Privacy Policy

1. About this policy

Apollo Investment Management Pty Ltd ABN 22 673 370 717, AFSL 559566 (Apollo, we, us) handles personal information in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth). This policy explains what personal information we collect, how we use and disclose it, and how you can access or correct it or make a complaint.

2. Whose information we collect

We collect personal information about:

• prospective and current investors in the funds we operate, manage or administer;
• directors, trustees, beneficial owners, controlling persons and authorised signatories of investors that are companies, trusts or superannuation funds;
• financial advisers, accountants and others who act for investors;
• people who contact us through this website or otherwise;
• clients of our fund services and corporate advisory business, our service providers and other business contacts; and

3. What we collect

Depending on how you deal with us, this may include:

• name, contact details, date of birth, residential address and occupation;
• details of identification documents, and the results of identity verification;
• information showing that you are a wholesale client, such as a qualified accountant's certificate;
• tax file number (TFN), ABN, tax residency and foreign tax identification numbers;
• bank account details, investment holdings and transaction history;
• information about the source of your funds or wealth, where required;
• the results of screening for politically exposed persons and sanctions; and
• records of your communications with us, and information about how you use this website.

We collect sensitive information only where the law requires or authorises it, or with your consent. Screening required by anti-money laundering law can reveal sensitive information, such as membership of a political association or a criminal record.

4. How we collect it

We collect personal information directly from you, for example through enquiry and application forms, emails, phone calls and meetings. We also collect it from your financial adviser or accountant, identity verification and screening service providers, public registers such as those kept by ASIC and the Australian Business Register.

5. Why we collect it, and what happens if you don't provide it

We collect, use and disclose personal information to:

• respond to your enquiries;
• assess whether you are a wholesale client;
• identify you and verify your identity, as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• process applications, withdrawals and distributions, and keep the register of investors;
• send you statements, reports and fund communications;
• meet our tax obligations, including reporting under the Common Reporting Standard (CRS) and the US Foreign Account Tax Compliance Act (FATCA) as required by Australian tax law;
• comply with the Corporations Act 2001 (Cth), the conditions of our licence, audit requirements and requests from regulators;
• handle complaints and disputes; and
• tell you about our funds and services (see section 9).

If you do not provide the information we ask for, we may not be able to respond to you, accept your application, pay distributions or provide other services. Providing your TFN is not compulsory. If you do not provide it, tax may be withheld from distributions at the highest marginal tax rate plus the Medicare levy.

6. Who we disclose it to

We may disclose personal information to:

• the trustee, general partner, administrator, registry or custodian of a fund you invest in or enquire about;
• our auditors, legal advisers and tax advisers;
• identity verification and screening service providers;
• banks and payment service providers;
• IT, cloud, email and website service providers;
• your financial adviser, accountant or other representative, with your authority; and
• government agencies and regulators, including AUSTRAC, ASIC and the Australian Taxation Office (ATO), and others where the law requires or authorises it.

We do not sell personal information.

7. Disclosure overseas

Before disclosing personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles. The ATO may exchange information reported under CRS or FATCA with the tax authorities of countries where you are a tax resident.

8. Security and retention

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

We keep personal information only for as long as we need it and for any period required by law. We keep customer identification records required by anti-money laundering law for seven years after our relationship with you ends. To verify your identity we record the details we need, and we do not keep copies of your identity documents longer than necessary. When we no longer need information, we take reasonable steps to destroy or de-identify it.

If a data breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme.

9. Direct marketing

We may send investors, and people who have contacted us, information about our funds and services. You can opt out at any time by using the unsubscribe link or by contacting us.

10. Website, cookies and enquiry forms

We use cookies and analytics tools to understand how the website is used. Information you submit through our enquiry form is sent to us by email.

11. Information about other people

If you give us personal information about someone else, such as a director, beneficial owner or joint investor, please tell them about this policy.

12. Access and correction

You can ask to access, or correct, the personal information we hold about you by contacting our Privacy Officer. We will respond within a reasonable period, usually 30 days. We may refuse access in limited cases, for example where the law prevents us from giving it. If we refuse, we will tell you why in writing.

13. Complaints

If you have a privacy complaint, please contact our Privacy Officer. We will acknowledge it promptly and aim to respond within 30 days. If you are not satisfied with our response, you can complain to the OAIC at www.oaic.gov.au or on 1300 363 992.

14. Tax file numbers

We collect, use, store and disclose TFNs only for purposes permitted by tax law, and in accordance with the Privacy (Tax File Number) Rule 2015.

15. Changes to this policy

We may update this policy from time to time. The current version is always available on this website.

16. Contact

Privacy Officer

Apollo Investment Management Pty Ltd

Level 7, 191 Clarence Street, Sydney NSW 2000

zhiming@apolloim.com.au

0458 966 666