Privacy Policy

This policy explains what personal information we collect through this website and in the course of our business, why we collect it, how we hold and share it, and how you can access or correct it or make a complaint. It is written to comply with Australian Privacy Principle 1 (APP 1) under the Privacy Act 1988 (Cth).

1. Who we are

In this policy, “Twynam”, “we”, “us” and “our” means Twynam Funds Management Pty Ltd ACN 665 482 119 and its related bodies corporate in the Twynam group, including the entities that carry on the group's agricultural and property operations. Twynam Funds Management Pty Ltd is a corporate authorised representative (CAR Number 1302016) of Boutique Capital Pty Ltd AFSL 508011(Boutique Capital). Where we handle personal information in providing financial services, Boutique Capital may also hold or have access to that information as our licensee.

2. What we collect

We collect personal information you choose to give us through this website and in dealing with us. Depending on how you interact with us, this may include:

• Contact form: your name, email address, organisation and the content of your message.
• Founder pitch form: your name, email address, company name, a description of your business and technology, and any links or documents you provide.
• Investor enquiry: your name, email address, organisation, the nature of your enquiry, and your self-declaration as to whether you are a wholesale client within the meaning of sections 761G or 761GA of the Corporations Act 2001 (Cth). If you proceed to invest, we and Boutique Capital will collect additional identification and financial information required by law; that collection is covered by the offer documents you receive at the time.
• Report requests: your name, email address, organisation and the research report requested.
• Newsletter subscription: your email address and, where you provide it, your name.
• Website analytics: aggregated, de-identified technical information such as page views, referrers, country, device type and page performance timings. See section 5.

We do not ask for sensitive information (such as health, political or religious information) through this website. Please do not include it in a message to us.

3. Why we collect it

We collect, hold and use personal information to:

• respond to your enquiry, pitch or request and communicate with you about it;
• assess investment opportunities you bring to us;
• verify that any offer of interests in Twynam funds is made only to wholesale clients, and otherwise meet our obligations under the Corporations Act 2001 (Cth) and the conditions of Boutique Capital's licence;
• send you the research or fund documents you have asked for;
• send you our newsletter, where you have subscribed;
• keep records we are required by law to keep; and
• operate, secure and improve this website.

We only use your information for the purpose for which it was collected, for a related purpose you would reasonably expect, or as otherwise permitted or required by law. We do not sell personal information.

4. How we store and share it

We hold personal information in secure, access-controlled systems operated by us and by third-party service providers acting on our instructions. We take reasonable steps to protect it from misuse, interference, loss and unauthorised access, modification or disclosure, including encryption in transit and at rest, access limited to staff who need it, and bot protection on our forms.

The service providers that process personal information collected through this website are:

We may also disclose personal information to:

• Boutique Capital, as our AFS licensee, for compliance monitoring and record-keeping;
• our professional advisers, including lawyers, accountants and auditors;
• related bodies corporate in the Twynam group where needed to respond to your enquiry; and
• regulators, law enforcement or courts where required or authorised by law.

Overseas disclosure

Because the providers listed above operate infrastructure outside Australia, personal information collected through this website is likely to be stored or processed in the United States and, for newsletter data, the European Union. Before disclosing personal information overseas we take reasonable steps to ensure the recipient handles it in a way consistent with the Australian Privacy Principles, including relying on the provider's contractual data-protection commitments. By submitting information through this website you acknowledge that it may be transferred to these locations.

5. Analytics and cookies

We use Vercel Web Analytics and Vercel Speed Insights to understand how the site is used and how it performs. Both are cookieless: they do not set cookies, do not use persistent identifiers, and do not track you across other websites. The data we receive is aggregated and cannot be used by us to identify you. For this reason the website does not display a cookie consent banner.

Cloudflare Turnstile protects our forms from automated abuse. To do so it may process technical information about your browser and device when you submit a form. This is used only to distinguish people from bots.

Links to third-party websites (for example LinkedIn, Instagram or DocSend) are subject to those sites' own privacy policies.

6. How long we keep it

• Investor enquiries and related records: 7 years from our last dealing with you, in line with financial services record-keeping requirements.
• Contact, pitch and report requests: for as long as needed to deal with your enquiry and for a reasonable period afterwards, unless the record must be kept for the period above.
• Newsletter subscriptions: until you unsubscribe. Every mailing includes an unsubscribe link, and you can also email us to be removed.
• Analytics data: held only in aggregated form by Vercel and not linked to you.

When we no longer need personal information for any purpose for which it may be used or disclosed, we take reasonable steps to destroy or de-identify it.

7. Access and correction

You may ask us for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete or misleading. Email us at mail@twynam.com with “Privacy request” in the subject line. We will respond within a reasonable period, usually within 30 days, and will not charge you for making a request. In limited circumstances the law allows us to refuse access or correction; if that applies we will tell you why in writing and how you can complain about the decision.

8. Complaints

If you believe we have mishandled your personal information, please tell us. Our complaints page explains how to lodge a complaint and what to expect, including how to escalate to Boutique Capital. We will acknowledge a privacy complaint promptly and aim to resolve it within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

9. Contact

Privacy enquiries, requests and complaints should be directed to:

Twynam Funds Management Pty Ltd
Attention: Privacy
226 Liverpool St, Darlinghurst, NSW 2010
mail@twynam.com

We may update this policy from time to time. The current version is always published at this address, with the date it was last updated shown at the top of the page.