Privacy Policy

This Privacy Policy details how we, Anchorage Capital Partners and the Anchorage Capital Partners Services Trust (together, "Anchorage"), handle your personal information.

How we collect personal information
In the course of providing our products and services, Anchorage may collect personal information in a number of ways, including:
  • directly from you;
  • from publicly available sources; and
  • by analysing our records of your use of Anchorage's services and website.

Anchorage may also collect your personal information when required to do so by law.

The types of personal information we collect and hold
Anchorage collects personal information in the ordinary course of our business. The personal information collected, held, used and disclosed will depend on the nature of your relationship with us. For example:
  • Investors - Name, address, personal and business contact details, personal financial, banking and tax information (including tax file numbers) and investor adviser details;
  • Advisers and Service Providers - Name, address, personal and business contact details;
  • Employment Applicants for both Anchorage and Investee Companies – Name, address, personal and business contact details, nationality and country of birth, curriculum vitaes including professional qualifications, membership of any professional association, education, prior employment, history, references and any other information that the applicant may provide.
Storage and security of your personal information

We store personal information in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers.

The security of your personal information is of paramount importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure.

These steps include:
  • Restricting access to information on our databases on a need to know basis;
  • Ensuring all staff are aware that they are not to reveal or share personal passwords;
  • Ensuring where sensitive information is stored in hard copy files that these files are stored in lockable filing cabinets. Access to these records is restricted to staff on a need to know basis;
  • Implementing physical security measures at our premises to prevent unauthorised access;
  • Implementing security systems, policies and procedures designed to protect personal information storage on our computer networks;
  • Implementing human resources policies and procedures, such as email and internet usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information; and
  • Making enquiries to ensure that any overseas third parties have processes in place to protect personal information from unauthorised use and disclosure.

Personal information we hold that is no longer needed, or required to be retained by any other laws, is destroyed in secure manner, deleted or de-identified as appropriate.

Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies.

How do we use your personal information?
Anchorage collects personal information in the ordinary course of business to provide and develop our private equity funds management and advisory services for investors in our funds. Anchorage may use your personal information to:
  • verify your identity;
  • facilitate the provision of our services to you or your services to Anchorage;
  • identify prospective employees and assess suitability for employment;
  • conduct marketing and promotional activities;
  • comply with legal obligations and / or governance requirements including requirements for Australian Financial Services Licensees and in relation to anti-money laundering and know-your-customer; and
  • do things related to the purposes described above which would be reasonably expected by you.

Anchorage will not use your personal information for purposes other than those described above unless you have consented to it or Anchorage is required to do so by law.

When we disclose your personal information
Anchorage may disclose your personal information to third parties to assist in providing its services. Third parties that Anchorage may disclose your personal information to include:
  • Anchorage's business partners;
  • persons engaged in providing Anchorage with professional, financial, business, technology and corporate services when reasonably required;
  • foreign and domestic governmental agencies and regulators in relation to compliance, anti-money laundering or law enforcement, including Foreign Investment Review Board and the Australian Taxation Office; and
  • others in accordance with your express consent or otherwise authorised by you.

Anchorage does not sell any personal information to any third party nor does it share or disclose your personal information to third parties to be used for a separate and unrelated purpose to the purpose for which the information was collected.

Disclosure of your personal information to overseas recipients

In relation to personal contact information (such as address, personal and business contact details), Anchorage's IT and data service providers may send your personal information overseas for the purposes of data storage and hosted contact management systems. Currently this is limited to the United States of America.

Anchorage will only disclose your personal information to overseas recipients with your consent or if Anchorage is authorised or required to do so by law.

How we ensure the quality of your personal information

We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date. On an ongoing basis we maintain and update personal information when we are advised by individuals or when we become aware through other means that their personal information has changed.

Please contact us if any of the details you have provided change. You should also contact us if you believe that the information we have about you is not accurate, complete or up-to-date.

How to gain access to your personal information we hold

You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us.

If we do not agree to provide you with access or to amend your personal information as requested you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.

Privacy complaints

If you wish to make a complaint about a breach by us of the Australian Privacy Principles, you may do so by providing your written complaint by email, letter, facsimile or by personal delivery to any one of our contact details as noted below. You may also make a complaint verbally.

We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we make seek further information from you in order to provide a full and complete response.

Your complaint may also be taken to the Office of the Australian Information Commissioner.

How to contact us
You can contact us about this Privacy Policy or about your personal information by:
Anchorage Capital Partners
Level 39, 259 George Street
Sydney NSW 2000 Australia
or by facsimile at +61 2 8259 7778.

If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.

Changes to our privacy and information handling practices

This Privacy Policy is subject to change at any time. Please check our Privacy Policy on our website (www.anchoragecapital.com.au) regularly for any changes.