Peak Equities PTY LTD
ACN 165 827 574 AFS Licence No: 458013
Effective date: 30 June, 2026
Our Commitment to Privacy
Peak Equities Pty Ltd and, where relevant, its related entities (together Peak, we, us or our) are committed to protecting your privacy and handling your personal information responsibly.
This Privacy Policy explains how we collect, hold, use and disclose personal information and how you may access or correct your personal information or make a privacy-related complaint.
We handle personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), and other applicable laws and regulatory requirements.
This Privacy Policy applies when you invest or seek to invest through Peak, use our products or services, communicate or otherwise deal with us, or use our website.
We may amend this Privacy Policy from time to time to reflect changes to our practices, technology or legal and regulatory obligations. The current version will be published on our website.
- What is Personal Information?
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true and whether or not it is recorded in a material form.
Some types of personal information are treated as sensitive information under the Privacy Act and are subject to additional protections. This may include information about a person’s racial or ethnic origin, political opinions or associations, religious beliefs, memberships and certain health or biometric information.
We will only collect sensitive information where it is reasonably necessary for our functions or activities and we have your consent, or where collection is otherwise authorised or required by law.
- What Personal Information do we collect and hold?
The types of personal information we may collect and hold depend on the nature of your relationship with Peak and may include:
• your name, residential and postal address, email address, telephone number, date of birth and other contact details;
• identity information and government-issued identifiers, including details contained in passports, driver licences or other identification documents;
• tax file number, Australian Business Number, Australian Company Number and other taxation information where relevant;
• bank account, payment and financial details;
• information relating to your financial circumstances, investment experience, investment preferences, risk profile and eligibility to invest in particular products or investment opportunities;
• information relating to the source of your funds or wealth where required for customer due diligence;
• details about companies, trusts, partnerships or other entities through which you invest, including information about directors, trustees, beneficial owners, beneficiaries, controllers and authorised representatives;
• information necessary to establish whether you, a beneficial owner, representative or other relevant person is a politically exposed person, is subject to sanctions or presents other money laundering, terrorism financing or proliferation financing risks;
• records relating to your investments, applications, transactions, distributions and correspondence with Peak;
• information about your professional advisers or representatives;
• records of communications with us, including emails, telephone calls, meetings and other correspondence;
• information collected when you use our website, including IP address, device and browser information, website usage information and cookie data;
• information relating to prospective and current employees, contractors and service providers; and
• any other information that you provide to us or that is reasonably necessary for us to provide our products or services or carry out our functions and activities.We do not collect personal information merely because it may be useful in the future. We seek to limit collection to information that is reasonably necessary for our activities or that we are required or authorised to collect by law.
Tax file numbers
Tax file number information is subject to additional protections under the Privacy Act and the Privacy (Tax File Number) Rule 2015. We will only collect, use, disclose and retain tax file number information where permitted by law.
- Anti-money laundering and customer due diligence
As part of our legal and regulatory obligations, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and associated rules, we may be required to undertake customer due diligence and ongoing monitoring.
This may involve collecting and verifying information about:
• your identity;
• beneficial ownership and control of companies, trusts and other entities;
• persons acting on your behalf;
• the source of funds or source of wealth;
• whether you or another relevant person is a politically exposed person (PEP) or a family member or close associate of a PEP;
• sanctions or other regulatory screening information; and
• other information reasonably required to assess and manage money laundering, terrorism financing or proliferation financing risk.We may obtain this information directly from you or through public registers, government sources, professional advisers, identity verification providers, sanctions and PEP screening databases and other third-party information sources.
Where the AML/CTF Act or another law requires or authorises us to collect, use, retain or disclose personal information, we may do so without obtaining separate consent.
- How do we collect personal information?
