1. About this policy
This policy explains how Main Street Venture Capital Pty Ltd ACN 651 165 481 (MSVC, we, us) manages personal information. We seek to handle personal information consistently with the Privacy Act 1988 (Cth) and Australian Privacy Principles where they apply, and with the practices described in this policy.
Contact MSVC about privacy at [email protected].
2. Information we collect
We may collect names, contact details, job titles, entity and registration details, addresses, tax residence, investor category, indicative allocation, referral details, authority and capacity information, expected wholesale or professional investor eligibility, declarations and supporting evidence. We may also collect correspondence, meeting and diligence records, access and document activity, device and browser information, and IP-derived security information.
Where permitted and reasonably necessary, information used for identity, eligibility, compliance or source-of-funds checks may include government identifiers, financial information or other information supplied by you or your professional advisers.
3. How we collect information
We collect information directly through forms, correspondence, meetings, data-room activity and transaction documents. We may also receive it from an entity you represent, professional advisers, service providers, publicly available sources, counterparties or persons involved in compliance and due diligence.
If you give us information about another person, you should be authorised to do so and should make them aware of this policy where appropriate.
4. Purposes of collection, use and disclosure
We use personal information to assess identity, authority and investor eligibility; evaluate and administer data-room access; manage investor enquiries, due diligence, allocations and transaction processes; communicate with you; maintain security and access records; prevent fraud or misuse; manage corporate, legal, tax, accounting and governance requirements; and comply with law, court or regulatory requirements.
If required information is not provided, we may be unable to assess an enquiry, verify eligibility, grant access, progress an application or maintain a business relationship.
5. Disclosures
We may disclose personal information to MSVC personnel and related entities; legal, financial, tax, accounting, compliance and other professional advisers; issuers, trustees, registries, administrators, financiers and transaction counterparties; identity, security and due-diligence providers; cloud hosting, database, storage, email and communications providers; and regulators, courts, law-enforcement bodies or other persons where required or authorised by law.
Access to the Google Drive data room is granted only after MSVC approval and is sent to the verified Google account address supplied for that purpose.
6. Overseas processing and disclosure
Our service providers may store or process personal information outside Australia. The database used for investor access submissions is hosted in Switzerland. Google, website-hosting, email, security and other service providers may process information in the United States and other countries in which they or their subprocessors operate.
Countries and providers can change as services evolve. We take reasonable steps appropriate to the circumstances to manage service-provider access and security, but overseas recipients may be subject to different privacy laws.
7. Security and retention
We use access restrictions, role-based permissions, private storage, encrypted network transport, validation, logging and other administrative and technical safeguards appropriate to the information and context. No system is completely secure.
We retain personal information for as long as reasonably needed for the purposes described above, transaction and investor records, dispute management and legal, tax, accounting or regulatory obligations. We may then delete or de-identify it where lawful and reasonable.
8. Access and correction
You may ask to access personal information we hold about you or request correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact [email protected]. We may need to verify your identity and may refuse or limit a request where permitted by law, explaining the reason where required.
9. Privacy complaints
Send a privacy complaint to [email protected] with sufficient detail for us to investigate. We will acknowledge and assess the complaint and aim to respond within a reasonable period. If you are dissatisfied and the Privacy Act applies, you may contact the Office of the Australian Information Commissioner.
10. Website and communications
Our website and service providers may process technical information necessary to deliver pages, secure forms, prevent abuse and diagnose errors. We do not use the investor access form to make solely automated decisions about eligibility or data-room approval. Email and internet communications involve inherent security risks.
11. Changes to this policy
We may update this policy as our practices, service providers or legal obligations change. The effective date above identifies the current version.