CapXcentric Privacy Policy

Effective Date: 15th January 2025

Version: 1.0

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Excentricity Pty Ltd (ABN: 42 679 978 959) trading as CapXcentric (“we,” “our,” or “us”) is committed to protecting the privacy of your personal information. This Privacy Policy outlines how we collect, use, store, and disclose personal information in compliance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and our obligations as a Corporate Authorised Representative (CAR) of True Oak Investments Pty Ltd (AFSL 238184).

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By using our website or engaging our services, you consent to the collection and handling of your personal information as described in this policy.

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1. Purpose and Scope

This Privacy Policy explains:

• Why we collect personal information.

• The types of personal information we collect.

• How we collect, hold, use, and disclose your personal information.

• How you can access or correct your personal information.

• How you can make a privacy-related complaint.
   

We respect your privacy and will only collect, use, or disclose personal information in ways that are consistent with this policy and applicable laws.

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2. Our Obligations as a Corporate Authorised Representative

As a Corporate Authorised Representative of True Oak Investments Pty Ltd (AFSL 238184), we may be required to collect or share certain personal information with our licensee and relevant regulatory bodies to comply with the Corporations Act 2001 (Cth), ASIC requirements, and other legal or regulatory obligations. Any personal information shared for these purposes is handled in accordance with the Australian Privacy Principles.

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3. Why We Collect Personal Information

We collect personal information for one or more of the following lawful bases:

1. Provision of Services

   • To deliver our capital-raising advisory services to you or your company.

2. Legal and Regulatory Compliance

   • To meet our legal obligations, including those imposed by our AFSL arrangements and Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws.

3. Legitimate Business Interests

   • To manage our operations, maintain internal records, respond to inquiries, improve our user experience, and develop new services.

4. Contractual Necessity

   • Where it is necessary for us to collect personal information to perform a contract or agreement with you (e.g., to provide advisory services).

5. Consent

   • Where you have provided clear, informed consent for specific purposes (e.g., newsletters, updates).
      

4. Types of Personal Information We Collect

1. General Information

   • Name, job title, company name, and business contact details (phone number, email address).

   • Details about your company’s financial and operational background relevant to our services.

   • Records of communication (e.g., emails, meeting notes).

2. Sensitive Information

   • We do not generally collect sensitive information (e.g., health, political, or religious data).

   • If we require sensitive information—for example, certain background checks—we will obtain your consent and only use such information for a primary or directly related purpose.
      

5. How We Collect Personal Information

We primarily collect personal information directly from you when you:

• Engage us for services or enquire about our services.

• Fill out online or paper-based forms.

• Contact us by phone, email, or social media.
   

We may also collect publicly available information from sources such as business websites, LinkedIn, or regulatory databases to verify company or investor-related details.

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6. Consequences of Not Providing Information

If you choose not to provide certain personal information when requested, we may be unable to:

• Provide some or all of our services.

• Comply with legal obligations (e.g., AML/CTF checks).

• Respond adequately to your inquiries.
   

In some cases, we may have to cease our business relationship with you if we are unable to collect necessary information.

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7. Use and Disclosure of Personal Information

We may use or disclose your personal information to:

• Provide and manage our capital-raising advisory services.

• Comply with regulatory requirements, including ASIC, the Corporations Act 2001 (Cth), and AML/CTF laws.

• Collaborate with third-party service providers (hosting, data storage, analytics, administration), bound by strict confidentiality and privacy obligations.

• Communicate with you about service-related matters.

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We will not sell or trade your personal information.

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8. Social Media Use

We maintain a presence on social media platforms (e.g., LinkedIn). While we may post updates or interact with you through these channels:

• We do not request that you share personal or sensitive information publicly.

• Any information you share on social media is subject to that platform’s own privacy practices, which we do not control.

• If you send us a direct message containing personal information, we will handle it in accordance with this Privacy Policy.

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9. Third-Party Links and Websites

Our website may include links to third-party websites. This Privacy Policy does not apply to the privacy practices of external sites. We recommend reviewing the privacy policies of any third-party websites you visit.

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10. Cookies and Website Analytics

We use the Wix platform for our website, which may automatically collect certain usage data and deploy cookies to enhance your browsing experience. In addition, we use Google Analytics, a third-party service that uses cookies and other tracking technologies to help us understand how users interact with our website.

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Cookies help us:

• Understand website traffic patterns.

• Identify usage trends.

• Improve functionality and your experience on our site.
   

You can manage or disable cookies in your browser settings, although doing so may affect certain website features.

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11. Security and Storage of Personal Information

We take reasonable steps to secure your personal information from misuse, interference, and loss, as well as unauthorised access, modification, or disclosure. Our security measures include:

• Encrypted cloud storage.

• Restricted access to client data for authorised personnel only.

• Secure email and communication platforms for sensitive data.
   

12. Overseas Data Storage and Cross-Border Disclosure

While we primarily store data within Australia, certain members of our team and/or our third-party service providers may operate from or store data in countries outside Australia. We take reasonable steps (such as contractual confidentiality obligations and secure access protocols) to ensure these personnel and providers handle your personal information in a manner consistent with the Australian Privacy Principles.

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If you would like more information on our overseas data handling practices, please contact us at privacy@capxcentric.com

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13. Data Retention

We will only retain your personal information for as long as necessary to provide our services or comply with legal obligations. Typically, we retain client-related information for at least 7 years to meet requirements under the Corporations Act 2001 (Cth) or AML/CTF laws.

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When we no longer need your personal information, we will securely destroy or de-identify it.

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14. Accessing and Correcting Your Personal Information

You have the right to request access to the personal information we hold about you and to request corrections if it is inaccurate, incomplete, or out of date.

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To make an access or correction request, please contact us using the details in Section 17. We may need to verify your identity. In certain cases, we may refuse access or correction requests as permitted by law, but we will provide a written explanation if this occurs.​