewable energy and infrastructure. IIG believes that values-aligned investment can be sustainable and profitable for all stakeholders. IIG is an early adopter of Impact Investing principles and is regarded as a thought leader in the emerging Australian Impact Investment space. IIG originates and transacts on investments which generate financial performance with sustained environmental and social impact. IIG regularly reports to its investors on the financial, social and environmental returns generated by its assets.

IIG is one of Australia’s first certified B Corporations and believes in using the power of business to drive positive social and environmental change. As a B Corporation, IIG has met high standards of transparency, governance and accountability assessed by the B Lab international standards committee. IIG is a member of the Responsible Investment Association of Australasia.

2. OUR COMMITMENT TO PRIVACY

This Privacy Statement relates to IIG and its subsidiaries, including Giant Leap Manager Pty Limited (ACN 609 960 036) (IIG Group).

In this policy, "us", "we" or "our" means IIG and its related bodies corporate within the IIG Group.

We recognise an individual’s right to privacy and understand that the protection and confidentiality of your personal information is important to you.

We have practices in place to comply with the 13 Australian Privacy Principles set out in The Privacy Act 1998 (Cth) (Privacy Act). These principles govern how organisations handle personal information.

This Privacy Statement outlines the types of personal information we collect, how that information is collected, used, stored, and protected and to whom we may disclose personal information.

3. THE TYPES OF PERSONAL INFORMATION THAT WE COLLECT

Personal information is information or an opinion about an identified, or reasonably identifiable individual.

The types of personal information that we may collect from you can include your name, contact details (such as your address and telephone number), date of birth, individual investment details, bank account information and tax file number.

The Corporations Act 2001 (Cth) requires us to collect your name, address and date of birth. Pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act(AML/CTF Act) we are also required to collect additional personal information from you to verify your identity.

4. PERSONAL INFORMATION SECURITY

We regard the security of your personal information as a priority and have a number of physical and electronic protection measures in place. Please be aware that the Internet is not a secure environment hence no personal data is stored on our public website.

5. FOR WHAT PURPOSES DO WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION?

We collect, use, hold and disclose your personal information for the purpose of providing you with our products and services. Collection of your personal information allows us to identify you and assess applications for your investment in our Schemes. This includes:

  • checking whether you are eligible for the product or service;
  • verifying your identity;
  • helping to manage the product or service;
  • managing relationships with our clients;
  • providing our clients with information about our products, services, the markets and developments that may interest them; and
  • facilitating our internal business operations, including to fulfil our legal requirements.

Your personal information will also be used for related purposes which include, the administering and ongoing management of your investment, communication with you and compliance with Australian taxation laws, the Corporations legislation, the AML/CTF Act and other laws and regulations.

Throughout the life of the investment product or service, we may collect and hold additional personal information about you. This may include transaction information or making a record of queries or complaints you make. We may also collect personal information about individuals who are not clients of the IIG Group (e.g. business contact details of a company representative with whom we deal).

We take steps to ensure that our agents and third parties(e.g.: consultants, advisors and partners)keep your personal information confidential and use it only for the purposes for which they, and the IIG Group are authorised.

You may also authorise us to disclose information to other persons nominated by you. These persons may include accountants, financial planners and investment managers. Your express consent is required in these circumstances. We reserve the right to contact you directly pursuant to our statutory obligations under the AML/CTF Act.

6. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect most personal information directly from you. For example, we will collect your personal information when you apply to invest in one of our Schemes or talk to us in person or on the phone.

Sometimes we collect personal information about you from other people or organisations. This may happen without your direct involvement, but as referred to above, your express consent will be required. For example, we may collect personal information about you from:

  • your representatives (including your legal or financial advisor, administrator, trustee, or attorney); and
  • other organisations, who jointly with us, provide products to you.

7. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose personal information for the purposes for which it was collected to:

  • our staff within the IIG Group;
  • our professional advisors including financial advisors, legal advisors, auditors and consultants;
  • our agents, contractors and external service providers;
  • Authorised Representatives on our AFSL who sell products on our behalf;
  • other organisations, who jointly with us, provide products or services to you;
  • your representatives (including your legal or financial adviser, accountant, trustee, or attorney); and
  • fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct.

We may also disclose your personal information to out-sourced back-office providers. The privacy standards of these providers must be at least in accordance with ours.

No personal information that we receive is disclosed by us to recipients based outside of Australian territory.

8. ACCESSING OR CORRECTING YOUR PERSONAL INFORMATION

You may contact us to request access to the personal information we hold about you at any time. You may also ask us to correct information about you that you may believe is inaccurate, incomplete or out of date.

