Privacy Policy
01 | Introduction
Woodbridge Capital Pty Ltd (ABN 82 656 985 572) and its related entities (“Woodbridge“, “we“, “our” or “us“) are committed to protecting the privacy of individuals and managing Personal Information.
This policy explains how Woodbridge collects, holds, uses, discloses and protects Personal Information and how individuals may access and correct Personal Information held by us.
Woodbridge complies with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act), to the extent that the Privacy Act applies to the relevant Woodbridge entity and its activities.
02 | What is Personal Information and Why Do We Collect?
Personal Information
Personal Information is information or an opinion that identifies an individual, or an individual who is reasonably identifiable.
Depending on our relationship with you, we may collect and hold information including:
- name and contact details;
- date of birth and identification information;
- residential, postal and business addresses;
- financial, investment, tax and bank account information;
- information required for customer identification, verification and AML/CTF purposes;
- records of communications and dealings with us;
- employment and professional information, where relevant; and
- website and technical information, such as IP address, browser and device information.
We may collect Personal Information directly from you, through our website and systems, or from third parties where permitted by law. These third parties may include responsible entities, trustees, administrators, custodians, professional advisers and other service providers.
Sensitive Information
Sensitive Information includes information such as health information, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership and criminal records.
Woodbridge will only collect Sensitive Information where permitted by the Privacy Act and where reasonably necessary for our functions or activities.
03 | Collection & Use of Personal Information
Woodbridge may collect, hold, use and disclose Personal Information for purposes including:
- providing and administering our services;
- establishing and managing client and investor relationships;
- administering investments and funds;
- conducting customer identification, verification and AML/CTF checks;
- processing transactions and payments;
- communicating with clients, investors and other stakeholders;
- managing complaints and enquiries;
- complying with legal, regulatory and reporting obligations;
- managing our business, systems and service providers;
- recruitment and employment administration, where relevant; and
- providing information about our products and services where permitted by law.
We may also use or disclose Personal Information for a secondary purpose where permitted by the Privacy Act.
04 | Disclosure of Personal Information
Woodbridge may disclose Personal Information where reasonably necessary for the purposes described in this Policy or otherwise permitted or required by law.
Depending on the circumstances, Personal Information may be disclosed to:
- Woodbridge related entities;
- responsible entities, trustees, fund administrators and custodians;
- banks and payment providers;
- professional advisers, auditors and insurers;
- technology, cloud and other service providers;
- providers assisting with customer identification and AML/CTF requirements;
- regulators and government authorities; and
- persons authorised by you or acting on your behalf.
Overseas Disclosure
Some of our service providers may be located outside Australia or may store or process Personal Information overseas.
Where this occurs, Woodbridge will take reasonable steps to ensure that any overseas disclosure is permitted under the Privacy Act and that appropriate safeguards are in place where required.
Where practicable, Woodbridge will identify the relevant countries in which overseas recipients are likely to be located.
05 | Direct Marketing
Woodbridge may use Personal Information to provide information about our products, services, funds, investment opportunities, events and other matters that may be relevant to you, where permitted by law.
You may opt out of receiving direct marketing communications at any time by contacting us at:
- info@woodbridgecapital.com.au
Electronic marketing communications will include an appropriate unsubscribe mechanism where required by law.
06 | Security and Retention
Woodbridge takes reasonable steps to protect Personal Information from misuse, interference, loss and unauthorised access, modification or disclosure.
Personal Information may be held in electronic systems, cloud-based systems, physical records and other business records maintained by Woodbridge or its service providers.
We retain Personal Information for as long as reasonably necessary to fulfil the purposes for which it was collected and to meet legal, regulatory and business requirements.
When Personal Information is no longer required, Woodbridge will take reasonable steps to securely destroy or permanently de-identify it, subject to applicable retention requirements.
07 | Data Breaches
Woodbridge maintains processes for identifying, managing and responding to suspected or actual data breaches involving Personal Information.
Where a data breach constitutes an eligible data breach under the Privacy Act, Woodbridge will comply with the requirements of the Notifiable Data Breaches scheme, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.
08 | Access and Correction
You may request access to Personal Information Woodbridge holds about you, subject to exceptions under the Privacy Act.
You may also request that Personal Information be corrected if it is inaccurate, incomplete, out of date or misleading.
Requests should be made in writing to:
We may require identification before providing access to Personal Information.
We will not charge you for making an access or correction request. In limited circumstances, a reasonable fee may be charged for providing access to Personal Information, consistent with the Privacy Act.
If we refuse a request, we will provide reasons where required and explain any available avenues for review or complaint.
09 | Privacy Complaints and Enquiries
If you have a question or complaint about how Woodbridge handles Personal Information, please contact us at:
We will investigate privacy complaints and aim to respond within 30 days.
If you are not satisfied with our response, or your complaint has not been resolved within a reasonable period, you may contact the Office of the Australian Information Commissioner (OAIC).
10 | Automated Decision-Making
Woodbridge may use technology and computer systems to assist with business, administrative and compliance activities.
Where Woodbridge uses automated decision-making involving Personal Information that is subject to specific disclosure requirements under the Privacy Act, Woodbridge will provide the information required by law.
11 | Policy Updates
This Policy may be updated from time to time to reflect changes to Woodbridge’s business, information handling practices, applicable legislation or regulatory requirements.
The current version of this Policy will be available on the Woodbridge website.
