Privacy Policy

This policy explains how we collect, hold, use and disclose personal information, and how you can access it, correct it or make a complaint. It applies to personal information we collect through this website, through our advertising and social media channels, through enquiries and registrations of interest, through the investment process, and in the course of our business generally.

Grista Group deals only with wholesale and sophisticated investors, as those terms are used in the Corporations Act 2001 (Cth). Grista Investment & Asset Management Pty Ltd ABN 33 689 696 419 is a Corporate Authorised Representative (CAR 1319814) of Bentleys (QLD) Advisory Pty Ltd ABN 19 057 135 636, the holder of Australian Financial Services Licence 274444. Financial services are provided under that authorisation.

What we collect depends on how you deal with us. It generally includes your name, contact details, postal address, date of birth, identification documents, bank account details, and information about your investment objectives and experience. Where you invest through a company, trust or self managed superannuation fund, we also collect details of that entity and of its directors, trustees, beneficial owners and controllers.

The Corporations Act 2001 (Cth) and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) require us to collect certain information, including evidence of your identity and of your status as a wholesale or sophisticated investor. We also keep records of our dealings with you.

When you use this website or interact with our advertising or social media channels, we and our service providers also collect information about your device and activity. This includes your IP address, device and browser type, the pages you view, the links you click, the source that referred you to us, and your interactions with our advertisements and social media content. This information is collected using cookies, tracking pixels and similar technologies, as described in the Cookies, analytics and online advertising section below, and in some cases it is personal information.

We also obtain personal information from third-party data providers. This can include names, contact details, demographic and professional information, and indicators that a person may be eligible as a wholesale or sophisticated investor.

If you do not provide the information we ask for, we may not be able to respond to your enquiry, verify your identity, or accept an investment application.

Wherever it is reasonable and practicable, we collect personal information directly from you, through this website, our forms, email, telephone and meetings. We may also collect it from your financial adviser, accountant or lawyer, from identity verification services, from referrers and introducers, from our unit registry provider, from licensed third-party data providers and list suppliers, and from publicly available sources. We also collect information automatically through cookies, tracking pixels and similar technologies when you use this website or interact with our advertising and social media channels.

We collect, hold and use personal information to:

• respond to enquiries and registrations of interest
• provide information about investment opportunities, including information memoranda and offer documents
• assess whether you are eligible to receive an offer as a wholesale or sophisticated investor
• process applications, maintain the unit register, pay distributions and administer your investment
• meet our obligations under the Corporations Act 2001 (Cth), the anti-money laundering and counter-terrorism financing regime, taxation law and other applicable laws
• identify and contact people who may be interested in our investment opportunities, and deliver, target and measure our advertising
• send communications you have asked for, and improve this website and our services

We may disclose personal information to:

• Bentleys (QLD) Advisory Pty Ltd as the holder of the Australian Financial Services Licence under which we are authorised
• the trustee, custodian, unit registry and fund administrator for a trust in which you invest or propose to invest
• our professional advisers, agents, contractors and service providers, including identity verification providers
• providers of analytics, advertising and social media services, and participants in the programmatic advertising ecosystem, including advertising platforms, exchanges and measurement and verification providers, in connection with the activities described in the Cookies, analytics and online advertising section of this policy
• your financial adviser, accountant or other representative, where you have authorised this
• regulators and government agencies, including AUSTRAC, the Australian Securities and Investments Commission and the Australian Taxation Office
• the Australian Financial Complaints Authority, where a complaint is referred to it
• any other person where you have consented, or where the disclosure is required or authorised by law

We do not sell personal information. Where we use third-party analytics and advertising services, those providers receive information about your online activity as described in the Cookies, analytics and online advertising section and may use it in accordance with their own privacy policies. Beyond this, we do not disclose personal information to third parties for their own marketing.

We regard the security of your personal information as a priority. We take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Those steps include restricting access to the people who need the information for their role, multi-factor authentication, encryption, and requiring our service providers to keep your information confidential and use it only for the purposes for which they are engaged.

No method of transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

Some of the platforms and service providers we use are located outside Australia, or store, process or access information outside Australia. Personal information we hold may therefore be disclosed to, or accessible from, overseas locations.

This applies to:

• The platform that hosts the enquiry and registration of interest forms on this website, which stores information in the United States. Information you provide through those forms is held outside Australia from the point at which you submit it.
• The providers of analytics, advertising and social media services, as described in the Cookies, analytics and online advertising section, including Google, Meta and LinkedIn. These platforms may also pass information to other advertising companies they work with. These providers operate global infrastructure. Information may be stored or processed in the United States and other countries in which those providers, or their sub-processors, operate.

Our document storage is hosted in Australia.

Where a provider operates a global network, it is not always practical for us to specify every country in which information may be stored or accessed, because the provider may move data between facilities and may engage sub-processors in other locations. Where we know that is the case, we have said so.

If you would like to know what we are able to tell you about where information about you is held, please contact us at info@gristagroup.com.au.

Before disclosing personal information overseas, we take reasonable steps to ensure the recipient handles it in a way consistent with the Australian Privacy Principles.