Where reasonable and practicable, we collect personal information directly from you. We may collect information when you or a person authorised by you:
• complete an application, identification, investor or other form;
• invest or seek to invest in an investment, trust, syndicate or other product offered or administered by Peak;
• request information about Peak or an investment opportunity;
• participate in a meeting or telephone or video call with us;
• communicate with us by email, telephone, post, through our website or in person;
• update your contact, banking, taxation or investment details;
• respond to a survey or provide feedback;
• subscribe to communications or change your communication preferences;
• visit or interact with our website; or
• otherwise deal with us.We may also collect personal information from third parties, including:
• your authorised representatives and professional advisers;
• our related entities;
• fund administrators, trustees, custodians and other investment service providers;
• banks and financial institutions;
• identity verification, AML/CTF, PEP and sanctions screening providers;
• government departments, regulators and public registers;
• superannuation funds;
• accountants, lawyers, auditors and other professional advisers;
• service providers and business partners; and
• publicly available sources.Unsolicited information
We may occasionally receive personal information that we did not request. Where this occurs, we will determine whether we could lawfully have collected that information. If not, and where permitted by law, we will take reasonable steps to destroy or de-identify it.
- Why do we collect, hold, use and disclose personal information?
We collect, hold, use and disclose personal information where reasonably necessary for our business activities, including:
• assessing and processing applications for investments;
• establishing and administering your investment;
• maintaining investor registers and records;
• processing distributions, redemptions and other transactions;
• preparing investor communications, reports, taxation information and other documentation;
• determining eligibility to participate in investment opportunities or receive particular financial products or services;
• providing information, products, services and support that you request;
• communicating with you about your existing investments;
• advising you about new investment opportunities, developments, events, products or services that may be relevant to you;
• conducting customer due diligence and complying with AML/CTF, sanctions and related obligations;
• verifying your identity and preventing or detecting fraud, suspicious activity or other unlawful conduct;
• understanding and managing legal, financial, operational, cyber security and other risks;
• operating, maintaining, protecting and improving our website, systems and services;
• conducting research and obtaining feedback to improve our products and services;
• managing our relationships with employees, contractors, advisers and service providers;
• establishing, exercising or defending legal rights and claims;
• managing complaints and disputes;
• complying with our obligations under applicable laws, including the Privacy Act, Corporations Act 2001 (Cth), AML/CTF Act, taxation laws and other laws and regulatory requirements applicable to our business;
• responding to requests from regulators, government agencies, law enforcement bodies, courts and tribunals; and
• any other purpose disclosed to you at the time the information is collected or for which you have consented.We may also use or disclose personal information for a secondary purpose where permitted by the Privacy Act, including where that purpose is related to the primary purpose of collection and you would reasonably expect us to use or disclose the information for that purpose.
- What happens if you do not provide your information?
You may choose not to provide personal information requested by us. However, in many circumstances we require particular information to comply with our legal obligations or provide our services.
If you do not provide information that we reasonably require, we may be unable to:
• process an application;
• accept or maintain your investment;
• make distributions or process transactions;
• verify your identity;
• satisfy our AML/CTF or other regulatory obligations; or
• provide particular information, products or services to you. - Anonymity and pseudonyms
Where practicable and lawful, you may interact with us anonymously or using a pseudonym. This will generally not be practicable where we need to identify you in order to establish or administer an investment, enter into a contract with you, verify your identity or comply with legal or regulatory requirements.
- Anonymity and pseudonyms
8.1 We do not currently disclose your Personal Information outside of Australia. In future we may choose to disclose your Personal Information outside of Australia to an entity in a foreign country and if practical will provide you with details of these countries when this occurs.
It is possible that such entity may be subject to foreign laws that do not provide the same level of protection of Personal Information as in Australia. We will take steps to ensure that these overseas entities are obliged to protect the privacy and security of your Personal Information and use it only for the purpose for which it is disclosed.
- Direct marketing
We may use your personal information to communicate with you about Peak, our activities, investment opportunities, events, products or services that we reasonably believe may be of interest to you. We will only undertake direct marketing where permitted by applicable law.
