Light Your Way

Privacy Policy

(Wholesale Investor & Institutional Version)

Pages Privacy Policy

1. Purpose and Scope

Ribbon Capital Pty Ltd (ACN [RED]) (“Ribbon”, “we”, “us”, or “our”) is committed to protecting the privacy and personal information of our investors, clients, counterparties, and partners. This Privacy Policy outlines how we collect, use, disclose, and protect personal information, in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. Types of Information Collected

We may collect personal information such as:

    • Name, contact details, date of birth, nationality;
    • Financial and investment details (including wholesale investor certifications);
    • Identity documents (e.g., passport, driver’s license) for AML/KYC verification;
    • Tax and residency status;
    • Transaction, investment, and account details.

3. Collection Purpose

We collect personal information to:

    • Assess wholesale investor eligibility and suitability;
    • Meet AML/CTF obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006;
    • Establish, administer, and manage investments in Ribbon funds;
    • Provide reporting and investor communication;
    • Comply with legal, regulatory, and audit requirements.

4. AML/KYC and Investor Suitability

As a regulated wholesale investment manager, Ribbon must perform:

    • Verification of investor identity (KYC);
    • Assessment of investor status and financial sophistication (wholesale investor eligibility);
    • Ongoing monitoring for suspicious activity as required by AML/CTF laws.
      Failure to provide requested AML/KYC documents may result in delayed or rejected applications.

4. AML/KYC and Investor Suitability

As a regulated wholesale investment manager, Ribbon must perform:

    • Verification of investor identity (KYC);
    • Assessment of investor status and financial sophistication (wholesale investor eligibility);
    • Ongoing monitoring for suspicious activity as required by AML/CTF laws.
      Failure to provide requested AML/KYC documents may result in delayed or rejected applications.

6. Overseas Disclosure

Where personal information is disclosed to overseas recipients, Ribbon ensures appropriate safeguards are in place, including contractual protections or reliance on jurisdictions with adequate privacy laws.

7. Security Measures

Ribbon takes reasonable steps to:

    • Protect personal information from misuse, interference, and unauthorized access;
    • Use encryption, secure storage, and access controls;
    • Ensure third-party service providers comply with equivalent data protection standards.

8. Access and Correction

You may request access to or correction of your personal information held by us. Please contact us at [insert contact details]. We will respond within a reasonable time.

9. Marketing Communications

We may use your information to send investment updates or related offers. You can opt out at any time.

10. Complaints and Contact

If you have concerns about our privacy practices, please contact 1300 089 999. If unresolved, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

11. Updates

Ribbon reserves the right to update these Terms & Conditions at any time. Continued use of the website after changes constitutes acceptance of the updated Terms.