PRIVACY
Last updated on March 31, 2026
1. Introduction Manly Real Estate Investments Pty Ltd (ABN 55 161 840 437) trading as Manly Private Wealth ('we', 'us', 'our') is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and disclose your personal information in accordance with the Privacy Act 1988 (Cth) ('Privacy Act') and the Australian Privacy Principles ('APPs'). By using our website, submitting an enquiry, or providing us with your personal information, you consent to the collection and use of your information as set out in this Policy.
2. What Information We Collect We may collect the following types of personal information: • Contact details: your name, email address, phone number, and postal address • Financial information: details about your income, assets, and investment experience, where relevant to assessing your suitability as an investor • Identity information: copies of identification documents required under our Know Your Customer (KYC) and Anti-Money Laundering (AML/CTF) obligations • Communication data: records of correspondence between you and us, including emails and notes from phone calls or meetings • Website usage data: information collected automatically when you use our website, such as IP address, browser type, and pages visited (see Section 9 on Cookies)
3. How We Collect Your Information We collect personal information in the following ways: • Directly from you when you submit an enquiry form or register your interest on our website • Via email, telephone, or in-person conversations • Through our CRM and marketing platform (GoHighLevel — see Section 7) • From third parties such as accountants or legal advisers, where required for investor verification
4. Why We Collect and Use Your Information We collect and use your personal information to:
• Respond to your enquiries and communicate with you about investment opportunities
• Assess your suitability and eligibility as an investor in our Trust
• Comply with our legal obligations under the Corporations Act 2001 (Cth) and the AntiMoney Laundering and Counter-Terrorism Financing Act 2006 (Cth)
• Send you investment updates, quarterly reports, and other information relevant to your participation in the Trust
• Send you general marketing communications about Manly Private Wealth, where you have consented to receive these • Improve our website and the services we offer
5. Sharing Your Information We may disclose your personal information to:
• Our professional advisers, including accountants and legal advisers, for the purposes of administering the Trust
• Commonwealth Bank of Australia, in connection with the Trust's banking arrangements
• ASIC, ATO, or other regulatory bodies, where required by law
• Third-party service providers who assist us in operating our business (including GoHighLevel as our CRM and marketing platform — see Section 7) We do not sell your personal information to third parties. We do not share your information with other parties for their own marketing purposes.
6. Data Storage and Security We take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification, or disclosure. Your data is stored securely using password-protected systems and encrypted cloud storage. We retain your personal information for as long as is necessary to fulfil the purposes described in this Policy, or as required by law. Where information is no longer needed, we take reasonable steps to destroy or de-identify it.
7. Overseas Disclosure — GoHighLevel We use GoHighLevel (headquartered in the United States) as our CRM and email marketing platform. As a result, some of your personal information may be stored on servers located outside Australia. By providing your personal information to us, you consent to this overseas disclosure. We have taken reasonable steps to ensure that GoHighLevel maintains privacy standards consistent with the APPs. However, you should be aware that we are not able to ensure that overseas recipients will comply with the APPs in all cases, and you may not have access to the same rights of redress available under Australian law.
8. Marketing Communications and Opt-Out If you subscribe to our waitlist or otherwise consent to receiving marketing communications, we may send you updates, educational content, and information about investment opportunities from time to time. You can opt out of marketing emails at any time by clicking the 'Unsubscribe' link in any email we send, or by contacting us directly at [email protected]. Opting out will not affect communications we are required to send you in connection with any investment you have made.
9. Cookies and Website Tracking Our website may use cookies and similar tracking technologies to improve your browsing experience and to understand how visitors interact with our site. Cookies are small data files stored on your device. You can control the use of cookies through your browser settings. However, disabling cookies may affect the functionality of our website.
10. Your Rights — Access and Correction Under the Privacy Act, you have the right to: • Request access to the personal information we hold about you
• Request correction of information that is inaccurate, out of date, incomplete, or misleading
• Make a complaint if you believe we have breached the APPs To exercise any of these rights, please contact us using the details below. We will respond to your request within a reasonable time — generally within 30 days.
11. Complaints If you have a complaint about how we have handled your personal information, please contact us in the first instance. If we are unable to resolve your complaint to your satisfaction, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
12. Changes to This Policy We may update this Privacy Policy from time to time. The current version will always be available on our website. Material changes will be communicated to existing investors directly.
13. Contact Us If you have any questions about this Privacy Policy or how we handle your personal information, please contact:
Manly Real Estate Investments Pty Ltd (trading as Manly Private Wealth)
Director: Anthony Manly
Email: [email protected]
Phone: 0435 954 890
Postal: PO Box 2426, Taren Point NSW 2229