You may opt out of receiving marketing communications at any time by:
• using the unsubscribe facility contained in an electronic communication; or
• contacting us using the details set out at the end of this Privacy Policy.Opting out of marketing communications will not prevent us from sending you communications that are necessary to administer an existing investment or comply with our legal obligations.We do not sell your personal information to third parties for their own marketing purposes.
- Who do we disclose personal information to?
We may disclose personal information where reasonably necessary for the purposes described in this Privacy Policy.
Recipients may include:
• Peak’s related entities and the directors, officers, employees and contractors of those entities;
• trustees, responsible entities, custodians, fund administrators, registry providers and other entities involved in establishing or administering investments;
• banks, financiers and other financial institutions;
• accountants, auditors, lawyers, tax advisers, consultants and other professional advisers;
• property managers, valuers, insurers and other parties involved in investments or assets managed by Peak;
• information technology, cloud computing, cyber security, data storage, communications and software providers;
• identity verification, AML/CTF, PEP and sanctions screening providers;
• mail, document management and other administrative service providers;
• your financial adviser, accountant, lawyer or another person authorised by you;
• government agencies, taxation authorities, regulators, law enforcement agencies, courts and tribunals;
• parties involved in an actual or proposed sale, restructuring, merger or transfer of all or part of Peak’s business or assets; and
• other persons where required, authorised or permitted by law.Where we engage service providers to handle personal information on our behalf, we take reasonable steps appropriate to the circumstances to ensure that personal information is handled securely and consistently with applicable privacy requirements.
We may also use or disclose information that has been appropriately de-identified or aggregated so that individuals are not reasonably identifiable.
- Disclosure and storage outside Australia
At the date of this Privacy Policy, Peak does not routinely disclose personal information to overseas recipients as part of the administration of its investments.
Some technology, cloud, software, identity verification or other service providers used by Peak may, however, operate infrastructure or provide support from locations outside Australia.
Depending on the arrangements with those providers, the handling of information may constitute an overseas disclosure for the purposes of the Privacy Act.
Where we disclose personal information to an overseas recipient, we will comply with the requirements of the Privacy Act, including taking reasonable steps, where required, to ensure that the recipient handles the information consistently with the APPs.
Where practicable and required, we will identify the countries in which overseas recipients are likely to be located through this Privacy Policy, an applicable collection notice or other communication.
The location of technology and service providers may change from time to time. You may contact our Privacy Officer if you would like further information about the countries in which your personal information may be handled.
- Our website, cookies and analytics
When you visit our website, we or our service providers may collect information about your use of the website.
This may include:
• your IP address;
• browser and device information;
• the date, time and duration of your visit;
• pages viewed;
• links followed;
• referring websites; and
• other website usage and diagnostic information.We use this information to operate, secure, maintain and improve our website and understand how it is used.
Cookies and similar technologiesOur website may use cookies and similar technologies. Cookies are small data files stored on your computer, mobile device or browser that can enable a website to recognise your device, remember preferences and understand website activity. You may configure your browser to reject or restrict cookies. Some parts of our website may not operate as intended if cookies are disabled.
We may also use analytics or similar technologies to understand website usage. We do not seek to use ordinary website analytics information to personally identify you unless this is necessary for security, fraud prevention, legal compliance or another permitted purpose.
- Links to other websites
Our website may contain links to websites operated by third parties.
We are not responsible for the privacy practices, security or content of third-party websites. You should review the privacy policy of a third-party website before providing personal information through it. - How do we protect your personal information?
We take reasonable steps to protect personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.
Our security arrangements include technical and organisational measures appropriate to the nature and sensitivity of the information we hold and the risks associated with its handling.