We will need to verify your identity before giving you access to, or correcting your information.

In certain circumstances, we may not be able to correct or provide you with access to your information. In these circumstances, we will write to you to explain and provide the reasons as to why access cannot be granted.

We take all reasonable precautions to ensure that the personal information that we collect, use and disclose is accurate, complete and current. However, we recommend that you advise us if there are any errors in your personal information and that you update us on any changes to your personal information such as changes of name, address or bank account details.

9. RESOLVING YOUR PRIVACY CONCERNS & COMPLAINTS

If you have a query or a complaint regarding your personal information, please contact us (contact details provided below).

We will acknowledge your complaint within 10 business days of receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint. We aim to resolve complaints as quickly as possible.

If a complaint remains unresolved, you may apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. The Commissioner may be contacted on the privacy hotline: 1300 363 992.

Contact details

If you have any questions about this Privacy Statement, or wish to make a complaint about how we have handled your personal information, please contact the Privacy Officer:

privacy@impact-group.com.au

Impact Investment Group

11 Princes Street

St Kilda Vic 3182

Telephone: (03) 8534 8060

DISCLAIMER

Use of the GIANT LEAP FUND Website

This web site, accessible at www.giantleapfund.vc (Website), is owned and operated by the Impact Investment Group Pty Ltd (ACN 139 328 108) and its related bodies corporate (IIG Group).

Acceptance of and changes to terms and conditions of use

By using this Website, or downloading materials from this website, you agree to the terms and conditions of use contained in this notice without limitation or qualification. These terms and conditions of use may be revised at any time by updating this posting, and will be effective as of the date of such posting. Your continued use of the Website after any changes to this posting will be considered acceptance of those changes. This text was last revised on 27 June 2016

General Information

General information, opinions and other materials appearing on this Website are of a general nature only and shall not be construed as a securities recommendation or advice. Neither the Impact Investment Group Pty Ltd nor its subsidiary Giant Leap Manager Pty Ltd (ACN 138 179 914, AFSL No. 356648) is licensed to give advice and does not guarantee the performance of or repayment of capital or income in relation to the investments referred to on this website. The Website has not been prepared with reference to your individual financial circumstances. You should not rely on any advice in this Website without first seeking appropriate professional advice.

Applications for investment in the Schemes referred to on this website can only be made on the application form attached to the Information Memorandum and issued for each Scheme. Impact Funds Management reserves the right to accept or reject any application at its absolute discretion. Before making an investment decision you should read the Information Memorandum and seek your own advice on the investment before investing.

Giant Leap Manager Pty Ltd accepts no responsibility for the accuracy or completeness of the information, opinions or other materials provided on or accessible through the Website. Where Giant Leap Manager Pty Ltd makes third party material available or accessible through the Website you acknowledge that Giant Leap Manager Pty Ltd is a distributor and not a publisher of that content and that its editorial control is limited to the selection of those materials to make available.

The content on this Website does not form part of the terms for Giant Leap Manager Pty Ltd supplying to you any products and services of Giant Leap Manager Pty Ltd.

No security or other product or service is offered or will be sold in any jurisdiction in which such offer or solicitation, purchase or sale would be unlawful under the securities, or other laws of such jurisdiction.

Disclaimer and Limitation of Liability

General

No part of these terms and conditions of use excludes, restricts or modifies any condition or warranty implied into these terms and conditions of use or any liability imposed on the Giant Leap Manager Pty Ltd by any applicable law (including the Australian Consumer Law contained in the Competition and Consumer Act 2010 (Cth)) if to do so would contravene such law or make any part of these terms and conditions of use void.

Exclusion and limitation

To the extent permitted by law, all conditions, warranties and other terms implied by statute, custom or the common law are excluded from these terms and conditions of use. If any statute implies terms into these terms and conditions of use which cannot be lawfully excluded, then those terms and conditions will apply and, to the extent permitted by law, the liability of Giant Leap Manager Pty Ltd for the breach of any such term will be limited to the minimum remedy provided for in such terms and conditions.

Liability of Giant Leap Manager Pty Ltd (whether that liability arises under contract, tort (including negligence) or statute) is limited to the amount paid by you, if any, for accessing this Website.

In no circumstances will Giant Leap Manager Pty Ltd, its subsidiaries, affiliates, or any party involved in creating, producing, or delivering this Website be liable to you or to any entity for any loss or damage, however caused (including negligence), which may be directly or indirectly suffered in connection with the use of, or the inability to use, the content, materials and functions on this Website or any linked Website, even if Giant Leap Manager Pty Ltd has been expressly advised of the possibility of such damage.

