Privacy Policy and Credit Reporting Policy

Effective date: 10 September 2025

This document includes our Privacy Policy and Credit Reporting Policy, and explains how the Capital Prudential group (us, we or our):

• manages your personal information (being information or an opinion, whether true or not, about an individual who is identified or is reasonably identifiable), including how we collect, protect, use and share your personal information; and
• where applicable, manages credit-related personal information, which includes credit information, credit eligibility information and CP derived information (being personal information derived from credit information),

(together, the Policy).

The Privacy Policy applies to Capital Prudential Pty Ltd ACN 63 634 875 273 and the following entities within the Capital Prudential group that are bound by the Australia Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act):

• Capital Prudential Diversified Development Fund Pty Ltd
• Capital Prudential Manager Pty Ltd
• Capital Prudential Funds Management Pty Ltd.

The Credit Reporting Policy applies to entities in the Capital Prudential group that collect or manage credit related personal information, including Capital Prudential Manager Pty Ltd.

Privacy commitment

Your privacy is important to us. We are committed to protecting your privacy and we want to ensure that you have a clear understanding about the information we collect about you, how we use it and who we share it with.

This Policy applies to personal information collected in the course of our business, including when we provide you with services and products and when you use our website. It sets out how we collect personal information about you, how we use it and how we keep it secure.

We may change this Policy by publishing changes to it on our website. Please check our website regularly to ensure that you are aware of any changes to this Policy.

What information do we collect?

Personal information

The personal information we may collect about you can include:

• name, address, email address, date of birth, phone number(s);
• government related identifiers, such as your tax file number;
• bank account details or credit or debit card details;
• accounting and financial information; and
• details about you to confirm your identity.

We may also collect sensitive information about you if required to provide you with certain products or services. We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act.

You may refuse to provide us with your tax file number. However, if you do not provide us with your tax file number, there may be financial consequences, and we may not be able to provide you with products or services.

Credit-related personal information

If we are providing you with credit, entities in the Capital Prudential group may collect credit-related person information about you. The credit-related personal information these entities may collect about you can include:

• information relating to your identity, such as your name and date of birth;
• information about your credit worthiness contained in a credit report.

How we collect and hold your personal information

Personal information

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:

• when you visit our website;
• when you interact with us;
• when you submit application forms with us;
• when you participate in a phone call with us; and
• when you email or otherwise correspond with us or we deal with us as part of our business.

In certain cases, we may collect personal information from publicly available sources and third parties such as our related entities, suppliers and service providers in connection with providing our products and services, your advisers, banks, financial institutions and other financial product providers, credit reporting bodies, professional advisers and other public sources.

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

Credit-related personal information

We may collect credit-related personal information from you directly when you:

• complete an application to make an investment with us; and
• establish an account with us to make an investment.

We may also collect credit-related personal information from a range of sources including:

• from persons acting on your behalf;
• deriving information from the information you provide us, including your use of your account;
• from credit reporting bodies; and
• from the public domain.

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Why we handle your personal information

Personal information

We collect, hold and use your personal information to:

• offer and provide you with our products and services and customer support;
• manage and administer those products and services, including account keeping procedures, communicating with you, and to identify and control or minimise risks to our products or services;
• comply with our legal and regulatory requirements and meet our statutory obligations, including to verify your identity pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act (AML Act); and
• otherwise manage our business.

We will not use or disclose your personal information for any other purpose unless you have consented to that use or disclosure, or the relevant use or disclosure is otherwise permitted by the APPs or some other law. We will not use your tax file number to confirm your identity or to connect your personal information unless it is permitted by an applicable law.

We may share your personal information with our related entities or to third parties, such as our suppliers and service providers, payment systems operators, banks or other financial institutions, professional advisers, government agencies, regulatory bodies and law enforcement agencies. In the event that we sell part or all of our business, we may disclose your personal information to the new operator of that business.

Where your personal information is disclosed to a third party, that organisation will have its own privacy policy outlining the manner in which it handles personal information.

Credit-related personal information

We collect, hold and use your credit-related personal information to:

• assess your suitability for certain products and, if we accept your application, provide you with those products;
• assess your suitability for credit and, if approved for credit, facilitate provide you with such credit;
• collect payments that are overdue in relation to any credit provided to you; and
• comply with our legal and regulatory requirements and meet our statutory obligations, including to verify your identity pursuant to the AML Act,

and otherwise where pemitted by the Privacy Act, including to provide you with ongoing services as relevant.

Identity verification and anti-money laundering

The AML Act places a number of obligations on us to ensure that we are appropriately managing certain risks. Where we have obligations to collect, retain, use or disclose information under the AML Act, those may override any requirements under the APPs.

We are required to verify your identity under the AML Act before providing you with certain products and services. If we are assessing your credit worthiness, we may also undertake a credit check when verifying your identity. In order to verify your identity electronically, we will ask for the following personal information:

• name;
• address;
• date of birth; and
• details of, and in some cases copies of, your identification documents.

