Privacy
Privacy Policy.
How Deployable Energy Fund Limited and its manager, Deployable Energy Funds Management Pty Ltd, collect, use, hold and disclose personal information.
1. Who we are
This policy covers Deployable Energy Fund Limited (ACN 701 609 387) (the Fund) and Deployable Energy Funds Management Pty Ltd (ACN 701 592 350) (the Manager), together "we", "us" and "our". We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
2. What we collect
To view or download our information documents, we require your first name, last name and email address and ask you to verify access to that email account. Organisation and phone are optional. We record verification times and the document, edition, access action, time, source page and copy reference. We also keep limited technical records needed to prevent misuse and maintain the service.
We collect personal information you provide to us, including: name and contact details; details of your investing entity (company, trust or SMSF); information needed to verify wholesale-client status (such as an accountant's certificate and supporting financial information); identity-verification information required by anti-money-laundering and counter-terrorism financing (AML/CTF) law; tax residency information (including US-person status); and correspondence with us.
The Expression of Interest, enquiry and referring broker forms on this website send the details you enter to our customer relationship management system, HubSpot, operated by HubSpot, Inc., which may store them on servers outside Australia. If you tick the optional updates box, we record that consent and you can unsubscribe at any time. The MSC application form is a separate, MSC-hosted Snapforms workflow: information entered there is handled through MSC and its service providers under the notices and consents in that form.
3. Why we collect it
We use document-access information to verify email access, deliver the requested documents, maintain an access history, support enquiries and protect the service. Requesting a document does not submit an investment application, establish investor eligibility or subscribe you to marketing.
We collect and use personal information to: respond to enquiries and expressions of interest; onboard referring brokers; verify investor eligibility and identity before applications are accepted; send updates you have asked for; comply with our legal obligations (including the Corporations Act 2001 (Cth), AML/CTF law, and tax law including FATCA/CRS); process applications, maintain the share register and provide investor reporting; and administer the Fund.
4. Who we disclose it to
Our document-access service uses Vercel for website hosting, Supabase for its access database and private document storage, Microsoft 365 for verification emails and internal notifications, and HubSpot for relationship and activity records. The Manager receives notifications of verified document access. Some providers may process information outside Australia, even where a regional hosting location is selected.
We may disclose personal information, where necessary for the purposes above, to: the AFSL licensee under whose authorisation financial services are provided; Melbourne Securities Corporation Ltd in its licensed-intermediary role and its onboarding and identity-verification providers; MSC Abacus Pty Ltd (ACN 630 730 684), the Administrator and registry provider; our professional advisers (legal, accounting, audit); technology providers, including HubSpot and our website host; and regulators or law-enforcement bodies where required by law. We do not sell personal information. Some service providers may store information on servers located overseas; where that occurs we take reasonable steps to ensure comparable privacy protections apply.
5. How we hold and protect it
We mark issued document copies with the supplied name, verified email address, file version, issue date and a copy reference. We remove unverified registration data within 24 hours, subject to service recovery if an interruption occurs. Temporary server copies are removed after the session ends or expires, normally within one hour. We review identifiable document-access history after 12 months and delete information no longer needed, subject to an existing relationship, legal obligation or documented hold. This review includes our document-access notes in HubSpot; it does not automatically delete unrelated contact or investor records. Separate investor, compliance and correspondence records remain subject to their applicable retention requirements.
Personal information is held in access-controlled systems used by the Manager, with eligibility and compliance records retained for the periods required by law (generally seven years). We take reasonable steps to protect information from misuse, interference, loss and unauthorised access.
6. Access, correction and complaints
You may request access to, or correction of, the personal information we hold about you by emailing info@defl.com.au. If you believe we have breached the APPs, contact us first and we will respond within a reasonable period. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
7. Cookies and analytics
Necessary verification, session and document-access records operate separately from optional analytics. We do not include verification codes, session secrets or recipient markings in advertising or analytics events.
This website uses Google Analytics, provided by Google LLC, to understand how visitors use the site: for example, which pages are viewed, how visitors arrive and their approximate location (city or region). Google Analytics uses cookies and does not store full IP addresses. We use this information in aggregate to improve the website and our communications. We do not use Google Analytics to identify you, and we do not share Google Analytics data for advertising. Google may process this information outside Australia, including in the United States. You can opt out with Google’s browser add-on at tools.google.com/dlpage/gaoptout or by blocking cookies in your browser.
This website also uses the LinkedIn Insight Tag, provided by LinkedIn, to measure the results of our LinkedIn advertising and to show our LinkedIn ads to people who have visited this site. The tag uses cookies and collects technical information such as the pages viewed, the referring page, IP address, device and browser details and the time of the visit. LinkedIn may match this information to LinkedIn member accounts. We receive only aggregated reports and audience counts, not the identity of individual visitors, and the contents of forms on this website are not sent to LinkedIn. If you submit a DEFL lead form on LinkedIn, the details you provide in that form are passed to us and recorded in our HubSpot CRM so that we can respond to you. LinkedIn may process this information outside Australia, including in the United States and Ireland. LinkedIn members can control how LinkedIn uses this information for advertising in their LinkedIn advertising data settings, and anyone can block or delete these cookies in their browser settings.
HubSpot page tracking is not enabled on this website. We use HubSpot, provided by HubSpot, Inc., as our customer relationship management system to record information submitted through our Expression of Interest, enquiry and referring broker forms, together with verified document-access activity. These records include contact details and information about the documents and editions requested for viewing or downloading.
These records help us respond to enquiries and administer document access; they are separate from tracking general browsing activity on this website. Requesting a document does not subscribe you to marketing communications. HubSpot may process this information outside Australia.
The website forms record the page from which they are submitted. MSC's externally hosted onboarding form is governed by the notices and consents displayed in that form.
8. Changes
We may update this policy from time to time. The current version, with its date, is always published on this page.