FundPro Privacy Policy
Version – August 2026
This Privacy Policy is issued by Bolt Capital Pty Ltd (ABN 37 636 202 223) and Venus Capital Pty Ltd (ABN 25 169 312 510), trading as FundPro (“we”, “us”, “our”). It applies to Personal Information handled by those entities and their related bodies corporate. We are committed to providing quality services to you and this policy outlines our ongoing obligations in respect of how we manage our clients and their representative’s Personal Information. Where we handle Personal Information on behalf of a client – for example, information about that client's own investors or customers – we do so under our agreement with that client, and the client's own privacy policy governs its relationship with those individuals.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone numbers, identification documents (such as driver's licences and passports), background checks (such as insolvency and police checks), professional references, curriculum vitae, insurance details and any other information necessary to provide our services.
This Personal Information is obtained in many ways including interviews, correspondence, by telephone, by email, via our website, from your website, from media and publications, from other publicly available sources, from cookies and from third parties. Our website may contain links to third party websites. We are not responsible for the content or the privacy practices of those websites, and we encourage you to review their privacy policies before providing them with your Personal Information.
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
We will only collect Sensitive Information about you where you have consented to the collection and the information is reasonably necessary for one or more of our functions or activities, or where the collection is otherwise required or authorised by law. Where we conduct background checks that may disclose Sensitive Information, including criminal record checks, we will obtain your express consent before doing so.
Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances, including to:
- our related bodies corporate;
- service providers who perform functions on our behalf, including fund administrators, custodians, unit registry providers, identity verification and screening providers, auditors, legal and other professional advisers, and information technology and data hosting providers;
- regulators and government agencies, including AUSTRAC, ASIC and the Australian Taxation Office, where required or authorised by law;
- third parties where you consent to the use or disclosure; and
- any other person where the disclosure is required or authorised by law.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
When your Personal Information is no longer needed for any purpose for which it may be used or disclosed, we will take reasonable steps to destroy it or permanently de-identify it, unless we are required by Australian law, or by a court or tribunal order, to retain it.
Where we are required to retain records – for example under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or the Corporations Act 2001 (Cth) – we retain only the information necessary to meet that obligation, for the period required (generally 7 years from the end of our relationship with you), and destroy it at the end of that period.
Identification documents collected for other purposes, including our internal client due diligence, are destroyed once that process is complete. We retain only the information extracted from those documents and a record that the verification was carried out.
Access to your Personal Information
You may request access to the Personal Information we hold about you, and ask us to correct it. Please make your request in writing to our Privacy Officer at the address below. We will respond within a reasonable period and, in any event, within 30 days of receiving your request.
Access is subject to the exceptions permitted under the Privacy Act. If we refuse your request, we will give you written reasons for the refusal and explain how you may complain about that decision.
We do not charge a fee for making a request. We may charge a reasonable fee for giving access, and we will tell you the amount before we proceed.
In order to protect your Personal Information we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Data Breaches
Where we have reasonable grounds to believe that an eligible data breach has occurred – that is, unauthorised access to, unauthorised disclosure of, or loss of Personal Information that is likely to result in serious harm to any individual – we will assess the incident promptly and, where required under Part IIIC of the Privacy Act, notify the affected individuals and the Office of the Australian Information Commissioner as soon as practicable.
Policy Updates
We may update this Policy from time to time. The current version is available at fundpro.com.au. Where a change is material, we will take reasonable steps to notify you.
Privacy Policy Complaints and Enquiries
If you have a query or complaint about how we have handled your Personal Information, please contact us at the details below.
We will acknowledge your complaint within 5 business days of receipt and aim to provide a substantive response within 30 days. If we need longer, we will tell you why and when you can expect a response.
If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au or on 1300 363 992.
Contact Details
Bolt Capital Pty Ltd (ABN 37 636 202 223)
Venus Capital Pty Ltd (ABN 25 169 312 510)
Westfield Tower 2
Suite 17.04, Level 17
101 Grafton Street
Bondi Junction NSW 2022
Email: info@fundpro.com.au