We may ask for additional information if we are also assessing your credit worthiness. You acknowledge that your personal information may be passed on to external organisations including government agencies and credit reporting bodies (CRBs) in order to facilitate the identity verification process. Your personal information may be disclosed to our agents who assist with the electronic identity verification  process. The CRB or our agents will then confirm whether the personal information provided to them to verify your identity is a full or partial match with information held on the relevant credit information files.

Where we do engage with CRBs as part of verifying your identity, we do so in the manner permitted by section 35A of the AML Act. The use of your personal information solely for electronic identity verification does not constitute a credit check or impact your credit standing. However, where we are also assessing your credit worthiness, electronic identity verification may be undertaken alongside a credit check and may impact your credit standing.

Your details will also be submitted to the Australian Government’s Documents Verification Service (DVS). The DVS is a national online system that allows organisations to compare an individual’s identifying information with a government record. More information about the DVS is available on their website.

You do not have to agree to electronic verification. You can choose for your identity to be verified in person, please just let us know if that is your preference.

We may use personal information to conduct monitoring activities as required by the AML Act, and we may disclose personal information to AUSTRAC where the AML Act requires or authorises us to do so.

Direct marketing

Personal information

From time to time, we may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you. Provided that you have not unsubscribed or otherwise opted out, we may use your information for direct marketing:

• where you have agreed to receive direct marketing from us; or
• where you have engaged with us directly, and we believe that you would reasonably expect to receive direct marketing from us.

We may utilise the services of third parties to assist us with undertaking our direct marketing activities. We will not otherwise disclose your personal information to third parties for marketing purposes without your consent.

You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by contacting our Privacy Officer.

Note that if you opt-out of direct marketing messages from us, we may still communicate with you from time to time for other purposes, including where we:

• respond to any correspondence you send us;
• provide you with statements or reports in relation to your investments;
• engage with our contractors and suppliers; or
• are legally required to provide you with notice of certain matters.

Credit-related personal information

We do not currently use your credit-related personal information for the purpose of undertaking direct marketing.

If we propose to undertake direct marketing using credit-related personal information in the future, we will only do so in accordance with the requirements of the Privacy Act. If you have previously specified that you no longer wish to receive commercial messages from us, then we will not send you direct marketing in the future (including using your credit-related personal information).

How we hold your information to keep it safe

We hold your personal information, including credit-related personal information, in electronic form or in a hard copy format.

We take reasonable steps to protect your information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information.

To protect your personal information, we may:

• impose confidentiality requirements on our employees and train them about how to keep your personal information safe and secure;
• have policies and procedures in relation to document storage security and security measures to govern access to systems;
• implement firewalls and virus scanning tools to stop viruses and unauthorised access to our systems; and
• destroy and de-identify data when it is no longer required for a valid purpose or required to be kept by law in accordance with our policies and procedures and legislative requirements.

However, we cannot guarantee the security of your information.

Automated decision making

We may use computer programs in our business to assist us to make decisions about you, including for verification purposes. The kinds of personal information we may use include your name, address, email address, date of birth and phone number.

At this time, we do not use computer programs to fully automate decisions.

We may use computer programs to directly assist us to cross-checking identity documents provided by potential new investors against databases. However, these programs will not be used to substantially and directly assist us to make a decision about your identity and are not expected to significantly affect your rights or interests.

Sharing (disclosing) your information outside Australia

We share (disclose) personal information outside of Australia to service providers located outside of Australia, including the USA and UK. We may also share your credit-related personal information outside of Australia to the USA and UK.

We take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.

As at the date of this Policy, we are not likely to disclose personal information to other overseas recipients. If in future we do propose to disclose personal information overseas, we will do so in compliance with the requirements of the Privacy Act. We will, where practicable, advise you of the countries in which any overseas recipients are likely to be located.

By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.

If you do not want us to disclose your information to overseas recipients, please let us know.

Using our website and cookies

We collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

Rights to access your information or seek correction

You can access the personal information and credit-related personal information we hold about you by contacting our Privacy Officer using the information below. Sometimes, we may not be able to provide you with access to all of your information and, where this is the case, we will provide you with a written notice stating our reasons for refusing access. We may also need to verify your identity when you request your information. We will not charge you for making a request to access personal information we hold about you but we may seek to recover from you reasonable costs incurred for providing you with access to such personal information. If you think that any information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected. We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time and otherwise in accordance with any timeframes specified in the Privacy Act.

Right to remain anonymous

You can choose not to provide us with personal information. However, if you do this, we may not be able to provide you with products or services, especially where we are required to take steps to confirm your identity under the AML Act.

If you do not provide us with credit-related person information, we may not be able to assess any application you make for credit, or otherwise may be unable to provide you with certain products or services.

How to complain

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.

If you are not satisfied with how we have dealt with your complaint you can contact the Office of the Australian Information Commissioner using any of the following details:

GPO Box 5288
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
www.oaic.gov.au

Contact Us

For further information about our Privacy Policy, Credit Reporting Policy or privacy practices, to access or correct your information, or make a complaint, please contact us using the details set out below:

Privacy Officer
T: 0405 227 368
E: shirley.shu@capitalprudential.com.au
A: Level 16, 25 Bligh Street, Sydney NSW 2000