3.1  Investors and Prospective Investors

Where you are an individual investor, or an officer, director, beneficial owner, or authorised representative of an investing entity, we or our services provider(s) may collect:

• Full legal name, date of birth, country of birth, and nationality
• Residential and postal address, email address, and telephone number
• Identity verification documents (such as a passport, driver's licence, or other government-issued identification)
• Tax File Number (TFN), Australian Business Number (ABN), and tax residency status
• FATCA and CRS classification and foreign tax identification numbers where applicable
• Bank account details and financial institution information
• Source of funds and source of wealth information and supporting documentation
• Investment experience, financial position, and wholesale investor status (including supporting accountant or qualified adviser certificates under section 708 of the Corporations Act 2001 (Cth))
• Beneficial ownership information, including information about trusts, companies, and their controllers
• Politically exposed person (PEP) and sanctions screening results
• Records of communications and instructions relating to your investment
• Distribution reinvestment elections, tax elections, and other investor preferences

3.2  Website and Portal Visitors

When you visit our website or investor portal, we may automatically collect:

• IP address, browser type and version, device type and operating system
• Pages visited, time and duration of visit, and referral URL
• Cookies and similar tracking data (see Section 10 for further detail)
• Information you submit via contact forms, enquiry submissions, or download requests

3.3  Counterparties, Service Providers, and Other Third Parties

In connection with our investment activities, we may collect personal information about officers, directors, and beneficial owners of counterparties, sellers of securities, and employees or representatives of service providers and professional advisers. This information is collected to the extent necessary to conduct our investment process, comply with our AML/CTF obligations, and manage our contractual relationships.

3.4  Information We Do Not Collect

We do not intentionally collect sensitive information such as health information, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, or criminal record information, unless this is directly relevant to a specific legal obligation (such as PEP screening) or you have given your consent in connection with a specific purpose. We do not knowingly collect personal information from individuals under 18 years of age.

4.1  Directly From You

Most of the personal information we hold is collected directly from you when you:

• Complete an investor application or subscription form via our investor portal
• Provide identification documents for AML/KYC verification
• Contact us by email, telephone, or in person
• Submit enquiries via our website
• Enter into agreements with us or provide instructions regarding your investment
• Respond to surveys or communications from us

4.2  From Third Parties

We may also collect personal information about you from third parties, including:

• Identity verification and electronic document verification service providers engaged by us or our fund administrator
• Credit reporting bodies and sanctions and PEP screening databases
• The Australian Transaction Reports and Analysis Centre (AUSTRAC) and other regulatory databases
• The Australian Taxation Office (ATO) and related government registers
• Your professional advisers, including accountants, financial advisers, and lawyers
• Our fund administration platform provider, which collects personal information on our behalf through the investor portal
• Publicly available sources, including company registers, ASIC records, and media

4.3  Automatically

Some personal information is collected automatically when you use our website or investor portal through cookies, web analytics tools, and similar technologies. Please see Section 10 for further information.If we collect personal information about you from a third party, we will take reasonable steps to notify you of that collection as soon as practicable, unless doing so would be impracticable or is not required under the APPs.

5.1  Fund Management and Investment Operations

• Processing investor applications, subscriptions, and redemptions
• Maintaining the unit registry for each Fund
• Calculating and issuing capital call notices and distribution payments
• Providing investor statements, tax statements, and other fund reports
• Managing the investment lifecycle, including deal sourcing, due diligence, and exit management
• Communicating with investors about fund performance, material events, and investor meetings

5.2  Legal and Regulatory Compliance

• Verifying investor identity and conducting customer due diligence (CDD) and enhanced due diligence (EDD) under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
• Screening against PEP lists, sanctions lists, and adverse media databases
• Confirming wholesale investor status under section 708 of the Corporations Act 2001 (Cth)
• Collecting and using TFNs, ABNs, and foreign tax identification numbers for the purpose of meeting withholding tax obligations and making required reports to the ATO
• Meeting FATCA and CRS reporting obligations to the ATO
• Complying with ASIC reporting and disclosure obligations applicable to registered managed investment schemes
• Responding to lawful requests from regulatory authorities, law enforcement, and courts

5.3  Risk Management and Compliance Monitoring

• Assessing and monitoring counterparty and investor risk
• Detecting, investigating, and preventing fraud, financial crime, and other unlawful activity
• Maintaining records required by law, including records required under the AML/CTF Act and the Corporations Act

