Our Privacy Policy

1. Introduction

Alternative Investments Portfolio Pty Ltd (ACN 99 697 202 430) trading as Altolio ("altolio", "we", "us" or "our"). We are committed to protecting the privacy of all individuals who interact with our platform, website and services.

This Privacy Policy explains how we collect, use, disclose and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Where relevant, we also address our obligations to individuals located in other jurisdictions, including the United States, the United Kingdom, the European Union and Asia.

By accessing or using the Altolio platform or website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this policy, please do not use our platform or services.

2. Who We Are

Alternative Investments Portfolio Pty Ltd (ACN 99 697 202 430) trading as Altolio is a corporate authorised representative (CAR No.xxxxx) of Banxly Investment Group (ABN 54 652 385 807) (AFSL 538864) and is regulated by the Australian Securities and Investments Commission (ASIC).

For privacy purposes, Altolio is the entity responsible for personal information collected through the Altolio platform and website.

Contact details:

Company:	Altolio
Email:	hello@altolio.com.au
Phone:	xxxxx
Postal:	PO Box 179, Port Melbourne VIC 3207

3. Information We Collect

We collect personal information that is necessary for the provision of our services and the operation of the Altolio platform. The types of information we collect include:

3.1 Information you provide directly

• Full name, date of birth and contact details (email, phone, address)
• Identity verification documents (passport, driver licence) for KYC/AML purposes
• Financial information required to assess wholesale investor eligibility
• Tax file number (TFN) or foreign tax identification number where required
• Bank account and payment details
• Investment preferences, risk profile and portfolio information
• Communications you send to us, including enquiries and correspondence

3.2 Information collected automatically

• Device and browser information, including IP address
• Usage data and platform activity logs
• Cookie and tracking data (see Section 10)
• Location data were permitted by your device settings

3.3 Information from third parties

• Identity verification services and credit reporting bodies
• AUSTRAC and government databases for AML/CTF compliance
• Introducers, referrers and partner organisations who refer you to us
• Publicly available source.

4. How We Use Your Information

We use personal information for the following purposes:

• Providing, operating and improving the Altolio platform and our services
• Verifying your identity and assessing your eligibility as a wholesale investor
• Processing investment applications, transactions and distributions
• Complying with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and related regulations
• Complying with our AFSL and ACL obligations and other applicable laws
• Communicating with you about your account, investments and platform updates
• Providing investor education content and market insights
• Responding to enquiries, complaints and feedback
• Detecting, preventing and investigating fraud and security incidents
• Conducting internal analytics, reporting and platform development
• Marketing our services to you where you have consented or were permitted by law

We will not use your personal information for purposes that are incompatible with those set out above without your consent.

5. Disclosure of Information

We may disclose your personal information to the following categories of recipients:

5.1 Service providers

Third-party service providers who assist us in operating the platform, including technology providers, identity verification services, custody providers, registry administrators, legal and compliance advisers and payment processors. These providers are bound by confidentiality obligations and are only permitted to use your information for the purposes for which it was disclosed.

5.2 Regulatory and legal bodies

ASIC, AUSTRAC, the Australian Taxation Office (ATO), law enforcement agencies and other government bodies where required by law or court order.

5.3 Professional advisers

Our lawyers, auditors, accountants and insurers, where necessary for the operation of our business.

5.4 Investment counterparties

Fund managers, product issuers and other investment counterparties where necessary to facilitate investments made through the platform.

5.5 Business transfers

In the event of a merger, acquisition, restructure or sale of our business, your personal information may be transferred as part of that transaction. We will notify you of any such transfer in accordance with applicable law.

We do not sell, rent or trade your personal information to third parties for their own marketing purposes.

6. Cross-Border Data Transfers

As Altolio anticipates serving investors from Australia, the United States, the United Kingdom, Europe and Asia, personal information may be transferred to, stored in or processed in countries other than Australia.

