Privacy Policy
1. Scope
Burlingame focuses on private market investments for Australian wholesale clients. This policy covers personal information about investors and prospective investors, website users, founders, fund managers, sellers and their teams, advisors, suppliers and job applicants. Burlingame handles personal information in line with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth).
2. What we collect
- Contact and profile: name, email, phone, address, employer and role, referrer.
- Eligibility: wholesale client basis and supporting evidence (such as an accountant's certificate), and details of the investing entity, its directors, trustees and beneficial owners.
- We may see or pass on related details such as date of birth, address, identity document details, tax residency and source of funds.
- Investment details: opportunities of interest, commitments, allocations, holdings and related correspondence.
- Deal counterparties: professional background, references, public records and background check results obtained in due diligence.
- Job applicants: CV, employment history, qualifications and referee details, used only to assess the application.
- Website data: IP address, device data and cookie data. If we use analytics, we'll say so here.
We do not request tax file numbers. We do not generally collect sensitive information, other than background checks on deal counterparties, which we obtain with consent or as permitted by law.
Anonymity. Because investors must pass identity checks, you cannot deal with us anonymously or under a pseudonym, other than for general website enquiries.
3. How we collect it
Mainly from you directly, and also from people who introduce you, your advisers, public sources and our investment platform provider.
4. How we use it
We use personal information to respond to enquiries, confirm wholesale eligibility, consider and administer investments, carry out due diligence on deal counterparties, assess job applications, meet our legal and regulatory obligations, and keep you informed about our activities. You can opt out of marketing at any time.
5. Who we disclose it to
- Our investment platform provider, which holds investments for investors and carries out identity checks
- Our Australian financial services licensee, for compliance oversight, audits and anti-money laundering obligations.
- Deal counterparties (issuers, sellers, SPV sponsors and administrators, fund managers, registries and transfer agents) where needed to complete or administer an investment, including information about underlying investors some counterparties require for their own identity, tax, eligibility or regulatory checks.
- Service providers including Google Workspace (email and document storage), website hosting, electronic signature and accounting tools.
- Professional advisors and insurers, under confidentiality.
- Regulators, courts and law enforcement where required or authorized by law.
- A buyer or successor of our business, under confidentiality.
We do not sell personal information.
6. Overseas disclosure
Our email and documents are held on Google's cloud services, which may store and process data in the United States and other countries.
Many of our deals involve US issuers, SPVs and fund managers, so investor information may be disclosed to recipients in the United States and, depending on the deal, the United Kingdom, the European Union, Singapore or the Cayman Islands.
We take reasonable steps to ensure overseas recipients handle personal information consistently with the APPs.
7. Security and retention
We take reasonable technical and organizational steps to protect personal information. We keep records as long as needed for these purposes and as the law requires (generally at least seven years for financial records), then delete or de-identify them. We will notify affected individuals and the OAIC of any eligible data breach.
8. Access and correction
You can ask for access to, or correction of, personal information we hold about you by contacting us. We will respond within 30 days and give reasons if we refuse.
9. Automated decisions
We do not use automated processes to make decisions that significantly affect individuals. We will update this policy if that changes.
10. Complaints
Send privacy complaints to us at the address below. We will respond within 30 days. If you are not satisfied, you may contact the Office of the Australian Information Commissioner (www.oaic.gov.au).
11. Contact and updates
Privacy contact: Daniel Sharp, PO Box R1054, Royal Exchange NSW 1225, enquiries@burlingamepartners.com. We may update this policy from time to time. The current version is on our website.