5.4  Investor and Client Relationship Management

• Communicating with you about your investment, including sending periodic reports, distribution notices, tax statements, and material fund updates
• Responding to your enquiries, instructions, and complaints
• Managing our relationship with professional advisers and authorised representatives acting on your behalf

5.5  Investor and Client Relationship Management

We may use your contact details to send you information about investment opportunities, fund updates, and market insights that we consider may be of interest to you, where you are a wholesale investor and we have a legitimate basis for doing so, or where you have consented to receive such communications. You may opt out of receiving marketing communications at any time by contacting us at notices@deltagcapital.com or by using the unsubscribe function in any marketing email. We do not sell personal information to third parties for marketing purposes.

5.6  Website and Platform Improvement

• Analysing website and portal usage to improve the user experience and functionality of our digital services
• Administering and maintaining the security of our technology platforms

TFN use: We use TFNs solely for the purpose of meeting our tax obligations in connection with our Funds, including calculating and withholding tax on distributions at the applicable rate and making required reports to the ATO. We will not use TFNs for any other purpose, and will not disclose TFNs to any party other than the ATO and our authorised tax agents, except as required by law.

6.1  Fund Service Providers

• Fund administration platform providers engaged to operate the investor portal, unit registry, capital call and distribution processing, AML/KYC services, and investor reporting
• The trustee or responsible entity of each Fund
• Identity verification and electronic document verification service providers engaged in connection with investor onboarding
• The custodian or sub-custodian engaged to hold Fund assets and operate Fund bank accounts
• Operations and middle office partners providing compliance monitoring, AML/CTF programme oversight, and investor services

6.2  Legal and Professional Advisers

• Legal counsel engaged in connection with fund establishment, investment transactions, and regulatory matters
• The Fund's auditor
• Tax advisers engaged in connection with the Fund's tax obligations

6.3  Regulatory and Government Authorities

• AUSTRAC — as required under the AML/CTF Act, including suspicious matter reports and annual compliance reports
• The ATO — in connection with withholding tax, FATCA, CRS, TFN reporting, and annual investment income reports
• ASIC — in connection with our registered managed investment scheme obligations
• Other regulatory authorities, courts, or law enforcement agencies where required or authorised by law

6.4  Transaction Counterparties

In connection with secondary market investment transactions, wemay need to disclose limited investor information (such as fund name andinvestor type) to counterparties, their legal counsel, or issuing companies asrequired to effect a transaction or obtain necessary consents. We take steps tominimise the personal information disclosed in this context and to ensure it issubject to appropriate confidentiality protections.

6.5  Business Transfers

If Delta-G Capital is involved in a merger, acquisition, restructure, or sale of all or part of its business, personal information held about investors and clients may be disclosed to the relevant counterparty as part of the transaction, subject to appropriate confidentiality arrangements and to the extent permitted by the APPs.

8.1  Notifiable Data Breaches

We are subject to the Notifiable Data Breaches scheme under the Privacy Act. If we become aware of an eligible data breach - being an unauthorised access to, or disclosure of, personal information that is likely to result in serious harm to any affected individual - we will notify the affected individual(s) and the Office of the Australian Information Commissioner (OAIC) as soon as practicable.

11.1  Access

You have the right to request access to personal information we hold about you. We will provide access within 30 days of a valid request unless we are permitted or required to refuse access under the Privacy Act. We will not charge a fee for making an access request, but we may charge a reasonable fee for providing access where this involves significant time or resources.

11.2  Correction

If you believe that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, you may request that we correct it. We will take reasonable steps to correct the information within 30 days and, where we are unable or unwilling to do so, we will explain our reasons in writing.

11.3  TFN Requests

Consistent with the TFN Guidelines, you may request access to TFN information we hold about you at any time. TFN information will not be disclosed to any party other than you, the ATO, and our authorised tax agents without your consent, unless required by law.

11.4  Withdrawal of Consent and Marketing Opt-Out

Where we rely on your consent to use personal information for marketing purposes, you may withdraw that consent at any time by emailing notices@deltagcapital.com or using the unsubscribe link in any marketing email.To exercise any of these rights, please contact us at notices@deltagcapital.com. Your request should include your full name, the nature of your request, and sufficient information to verify your identity.