NGE Capital Limited (NGE) (ABN 31 112 618 238) is committed to protecting your privacy and maintains a policy of strict confidence concerning your personal information (Privacy Policy).

This Privacy Policy details how NGE deals with your personal information and has been developed in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).

By providing your personal information directly or indirectly you accept the terms of this Privacy Policy. Providing your personal information indirectly includes via one of NGE’s service providers or a person authorised by you to provide your personal information.

1. Why do we collect your personal information?
   Personal information is information about you from which you can be reasonably identified.

   The primary purpose for which the information is collected is to enable our investor’s holdings to be maintained and administered efficiently, to keep our investors informed about our business and its performance, and to enable us to comply with our legal and regulatory obligations.

   We may also collect your personal information for marketing and promotional purposes.

   In addition, we may collect personal information about individuals who are not investors in NGE Capital Limited, for example business contacts details of potential investees and representatives of companies with whom we deal.

2. What information do we collect?
   We may ask for a range of personal information to assist us in providing you with our services. Information we may request includes personal information such as your name, address, and contact details. We may also ask you to provide details of your security holdings.

   Information such as your bank account details, date of birth, and TFN may also, or instead, be collected by the share registry (Boardroom Pty Limited). Please refer to their privacy policy for further details:

   https://boardroomlimited.com.au/privacy-policy/

3. How do we collect your personal information?
   We collect personal information about you directly from you. We may collect information from you when you:
   • invest in the company;
   • request information from us or from our service providers;
   • telephone, email or write to us or our service providers;
   • attend our presentations to investors, potential investors and financial planners; or
   • subscribe to receive company updates through our website.

   We may also collect your personal information from third parties including public sources, your adviser(s), agents, referrers, brokers and service providers.

   However, we will only collect information from third parties where it is not reasonable and practical to collect the information from you directly.

   We may collect information based on how you use NGE’s website. NGE may use “cookies” to collect information on website activity. This information can be used to analyse and improve our website, but no attempt is made by NGE to use this information to personally identify you.

   If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.

4. Use and disclosure of information
   We will only use personal information for the purposes for which it was given to us, or for purposes which are directly related to the provision of our services.

   In certain circumstances, it may be necessary for us to disclose your personal information to third parties in order to assist us in providing our services, or where disclosure is required by us to meet our legal and regulatory obligations. Third parties may include:

   • the share registry, Boardroom Pty Limited;
   • technology support services;
   • auditors and insurers;
   • government and law enforcement agencies and regulators; and
   • entities established to help identify illegal activities and prevent fraud.

   We may also disclose your personal information to anyone authorised by you, or to whom you have provided your consent (either expressly or impliedly) or where another permitted general situation applies (as defined in Section 16A of the Privacy Act 1988 (Cth)).

   NGE does not sell, rent or trade personal information to, or with, third parties.

5. Storage and security
   We keep physical and electronic records of the personal information we gather at our premises and the premises of our services providers, which may include storage on the cloud.

   The security of your personal information is paramount to us and we use all reasonable endeavours to keep your information in a secure environment and to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us (see below).

   If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy, securely delete, or de-identify your personal information as appropriate.

6. Direct marketing
   We may use your personal information to keep you informed of company updates and reports. We may use an email address or other contact information you provide to us at any time for this purpose.

   You can opt out of receiving direct marketing material information from us at any time. You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you.

7. Accuracy of your information
   We take reasonable steps to ensure that the personal information held by us is accurate, complete and up to date. If you believe that any of your personal information is inaccurate, please contact us and we will take reasonable steps to correct it.
8. Third Parties and your information
   NGE’s website may link directly to websites operated by third parties (Linked Sites). You acknowledge that Linked Sites are not operated by us. We encourage you to always read the applicable privacy policy of any Linked Site. We are not responsible for the content or practices of the Linked Sites or their privacy policies regarding the collection, storage, use and dissemination of your personal information.
9. Variation and consent to variation
   We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy.
10. Access to your information and making a complaint
    You may request access to the personal information we hold about you. If you do so we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by contacting us as follows:

    By email: [email protected]
    By phone: +613 9648 2290

    In writing to:
    Company Secretary (Privacy Officer)
    NGE Capital Limited
    Level 4 North Building , 333 Collins Street
    Melbourne Vic 3000

    If you wish to make a complaint about a breach of the Privacy Act by us please contact our Privacy Officer who will try to resolve the matter within ten (10) working days. If we are unable to resolve the matter within that time, we will contact you or, if more appropriate, suggest the matter be referred to the Privacy Commissioner.