Privacy Policy

Effective date: 18 August 2026 · Last updated: 25 August 2026

1. About this policy

Ferguson Hyams Investment Management Pty Ltd (ACN 611 059 940, AFSL 490023) (“Ferguson Hyams”, “we”, “us”) is committed to protecting your personal information. This policy explains how we collect, hold, use and disclose personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). It applies to our websites, our fund, and our dealings with investors, advisers and other contacts.

2. What we collect

Depending on your dealings with us, we may collect: your name and contact details; the organisation you represent and, for financial advisers, your AFSL details; information needed to assess wholesale or sophisticated investor eligibility; identity verification information required by law; tax-related identifiers you choose to provide; bank account details for distributions and redemptions; details of your investment and transactions; records of your communications with us; and technical information collected automatically when you use our websites.

We do not generally collect sensitive information. We collect government-related identifiers only where required for identity verification or tax purposes, and use them only for those purposes.

3. How we collect it

We collect personal information directly from you when you complete a form on our websites, contact us by phone or email, or meet with us. We may also collect information from your financial adviser or accountant acting on your behalf, from identity verification and screening services, from the platform through which you invest, and from our registry provider and custodian, Keystone Private.

4. Why we collect and use it

We collect, hold and use personal information to respond to enquiries; assess investor eligibility; process and administer investments; verify identity and comply with legal obligations; communicate with investors and advisers; improve our websites and services; and, where you have not opted out, provide relevant fund updates. You can opt out of marketing communications at any time using the unsubscribe link in any message or by contacting us.

5. Who we disclose it to

We disclose personal information, where necessary, to our registry provider and custodian; investment platforms; identity verification and screening providers; auditors, insurers and professional advisers; representatives you authorise; regulators and government agencies; HubSpot; consented advertising and analytics platforms; and IT, hosting and software providers operating under confidentiality obligations.

If you are located outside Australia, information you submit will be transferred to and processed by Ferguson Hyams in Australia. Some service providers store or access data outside Australia, including HubSpot and analytics providers in the United States, Swissquote in Switzerland, Utmost in Ireland and Clearstream in Luxembourg. Where required, transfers are protected by safeguards applicable to the relevant provider and jurisdiction.

We do not sell personal information.

6. Cookies and website analytics

Our websites use essential storage to operate and remember choices. Optional Google Tag Manager and the analytics or advertising services configured through it load only after you consent. These services may collect technical information such as IP address, device and browser type, pages viewed and referral source. You can manage or block cookies through your browser settings, or reopen Cookie preferences from the footer to withdraw analytics consent; some site features may not function without them.

When you accept the “Accessing this website” acknowledgement, we store an essential ISO timestamp under disclaimerAcceptedAt in your browser’s local storage. It is used only to remember the acknowledgement for 24 hours, is not sent to us or a third party, and does not enable or record analytics. If the timestamp is missing, invalid, in the future or at least 24 hours old, the acknowledgement is shown again. Clearing or blocking local storage may therefore cause it to appear more often.

7. Storage, security and retention

We hold personal information in electronic systems maintained by us and our service providers, protected by technical and organisational measures appropriate to its sensitivity. We retain information for as long as needed for the purposes described and to meet legal obligations. When information is no longer required, we take reasonable steps to destroy or de-identify it. If a data breach is likely to result in serious harm, we will make notifications required by the Notifiable Data Breaches scheme.

8. Access and correction

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date or incomplete, by contacting us using the details below. We will respond within a reasonable period. In limited circumstances the law allows us to refuse access; if so, we will tell you why in writing.

9. Complaints

If you have a concern about how we have handled your personal information, please contact us first. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (opens in a new tab) or call 1300 363 992.

10. Changes to this policy

We may update this policy from time to time. The current version will always be available on this page, with its effective date shown above.

11. Contact us