PRIVACY POLICY

In order to establish and administer your investment in a scheme and provide information about our products and services to investors and financial advisers, and to comply with relevant legislation, we may collect the following information:

• Various privacy laws impact on the way in which the Gcomm.Digital Pty Ltd TA The Seo Company (we,us and our) and each of the schemes of which we are theresponsible entity or trustee, operate. These laws includethe Australian Privacy Principles contained in the Privacy Act1988, the Privacy Amendment (Notifiable Data Breaches)Act 2017 and the European Union General Data ProtectionRegulation (the GDPR).
• Your privacy is important to us and we are committedto managing your personal information responsibly andin accordance with our legal obligations including therequirements of the Privacy Act 1988 and with the AustralianPrivacy Principles. These laws and principles regulate,among other things, the way we collect, use, disclose, keepsecure, and give you access to your personal information.
• In order to provide investment services to you we need tocollect and retain some personal information. This allowsus to process applications, administer accounts and provideyou with information. We may also use your personal detailsto communicate with you about products and services andcomply with relevant laws. We consider all information aboutyou to be private and confidential.
• This Privacy Policy sets out the type of information we collectand how we collect, store, use and disclose your personalinformation. We recommend that you read it carefully.
• You are not required to provide us with your personalinformation, but if you do not do so we may not be ableto provide you with our products or services.
• If you apply for or accept any of our products or servicesor otherwise provide us with your personal information, youagree to your information being collected, held, used anddisclosed as set out in this Privacy Policy. We may revisethis Privacy Policy from time to time by placing the revisedPrivacy Policy on our website or otherwise notifying youof the change.

Wherever practicable, we will collect information about individuals from those individuals.
However, it may be necessary at times to collect information about individuals from other external sources, such as: ·
• a financial adviser or broker;·
• authorised representatives, such as executors oradministrators; and·
• identification verification service providers.

We currently operate a website, at www.seo co.funds.com.au.
Our web server (ie the computers that house our website) has the capacity to collect the following types of information for statistical purposes:

• The number of users who visit the website;·
• The number of pages viewed; and·
• Traffic patterns.

This is anonymous statistical data and no attempt is made to identify users or their browsing activities. This data is used only to evaluate our website performance and to improve the content we display to you.
Other information, such as browser type, is included in a ‘cookie’ that is sent to your computer when you complete certain tasks on our website. A cookie contains bits of information that enables our servers to identify and interact efficiently with your computer. Cookies are designed to provide a better, more customised website experience, and to make it easier for you to use our website. You can configure your computer to accept or reject cookies.

Your information is protected from unauthorised access through the use of secure passwords, user log-ons or other security procedures. Developments in security and encryption technology are reviewed regularly. Where necessary, we will remind you that the Internet is an insecure medium.

Generally, we only use and disclose personal information for the purpose for which it was disclosed to us or related purposes which would reasonably be expected. Those purposes include: 
To establish and administer an investor’s investmentaccount and
Their relationship with us;

• For communication purposes;
• To comply with our record-keeping, reporting, andtax obligations;
• to protect legal rights and comply with legal obligations;
• To prevent fraud and abuse;
• To enable us to provide information about and existingproducts and services that will enhance our relationshipwith the relevant parties. However, we do respect the rightof individuals to ask us not to do this; and
• To handle any relevant enquiries or complaints.

Required by law 

We may be required by law to disclose personal information. For instance, we may be required to provide details to: · Australian Government regulators such as the Australian Securities and Investments Commission (ASIC), Australian Tax Office (ATO), Australian Transaction Reports and Analysis Centre (AUSTRAC) and to other regulatory or government entities;·Australian Financial Complaints Authority (AFCA)·Office of Australian Information Commissioner (OAIC)· as required by a court order;· to other regulatory or governmental entities outsideof Australia as may be required; and· your spouse in accordance with the Family LawAct requirements.

Market research

We may also provide some information to market research companies, for the purpose of analysing our client base. We may provide investors’ and advisers’ or prospective investors’and advisers’ contact details to market research companies, to undertake research on our behalf. These agencies must return to us, destroy or retain in accordance with the privacy law all records of this information. We retain ownership of this information and will ask you if you do not wish to participate in market research.

Information about you or your investment in the scheme is not and will not be sold to any other company, individual, or group.

You may request access to any personal information we hold about you. Generally, if it is incorrect, we will correct it at your request.Your right to access is subject to some exceptions allowed by law. We will notify you of the basis for any denial of access to your personal information.

If you are located in the EU, then you may have additional rights. Some of these rights will only apply in very limited circumstances.

• You can ask us to confirm if we are using or holding yourpersonalinformation.
• You can ask us to delete your personal information. Thisright applies only on limited circumstances and will notusually apply where it remains necessary for is to use yourinformation for the purposes for which it was collected,we are required by law to retain your information or yourinformation is relevant to a legal dispute.
• You can ask us to help you move your personal informationto other companies, where this is technically possible andonly if we have collected and used your data via automaticmeans.
• You have the right to be informed and now about anyprotections that we have in in place where we are transferringyour data overseas. We may send your personal informationto third party service providers to whom we outsource certainfunctions, who may be located overseas. When we discloseyour information overseas, we are required to take measuresto ensure your information is treated in accordance withthe standards that apply in Australia except in rare cases(for example, where we are required by law to disclose yourinformation overseas).

Yes. A copy of our current Privacy Policy (this document) is available from us free of charge as follows:

1. You can request a copy be emailed to you by emailingyour request to investorrelations@seo.co;
2. You can request a copy be emailed to you by emailingyour request to investorrelations@seo.co;
3. You can telephone us and request a copy be mailed oremailed to you by calling 1300 885 557
4. You can write to us and request a copy be mailed oremailed to you. Our postal address is: 276 Petrie Terrace, Brisbane QLD 4000.
5. If you would like a copy of this Privacy Policy in a particular format (for example, on audio disc) please contact us at the telephone number or postal address set out above and we will accommodate any reasonable request.

If you have any further questions relating to this privacy statement, or concerns about the way in which we have handled your personal information, please do not hesitate to:

• Email us at support@seo.co
• Telephone us on 1300 885 557
• Write to us at 276 Petrie Terrace, Brisbane QLD 4000.