Where we transfer personal information outside Australia, we take reasonable steps to ensure that the recipient is subject to privacy protections that are substantially similar to those provided under the Australian Privacy Principles, or we otherwise comply with APP 8 in relation to that transfer.

6.1 United Kingdom and European Union

For individuals located in the UK or EU, we acknowledge the requirements of the UK GDPR and EU GDPR respectively. We rely on appropriate safeguards including standard contractual clauses or adequacy decisions for transfers of personal data from the UK or EU to Australia or other third countries.

6.2 United States

For US-based individuals, personal information may be processed and stored in Australia and other jurisdictions. We handle all such information in accordance with this policy and applicable law.

6.3 Asia

For individuals located in Asian jurisdictions, we comply with applicable local privacy laws to the extent required and handle personal information in accordance with this policy.

By providing your personal information to us, you consent to its transfer, storage and processing in accordance with this section.

7. Security

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

• Encryption of data in transit and at rest
• Multi-factor authentication for platform access
• Access controls limiting information to authorised personnel
• Regular security assessments and penetration testing
• Incident response procedures for data breaches

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

No method of transmission over the internet or electronic storage is completely secure. While we use commercially reasonable measures to protect your information, we cannot guarantee absolute security.

8. Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Key retention periods include:

• AML/CTF records: Minimum 7 years from the date of the transaction or end of the customer relationship, as required by the AML/CTF Act
• Financial services records: As required by our AFSL obligations and ASIC regulatory guidance
• Tax records: As required by the ATO and applicable tax legislation
• General account information: For the duration of your relationship with us and a reasonable period thereafter

When personal information is no longer required, we take reasonable steps to destroy or de-identify it securely.

9. Your Rights

9.1 Access and correction

You have the right to request access to personal information we hold about you, and to request that we correct any information that is inaccurate, out of date, incomplete or misleading.

To make a request, contact us at hello@altolio.com.au.

We will respond to access and correction requests within 30 days. In some circumstances, we may be unable to provide access — for example, where doing so would unreasonably impact the privacy of another individual, or where we are legally required to withhold the information.

9.2 Additional rights for UK/EU individuals

If you are located in the UK or EU, you may have additional rights under the UK GDPR or EU GDPR, including the right to erasure, restriction of processing, data portability and the right to object to processing. To exercise these rights, please contact us at hello@altolio.com.au.

9.3 Marketing opt-out

You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions in any marketing email, or by contacting us directly. Opting out of marketing does not affect our ability to send you service-related communications.

10. Cookies and Tracking

We use cookies and similar tracking technologies on our website and platform to enhance your experience, analyse usage and support platform functionality. Types of cookies we use include:

• Essential cookies: Required for the platform to function correctly
• Analytics cookies: Help us understand how visitors use our platform (e.g. Google Analytics)
• Preference cookies: Remember your settings and preferences
• Marketing cookies: Used to deliver relevant content and track the effectiveness of our communications

You can control cookie settings through your browser. Disabling certain cookies may affect platform functionality. By continuing to use our platform, you consent to our use of cookies in accordance with this policy.

11. Privacy Complaints

If you believe we have handled your personal information in a way that does not comply with this policy or the Australian Privacy Principles, you may make a complaint by contacting us at:

Privacy Officer

Company:	Altolio
Email:	hello@altolio.com.au
Phone:	xxxxx
Postal:	PO Box 179, Port Melbourne VIC 3207

We will acknowledge your complaint within (5) business days and aim to resolve it within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

12. Contact Us

For any privacy-related questions, requests or concerns, please contact us:

Company:	Altolio
Email:	hello@altolio.com.au
Phone:	xxxxx
Postal:	PO Box 179, Port Melbourne VIC 3207

We reserve the right to update this Privacy Policy from time to time. Where we make material changes, we will notify you by email or by posting a notice on the platform or website. The date of the most recent update is noted at the top of this policy.