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1.1 Quintessential Equity Pty Ltd A.C.N. 141 879 423, AFSL 347953 and each Group Entity are committed to the protection of Personal Information in accordance with the Australian Privacy Principles and the Privacy Act.
1.2 This Privacy Policy describes the way we collect, hold, use, and disclose Personal Information in accordance with the Privacy Act and the Australian Privacy Principles. It is not intended to cover categories of Personal Information that are not covered by the Privacy Act or the Australian Privacy Principles.
1.3 This Privacy Policy applies to Personal Information collected from:
1.4 This Privacy Policy does not apply to employee records we hold relating to current or former employees, where the handling of those records is directly related to the employment relationship, as permitted under applicable law.
1.5 We may, from time to time, review and update this Privacy Policy, including for business practices, to consider new laws, regulations, and technology.
1.6 All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website.
1.7 This policy is available free of charge via our Website.
2.1 If you wish to make any inquiries about this Privacy Policy or make a complaint you can contact us in any of the following ways:
By Email - Marked to the attention of the Privacy Officer
coysec@quintessential.com.au
By Post
Privacy Officer
Quintessential Equity Pty Ltd
Level 3, 90 Collins Street Melbourne, VIC 3000
By Telephone
Privacy Officer
(03) 9914 2214
3.1 For the purpose of this Privacy Policy:
AML Information means the Personal Information that we collect and hold as part of complying with our AML/CTF obligations, including (but not limited to) customer due diligence-related information.
AML/CTF Obligations means our obligations as a reporting entity, as set out in the AML/CTF Legislation.
AML/CTF Legislation means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and the Anti-money Laundering and Counter-Terrorism Financing Rules 2025 (Cth), as amended from time to time.
Australian Privacy Principles means the principles set out in schedule 1 of the Privacy Act.
Business Day means any day of the week except a Saturday, Sunday or a day which is an official public holiday in the city of Melbourne
Group Entity means a company which shares a common director or shareholder with Quintessential Equity Pty Ltd A.C.N. 141 879 423.
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not, and includes AML Information.
Privacy Act means Privacy Act 1988 (Cth) as amended from time to time.
Privacy Officer means the contact person within our business for questions or complaints regarding our handling of personal information.
Sensitive Information means information or an opinion about an individual’s:
that is also Personal Information; or
Suspicious Matter Report means a report that we are required to submit to AUSTRAC if a suspicious matter reporting obligation arises as defined in section 41 of the AML/CTF Act.
Tipping off prohibition means a disclosure to a person that we have lodged, are required to lodge, or have prepared, a Suspicious Matter Report to lodge AUSTRAC, where such disclosure would or could reasonably be expected to prejudice a criminal investigation.
Website means the website accessible via the internet or similar network that is owned, operated or made available by or on behalf of Quintessential including any associated domains, subdomains and content. The URL of the Quintessential Website at the date of this Privacy Policy is https://www.quintessential.com.au
A reference to “ Qunitessential” “we or us” is a reference to Quintessential Equity Pty Ltd A.C.N. 141 879 423 and each Group Entity.
A reference to “you” is a reference to an individual in repect of whom we have collected and hold Personal Information or intend to do so.
4.1 We may collect and hold Personal Information from investors, prospective investors, employees, prospective employees, suppliers and contractors and other individuals that is reasonably necessary:
4.2 Information which we collect and hold may include your name, gender, date of birth, contact details (including your address, phone numbers, and email addresses), details or copies of your identification documents (such as driver’s licence or passport), financial information, payment details, bank account details, tax file numbers (where permitted by law), company and trust information including information regarding directorships , beneficiaries and ABN/ACN, and/or products and services information and preferences, employment history, qualifications and references, payroll tax, and superannuation information.
4.3 We may collect Sensitive Information where we are required to do so or otherwise with consent of the individuals concerned. We will not collect Sensitive Information about you without your consent, unless an exemption in the Australian Privacy Principles applies. These exemptions include (but are not limited to) if the collection is required or authorised by law, or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
4.4 We do not adopt a government related identifier (such as a tax file number, Medicare number or driver’s licence number) as our own identifier of you. We only use or disclose government related identifiers where required or authorised by law or otherwise permitted.
4.5 We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical and, in some circumstances, illegal for us to deal with individuals who are not identified.
