Privacy Policy

Zen Capital Management is committed to ensuring that your privacy is protected. This privacy policy sets out how Zen Capital Management uses and protects information you provide when you visit this website. Our policy has been derived with respect to the Australia Privacy Principles.

Zen Capital Management may change this policy from time to time by updating this page.

What information do we collect?
We collect information from you when you register on our site. This information may include your name; city, state, zip code and country of residence; email address; phone number; email address; and whether you are classified as a Wholesale Investor.

If you currently are (or become) a client of ours we collect additional information as required for us to meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act. The full scope of information collected varies depending upon the nature and location of the investor. The relevant scope of information collected can be determined through perusal of the account opening form contained in our Private Placement Memorandum. All information collected is forwarded to our Fund Administrator, Apex Fund Services Ltd, for processing and we retain a copy.

For what do we use your information?
The information we collect from you may be used in one of the following ways:

  • To personalize your experience (your information helps us to better respond to your individual needs)
  • To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
  • The email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions.
  • To meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act.

Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.

How do we protect your information?
We have taken significant steps to your personal information from loss and unauthorised access, destruction, use, modification or disclosure. Our site uses a 256-bit Secure Sockets Layer (SSL) to create an encrypted connection between your web browser and our web server. You can check the SSL security of our website by clicking on the “MCafee Secure” logo which appears at the bottom right corner of each page or by following this link.

Client and prospective client information is primarily stored on our local computer systems. All our local data is backed up using SugarSync. Your files are transferred securely using TLS (Transport Layer Security) SSL3.3 and are stored in the cloud in an encrypted format using 256-bit AES. Sugarsync uses Equinix’s SV International Business Exchange data centre in Silicon Valley, California, USA.

Every 6 hours our website is backed-up to CodeGuard. Codeguard copies website files using Amazon EC2 and stores these files using 256-bit AES in Amazon S3 data centres. Amazon's data centres are located all over the world.

Do we use cookies?
Our website is powered by WordPress. The WordPress Content Management System uses cookies to control the user experience on our website. Our website would not function correctly without these cookies. For general information about cookies please visit this link. For the latest information on WordPress cookies please visit the WordPress website by following this link.

Our website is also monitored by Google Analytics. Google Analytics uses cookies to collect information about how visitors use our website and we use this information to improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site; the site from which a visitor has navigated to our website; and the pages they visited whilst on our website. For the latest information on Google Analytics cookies please follow this link.

Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Our website is protected against hackers and spammers using multiple redundant systems. We participate in a global community of website managers who work together to identify website visitors who appear to be hacking websites and/or harvesting e-mail addresses for spam or other similar purposes. We share information with trusted third parties to stop such attacks.

Your Consent
By using our site, you consent to this Privacy Policy.

How can you access and correct your Personal Information?
You have a right to seek access to information which we hold about you, although there are some exceptions to this. You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. Zen Capital Management's policy is to consider any requests for access or correction in a timely way. To provide you with access to your personal information, Zen Capital Management would ordinarily provide you with a print-out of the relevant personal information from our current databases, or with photocopies of records which are held only on current paper files.

Zen Capital Management will endeavour to process your request within 10 business days and attempt to investigate and resolve any complaints within 30 business days. We will let you know if we are unable to meet your request and the reasons why we are unable to meet your request. In some circumstances we may not be able to meet request due to legal restrictions. In some circumstances, it may be necessary for us to seek to arrange access to your personal information via our Fund Administrator.

If you have any questions about this privacy policy, if you wish to complain about how we have handled personal information about you, or if you wish to access or correct your personal information, please contact our Privacy Officer:

  • by telephone: +612 8005 2308; or
  • by letter: The Privacy Officer, Zen Capital Management Pty Ltd, Level 26, 1 Bligh Street, Sydney NSW 2000, Australia


Policy Updated: October 2014