Last updated 19/20

What is this policy about?

Seed Space recognises the importance of ensuring that its clients have confidence in the way that Seed Space handles personal information. This document sets out the policy of Seed Space for handling personal information and has been prepared to:

  1. provide the Director, employees and Authorised Representatives with information about what they can do with personal information collected from clients; and
  2. provide clients with information about what Seed Space can do with their personal information.

Seed Space is bound by, and committed to the terms of the Privacy Act 1988 and the National Privacy Principles forming part of that Act. A summary of the National Privacy Principles is available by contacting our office.

What is personal information?

Personal information is any information about you, that identifies you or by which your identity can reasonably be ascertained.

What kinds of personal information do we collect and hold about you?

Seed Space only collects personal information that is necessary for one or more of its functions or activities.

Seed Space is subject to certain legislative and regulatory requirements which require it to obtain and hold detailed information which personally identifies you and/or contains information or an opinion about you (“Personal Information”).

In order to provide you with comprehensive advisory and dealing services, Seed Space may (where relevant) require certain Personal Information about you, including:

  1. name and/or names used;
  2. permanent address and postal address if different;
  3. employment details;
  4. date of birth;
  5. Tax File Number (or Exemption);
  6. details of your financial needs and objectives;
  7. details of your investment history and preferences; and
  8. your aversion or tolerance to risk.

We will not collect any Personal Information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us. Generally collection of your Personal Information will be effected in either a face-to-face interview, over the telephone or by way of the Managed Discretionary Account Agreement. From time to time additional and/or updated Personal Information may be collected through one or more of those methods.

We will only collect, maintain and use Personal Information about you if it is necessary for us to adequately provide to you the service you have requested including investing in financial products on behalf of your account and all things necessary or incidental to this service.

How is Personal Information collected?

Most information that we hold about clients is collected from the initial interview and the Managed Discretionary Account Agreement. Information may also be collected over the phone or via the internet during the course of the client's relationship with Seed Space. Sometimes, information about an individual is collected from other people or organisations. For example, information about a director of a corporate client may be obtained from a public record relating to the company.

Regardless of how it is collected, all Personal Information is handled in accordance with this Privacy Policy.

Use and Disclosure of Personal Information i.e. what does Seed Space use your Personal Information for?

Seed Space uses the Personal Information it holds in order to provide its clients with the services that they request. Seed Space will not use or disclose Personal Information collected by us for any purpose other than:

  1. the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
  2. where you have consented to such disclosure; or
  3. where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

Seed Space is required under the Corporations Act to make certain information available for inspection by the Australian Securities and Investments Commission (ASIC) and Innovation and Science Australia (ISA) on request to ensure ongoing compliance with licensing and regulatory requirements. This may involve the disclosure of your Personal Information. Seed Space may also collect Personal Information from its suppliers in order to complete business transactions and purchase products and services.

It is a condition of our agreement with each of our external contractors that they adopt and adhere to this Privacy Policy. You can be assured that your information will be maintained by any contractor to whom it is disclosed in accordance with this policy. If you have any concerns in this regard, you should contact us by any of the methods detailed below (refer paragraph below entitled “Contact Details”).

It is important to note that Seed Space provides clients with investment products in the form of Venture Capital Funds. Providing a client with this product/service includes undertaking activities such as receiving and administering the client's investment, providing client support, responding to enquiries and requests for product information and meeting regulatory requirements.

Seed Space may disclose your Personal Information to external contractors for the following purposes:

a) performing KYC as required for AML/CTF verification;

b) registration and/or changes to shareholder details;

c) accounting for financial product transactions;

d) causing statutory audits to be conducted as required by law;

e) maintenance and service of our information technology systems; or

f) in the course of reviews by external consultants.

If Seed Space is unable to collect Personal Information from or about a client, it may not be able to do business with that client. Seed Space may also use the Personal Information collected from you for the purpose of providing you with direct marketing material such as research that may be of interest to you, to inform you about any new products and services or special offers from time to time. However you may, by contacting us by any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow 2 weeks for your request to be actioned.

Document storage and security

We will at all times seek to ensure that the Personal Information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your Personal Information is treated as confidential and any sensitive information is treated as highly confidential and stored securely.

Your Personal Information is generally held in your client file. Information may also be held in a computer database. Seed Space will take reasonable steps to ensure that all Personal Information we collect or use is:

  • accurate, complete and up-to-date;
  • stored in a secure environment; and
  • accessed only by authorised personnel for permitted purposes.

If your details change, we ask that you advise us of the change as soon as possible in order that we may maintain accurate records.

All electronic information is protected by maintaining a certified security capable operating system i.e. access is only granted via suitable passwords on each computer.

In the event you cease to be a client, any Personal Information which we hold about you will be maintained for a period of 7 years in order to comply with legislative and regulatory requirements, following which time the information will be destroyed.

Access to your Personal Information

You may at any time, by contacting us (refer paragraph below entitled “Contact Details”), request access to your Personal Information.

Seed Space will (subject to the following exceptions) provide you with access to that information either by:

  • providing you with copies of the information requested;
  • allowing you to inspect the information requested; or
  • providing you with an accurate summary of the information held.

We may, prior to providing access in accordance with this policy, require you to provide evidence of your identity.

Seed Space will not provide you with access to your Personal Information if:

a) providing access would pose a serious threat to the life or health of a person;

b) providing access would have an unreasonable impact on the privacy of others;

c) the request for access is frivolous or vexatious;

d) the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;

e) providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;

f) providing access would be unlawful;

g) denying access is required or authorised by or under law;

h) providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

In the event Seed Space refuses you access to your Personal Information, we will provide reasons.

Correction of Personal Information

Seed Space will endeavour to ensure that, at all times, the Personal Information about you (that we hold) is up to date and accurate. In the event that you become aware, or believe, that any Personal Information which we hold about you is inaccurate, incomplete or outdated, you must contact us and provide us evidence of the inaccuracy or incompleteness. Seed Space will, if we agree that the information requires correcting, take all reasonable steps to correct the information.

If we do not agree that your Personal Information requires correcting, Seed Space must, if you request, take reasonable steps to ensure that whenever your Personal Information is accessed or handled in the future, it is apparent that you are not satisfied as to the accuracy or completeness of that information.

We will endeavour to respond to any request for access within 2 weeks, depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.

Does Seed Space disclose the Personal Information it holds?

Sometimes Seed Space obtains services from other organisations and where necessary (and where the law permits), Personal Information will be provided to those organisations. The kinds of services obtained externally by us include information technology support, administrative services, legal advice and compliance advice.

External service providers are only authorised to use Personal Information for the purpose for which we supplied it. Those organisations are not authorised to use that Personal Information for their own purposes.

Sometimes, the law requires us to disclose Personal Information. For example, information may be disclosed to a court in response to a subpoena or to a Government agency such as the Australian Taxation Office.

Where a client nominates someone to act on their behalf, Seed Space may provide information to that person, for example, the client's accountant or financial adviser.

Resolving concerns

If you believe that the privacy of your Personal Information has been compromised, you are entitled to complain. Complaints can be made by contacting the Managing Director, Mr Dirk Steller. We will respond to complaints as soon as possible. It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are not satisfied with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.

Contact Details

Managing Director
Dirk Steller

Address Seed Space Pty Ltd
Level 4, 11 York St
Sydney NSW 2000
Australia Email dirk@seedspace,vc.

Additional information If you would like more information about our approach to privacy, you are encouraged to contact the Managing Director.