5.1 We collect Personal Information for our usual functions or activities, including:
6.1 We may collect Personal Information about you in a number of ways including when you:
6.2 We may also collect Personal Information about you through publicly available sources or via third parties, including from our business partners and other service providers who assist us in our business operations.
6.3 In some circumstances, we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.
6.4 When we collect Personal Information (whether directly from you or from a third party), we will notify you or ensure you are aware of:
We usually provide this information through collection notices on application forms, investor portals, website forms, onboarding documentation and supplier engagement materials.
7.1 We will not collect any Personal Information about users of our Website except when they knowingly provide it or as otherwise described below. For example, we may collect Personal Information from users of the Website when they:
8.1 When you visit and browse our Website, our Website host may collect Personal Information for statistical, reporting, and maintenance purposes. Personal Information collected by our Website host will not be used to identify you. The information may include:
8.2 Quintessential’s Website host uses this information to administer and improve the performance of our Website, including to assist with the diagnoses of and to provide support for any issues with our Website or services.
9.1 Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type, or website visiting patterns.
9.2 If you access our Website, a cookie is downloaded onto your computer's hard drive when you first log on to our Website. You can adjust your internet browser to disable cookies; however, we may not be able to provide you with all the service or functionality you require on our Website if you choose to do so.
10.1 Web beacons are images that originate from a third-party site to track visitor activities. We may use web beacons to collect aggregate data and provide this information to our Website host to administer and improve the performance of our Website.
11.1 If you follow any links to external websites from our Website, this Privacy Policy will not apply to those websites, which may have their own policies relating to privacy and data collection and website usage. If you choose to access any linked website or provide any Personal Information on such websites, you should review their policies and terms of use to learn more about how they may use your Personal Information. We are not responsible for and will not be liable for the operations or policies of any external website.
12.1 We use the Personal Information which we collect about you for our business functions and activities, which may include the following:
12.2 We may use your Personal Information for a secondary purpose if that secondary purpose is related to those purposes listed in clause 12.1 if we have your consent, or if otherwise provided for under the Privacy Act. Sensitive Information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise, or an exemption in the Privacy Act applies.
13.1 We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you.
13.2 We may only use Personal Information we collect from you for the purposes of direct marketing without your consent if:
13.3 These communications may be sent in various forms, including mail, SMS, and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe' set out in the relevant communication or by contacting us using the details set out in Part 2.
13.4 In addition, where you have provided your consent, we may also use your Personal Information or disclose your Personal Information to third parties for the purposes of advertising, including online behavioural advertising, website personalisation, and to provide targeted or retargeted advertising content to you (including through third party websites).
13.5 If we disclose Personal Information to a third party, before we enter into an agreement with the third party, we review the terms of the agreement with the third party to understand how Personal Information is collected, handled and stored by that third party, and we ensure that we are satisfied that the third party has appropriate processes in place to protect the Personal Information, and where relevant, to comply with its obligations under the Privacy Act.
14.1 We may use automated processes, including algorithms and data analytics tools, to assist in making decisions and carrying out activities in connection with our business. These processes may involve the use of your Personal Information to:
14.2 Automated decision-making may involve profiling, where we analyse Personal Information to evaluate certain characteristics, such as investment preferences, risk profile, or likely interests.
14.3 Where automated processes are used, they are typically designed to support human decision-making and are not solely determinative of outcomes that significantly affect you. However, in some circumstances, decisions may be made with limited human involvement.
14.4 We take reasonable steps to ensure that any automated decision-making processes we use are fair, reasonable, and do not result in unjustified adverse impacts.
14.5 You may request further information about how automated decision-making is used in relation to your Personal Information, or request that we review a decision, by contacting us using the details set out in Part 2
15.1 Depending on the nature of your relationship with us, we may disclose your Personal Information to shareholders, officers, and employees of Quintessential or of a Group Entity, service providers who assist us in our business operations when this is necessary for them to provide their services, government bodies, regulatory authorities and law enforcement bodies, and third parties, or otherwise as required by law, including as required to comply with our AML Obligations.
15.2 We may also disclose your Personal Information to our Website host or service providers in certain limited circumstances, for example, when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner. To the extent that we do share your Personal Information with a service provider, we would only do so if that party has agreed to comply with the same or similar privacy standards as described in this Privacy Policy.
15.3 We may also share non-personal, de-identified, and aggregated information for research or promotional purposes in connection with providing requested information or services to you, or for the purposes of improving our services. We will not sell your Personal Information to third parties for marketing purposes.