The IIG Group excludes liability (whether that liability arises under contract, tort (including negligence) or statute) for any incidental, consequential, special, or punitive damage (including, without limitation, any loss of profits, loss of opportunity, loss of revenue, loss of anticipated savings, business interruption, loss of information or programs or other data on your information handling system) resulting from the use of, or the inability to use, the content, materials and functions on this Website or any linked Website, even if the IIG Group or an authorised representative of Impact Funds Management Pty Ltd has been expressly advised of the possibility of such damage.

Damage and viruses

Giant Leap Manager Pty Ltd will not be liable for any damage to, or viruses that may infect, your computer equipment or other property as a result of access to, use of, or browsing this Website or your downloading of any data, text, images, video, or audio material from this Website.

Errors

Giant Leap Manager Pty Ltd does not warrant that the functions contained in the Website materials will be uninterrupted or error-free, that defects will be corrected, or that this Website or the server that makes it available are free of viruses or other harmful components. The IIG Group does not warrant or make any representations regarding the use or the results of the use of the materials on this Website in terms of their correctness, accuracy, reliability, or otherwise.

Copyright

This website contains copyright works that have been created by Giant Leap Manager Pty Ltd . No copyright work shall be reproduced or transmitted separately to this website content in any manner without the specific written permission of Giant Leap Manager Pty Ltd . Any unauthorised use of the images may infringe copyright laws, trade mark laws, the laws of privacy and publicity, and communications regulations and statutes. If it has been discovered that unauthorised use of copyright materials, which includes images, icons, tables, etc, has been taken then Giant Leap Manager Pty Ltd may bring legal proceedings against the unauthorised user and seek monetary damages as well as injunctions to stop immediate use those materials. In addition, the associated legal costs will be sought.

Governing law

This Website is controlled, operated and administered by Giant Leap Manager Pty Ltd from its offices in Melbourne and Sydney, Australia. Giant Leap Manager Pty Ltd makes no representation that materials on this Website are appropriate or available for use at other locations outside of Australia and access to them from territories where their contents are illegal is prohibited. If you access this Website from a location outside of Australia, you are responsible for compliance with all applicable local laws. These terms and conditions of use shall be governed by the laws of the State of Victoria. You agree that the appropriate State or Federal Court in Victoria will have the exclusive jurisdiction to resolve all disputes arising from this Website or these terms and conditions of use, and you consent to personal jurisdiction in such forum.

Entire agreement and severance

These terms and conditions of use constitute the entire agreement between Giant Leap Manager Pty Ltd and you with respect to your use of this Website. Part or all of any provision in these terms and conditions of use that is illegal or unenforceable, will be severed from these terms and conditions of use and the remaining provisions will continue in force and effect and be enforced to the maximum extent permissible so as to effect the original intent of these terms and conditions of use.

DISCLAIMER

This website published June 2016 has been prepared and issued by Giant Leap Manager Pty Ltd (ACN 609 960 036) (“GLM”), a corporate authorised representative of Impact Funds Management Pty Ltd (ACN 138 179 914, AFSL No. 356648) (“IFM”). The information contained in this website has been made available to the recipient for information purposes only. It is not intended to be, and does not constitute a Product Disclosure Statement, prospectus, short form prospectus or profile statement as those terms are defined in the Corporations Act 2001 (Cth). General information which is presented in this website is not intended to constitute a securities recommendation. Neither IFM nor GLM is licensed to give personal advice and does not guarantee the performance of or repayment of capital or income in relation to the Fund. For this reason, it is important that you consider the Giant Leap Fund Information Memorandum (“IM”) once available and seek appropriate independent professional advice before making any investment decision. Applications for investment in the Fund can only be made on the application form attached to the IM.

This investment opportunity will be available for “wholesale clients” or sophisticated investors” only as those terms are defined in the Corporations Act 2001 (Cth). An investment in the Giant Leap Fund is subject to risk, including possible delays in payment and loss of income and principal invested. Neither GLM nor any of its associates, related entities or directors, guarantee the performance of any investment or the repayment of monies invested. While every care has been taken in the preparation of this website, GLM does not make any warranty as to the accuracy or completeness of any statement on this website in it including, without limitation any forecasts or opinions. To the maximum extent permitted by law, GLM disclaims all liability for any loss or damage which may arise out of the provision to, or by, or use by, any person of the information contained in this website. All figures stated herein are as the date of the website unless otherwise stated. GLM does not receive fees in respect of the general financial product advice it provides, however it will receive fees for establishing and operating the Fund, in accordance with the partnership documents. GLM and its related entities may also receive fees for managing the assets of, and providing resources to the Fund. For more detail on fees, refer to the IM.