These measures may include:
• restricting access to information to personnel and service providers who require it;
• access controls and authentication measures;
• appropriate cyber security, malware protection and network security measures;
• secure storage and transmission practices;
• confidentiality obligations for employees and contractors;
• staff privacy and information-security awareness;
• physical security measures;
• management of third-party service-provider risks;
• data back-up and recovery processes; and
• processes for the secure destruction or de-identification of information that is no longer required.No method of electronic transmission or storage is completely secure. Accordingly, while we take reasonable steps to protect personal information, we cannot guarantee absolute security.
- Data breaches
We maintain processes for responding to suspected or actual data breaches. Where a data breach involving personal information is likely to result in serious harm to an individual and the requirements of the Notifiable Data Breaches scheme under the Privacy Act are satisfied, we will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as required by law.
We will also take reasonable steps to contain, investigate and remediate a data breach and reduce the risk of similar incidents occurring in the future.
- How long do we keep your personal information?
We retain personal information only for as long as reasonably necessary for the purposes for which it may lawfully be used or disclosed, including to:
• administer investments;
• maintain appropriate business and transaction records;
• meet taxation, corporations, financial services and AML/CTF record-keeping requirements;
• manage legal claims, complaints and risks; and
• satisfy other legal and regulatory obligations.When personal information is no longer required for a permitted purpose and we are not required by law or a court or tribunal order to retain it, we will take reasonable steps to destroy it or ensure that it is de-identified.
Identification documents
We may obtain copies of identification documents for identity verification or customer due diligence. We will not retain complete copies of identification documents for longer than reasonably necessary or otherwise permitted or required by law.
Where we no longer require a copy of an identification document, we will take reasonable steps to securely destroy or de-identify it while retaining any information or verification records that we are required or permitted to retain.
- Accuracy and correction of personal information
We take reasonable steps to ensure that personal information we collect, use and disclose is accurate, up to date, complete and relevant.
Please contact us if your personal information changes or if you believe that information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading.
We will take reasonable steps to correct personal information where required by the Privacy Act.
- Access to your personal information
You may request access to personal information that we hold about you. We may need to verify your identity before providing access.
There may be circumstances in which we are permitted or required by law to refuse access to some or all of the information requested.If we refuse an access request, we will generally provide written reasons for that decision and information about available complaint mechanisms, unless it would be unreasonable or unlawful to do so.
Requests for access may be made using the contact details at the end of this Privacy Policy. - Credit information and credit reporting
Peak does not currently disclose consumer credit information to credit reporting bodies for the purpose of obtaining consumer credit reports or conducting consumer credit checks.
If our activities change so that the credit-reporting provisions of Part IIIA of the Privacy Act apply to us, we will comply with those requirements and update our privacy disclosures as necessary.
- Automated decision-making
Peak does not currently use personal information in automated decision-making systems to make decisions that could reasonably be expected to significantly affect an individual’s rights or interests without appropriate human involvement.
If we introduce systems of that kind, we will update this Privacy Policy to describe their use and the types of personal information involved as required by the Privacy Act.
- Privacy complaints
If you believe that we have interfered with your privacy, breached the APPs or otherwise handled your personal information inconsistently with this Privacy Policy, you may make a complaint to our Privacy Officer.
Please provide sufficient details for us to understand and investigate your complaint.
We will:
• acknowledge your complaint;
• investigate it appropriately;
• contact you if we require further information; and
• provide a response within a reasonable period.We will endeavour to resolve privacy complaints directly with you.
If you are not satisfied with our response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner.Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
Website: www.oaic.gov.au - Contact us
For further information about this Privacy Policy or our privacy practices, or to request access to or correction of your personal information or make a complaint, please contact:
Privacy Officer
Peak Equities Pty Ltd
Telephone: 03 9863 8380
Email: info@peakequities.com.au
Address: Suite 401, 390 Malvern Road, Prahran VIC 3181 - Changes to this Privacy Policy
We may review and update this Privacy Policy from time to time, including to reflect changes to our business practices, technology and legal or regulatory requirements.
The most current version will be published on our website and will apply to the personal information we hold from the date specified in the updated policy.