15.4 You may authorize us to disclose Personal Information that we hold about you to your financial adviser, administrator, or another person nominated by you.
15.5 If we disclose your Personal Information to third parties, including service providers that perform business activities for us, they may only use your Personal Information for the specific purpose for which we supply it.
15.6 We will make third parties aware of this Privacy Policy and will also ensure that third parties have implemented policies in relation to the management of your Personal Information in accordance with the Privacy Act.
15.7 These policies include:
15.8 When disclosing Personal Information about an individual, we ensure that we will not breach the Tipping off prohibition.
15.9 Unless otherwise specified in this Privacy Policy, Quintessential, Group Entity or Quintessential’s Website host will not disclose any of your Personal Information to any other organization unless the disclosure is required by law or is otherwise permitted by the Privacy Act or is with your consent.
16.1 We may disclose personal information to recipients located overseas, including where we use offshore service providers or cloud-based systems. Where we do so, we take reasonable steps to ensure that the recipient complies with the Australian Privacy Principles.
17.1 Quintessential will take reasonable steps to protect your Personal Information from misuse, interference, and loss and from unauthorized access, modification, or disclosure. We will do this by adopting one or more of the following
17.2 Quintessential aims to keep your Personal Information secure and up to date. we will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information that is held on Quintessential’s computer systems.
17.3 Personal Information that is held by Quintessential in hard copy is stored securely on its premises and is only disclosed or used for the purposes described in this Privacy Policy.
18.1 Quintessential will take reasonable steps to ensure that the Personal Information that we collect, use, hold and disclose is accurate, up-to-date, and complete. You can update your Personal Information at any time by contacting us in any of the ways specified in Part 2. We welcome any changes to your Personal Information to keep our records up to date.
18.2 We encourage you to contact us to update any Personal Information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.
19.1 Quintessential will keep your Personal Information only for as long as required for our business purposes and otherwise as required by Australian law, including as required to comply with our AML Obligations.
19.2 Where there is no longer a need to keep your Personal Information, we will take positive and reasonable steps to destroy or de-identify your Personal Information.
19.3 If you wish to have your Personal Information destroyed or de-identified, please let us know, and we will take reasonable steps to do so (unless we need to keep it for legal, auditing, or internal risk management reasons).
20.1 You are entitled to access Personal Information that we hold about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted under the Australian Privacy Principles or at law. If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal.
20.2 A request for access can be made by contacting us in any of the ways specified in Part 2. You may request access to, or correction of, your Personal Information by contacting us. We will respond within a reasonable period and in accordance with the Privacy Act. We may refuse access in limited circumstances permitted by law.
20.3 We will require identity verification, and specification of what information is required, before we provide access to Personal Information. An administrative fee for search and photocopying costs may be charged for providing access.
21.1 We maintain a data breach response process. Where we suspect unauthorised access, disclosure or loss of Personal Information, we will take steps to contain and assess the incident.
21.2 If a breach is likely to result in serious harm and is an ‘eligible data breach’, we will comply with our obligations under the Notifiable Data Breaches scheme, including notifying affected individuals and the Office of the Australian Information Commissioner where required.
22.1 If you believe we have breached the Privacy Act or the Australian Privacy Principles, you may contact us using the details in Part 2. Please note we may require proof of your identity and full details of your request before we can process your complaint. We will acknowledge your complaint promptly, investigate the matter; and provide a response within a reasonable timeframe.
22.2 If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner.
by:
23.1 This Privacy Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.
23.2 We ensure that we stay informed of any issues or developments in relation to the application of the Privacy Act and any changing legal obligations by subscribing to the OAIC’s newsletter (Information Matters newsletter | OAIC).
23.3 We monitor for, and address any new security threats or risks, by signing up to alerts from the Australian Signals Directorate (Sign up for alerts | Cyber.gov.au).
24.1 It is the responsibility of management to inform employees and other relevant third parties about this Privacy Policy and any changes to this Privacy Policy.
24.2 All new employees are provided with timely and appropriate access to this Privacy Policy, with training in relation to appropriate handling of Personal Information, including in relation to de-identifying or destroying documents, as well as cyber-security threats and risks.
24.3 Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.
Privacy breaches must be reported to management by employees and relevant third parties. Ignorance of this Privacy Policy will not be an acceptable excuse for non-compliance. Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.
Effective from 1 July 2026.