That includes putting confidentiality, security, and use restrictions in our agreements and choosing providers with recognised data protection and security standards. These obligations apply whether or not we can identify the country in which the recipient holds the information.

We may send you information about investment opportunities, market updates and events where you have asked to receive it or have consented to receive it. Every marketing communication includes a simple way to opt out. You may also opt out at any time by emailing info@gristagroup.com.au

Marketing communications are sent in accordance with the Spam Act 2003 (Cth) and, where they apply to us, the direct marketing requirements of the Australian Privacy Principles.

Our marketing also includes online advertising targeted to you based on your previous interactions with our website, our advertisements and our social media channels. You can opt out of this form of advertising using the methods described in the Cookies, analytics and online advertising section, in addition to the opt-out included in every direct communication.

Some of our marketing uses information obtained from third-party data providers, sometimes combined with information about how people have interacted with our website, advertising and social media channels. Where we contact you using information obtained from a third party, the communication will include a prominent statement about how to opt out, and you may ask us to tell you the source of your information.

This website uses cookies and similar technologies, including tracking pixels and tags provided by third parties. Cookies are small files placed on your device. Pixels and tags are small pieces of code that send information about your activity to the provider’s servers.

We use these technologies to help the website function, to analyse how it is used, and for advertising. Our advertising includes measuring the performance of our campaigns, showing you our advertisements on other websites and on social media platforms based on your previous interactions with our website and our social media channels (sometimes called retargeting), and buying advertising space across websites and apps through automated (programmatic) advertising platforms, currently including Google Display & Video 360. To select who sees our advertisements, we may share audience information with these platforms, including information described in the Combining information section of this policy.

The providers of these technologies, currently including Google (including Google Analytics and Google Marketing Platform), Meta and LinkedIn, receive information about your activity when you visit our website or interact with our content. Those providers may use that information for their own purposes in accordance with their own privacy policies, including to improve their services and to combine it with other information they hold about you.

Delivering advertising programmatically involves other participants in the advertising ecosystem, such as advertising exchanges, publishers, and measurement and verification providers. These participants receive limited technical information, such as an advertising identifier, IP address, approximate location and details of the page or app where an advertisement may appear and handle it in accordance with their own privacy policies.

We may also provide contact details, in hashed form, to advertising platforms so that we can show our advertisements to existing contacts and to audiences with similar characteristics.

You can limit interest-based advertising by adjusting your browser settings to refuse cookies, by using the advertising preference and opt-out tools offered by the platforms themselves (such as Google’s My Ad Centre), and through the industry opt-out tool at youradchoices.com.au. Parts of the website may not work as intended if you refuse cookies.

This website may contain links to other websites. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy policies.

We may combine information obtained from data providers with information we hold or collect ourselves, including behavioural information collected through our website, our advertising and our social media channels. We do this to better understand our audience, to identify people who may be interested in our investment opportunities, and to make our marketing more relevant. If we contact you using information obtained from a third party, you may ask us where we obtained it, and you may opt out of further marketing at any time.

We may use software, including artificial intelligence features, to help sort, summarise and route information you provide to us. We do not use automated processes to make decisions about you that have a legal or similarly significant effect. Decisions about eligibility and investment applications are made by our people.

We keep personal information only for as long as we need it, and for as long as the law requires.

Records relating to an investment, and records created for customer identification and verification, are kept for at least seven years, consistent with obligations under the Corporations Act 2001 (Cth) and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Some records are kept for longer where a legal, insurance or regulatory reason requires it.

Where an enquiry does not proceed, we keep the information for a reasonable period and then destroy or de-identify it.

You may ask for access to the personal information we hold about you, and you may ask us to correct it. Requests should be made in writing to info@gristagroup.com.au.

We will acknowledge your request within five business days and respond within 30 days. We may need to verify your identity before releasing information. There is no charge for making a request.

Access may be limited in some circumstances, for example where releasing the information would unreasonably affect another person’s privacy, or where the law requires or authorises us to refuse. Where we limit access, we will explain why.

Where we suspect that an eligible data breach may have occurred, we will assess the incident and, where required under the Notifiable Data Breaches scheme, notify affected individuals and the Office of the Australian Information Commissioner.

If you are concerned about how we have handled your personal information, please contact us at info@gristagroup.com.au. We will acknowledge your complaint within five business days, look into it, and respond within 30 days.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at oaic.gov.au, by telephone on 1300 363 992, or in writing to GPO Box 5218, Sydney NSW 2001.

Where your complaint relates to financial services provided under the authorisation described above, we notify Bentleys (QLD) Advisory Pty Ltd as licensee and work with them to resolve it. Bentleys (QLD) Advisory Pty Ltd is a member of the Australian Financial Complaints Authority (AFCA), an independent external dispute resolution scheme. If your complaint is not resolved to your satisfaction, you may refer it to AFCA.

Questions about this policy, and requests or complaints under it, should be sent to info@gristagroup.com.au.

Grista Group, Level 1, 11/65 James Street, Fortitude Valley QLD 4006.

We may update this policy from time to time. The current version is available at gristagroup.com.au. This policy is reviewed by 1 September 2028, and every two years after that, or earlier if there is a change in law, systems or our operations.