Who we are
This policy applies to Wahl Citadel Pty Ltd (ACN 663 558 709, AFSL 565935) (Wahl Citadel, we, us), including in its role as trustee of the Wahl Citadel funds, and to this website, wahlcitadel.com.
What we collect
We collect personal information you give us directly, including when you:
- send an enquiry through our website: your name, mobile number, email address and message;
- request an investment document: your name, email address, mobile number, whether you are an existing investor, and your confirmation that you are a wholesale or sophisticated investor;
- invest in one of our funds: identification and verification information required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), contact and bank details, and your tax file number if you choose to provide it.
When you use our website we also collect technical information automatically: your IP address, browser and device type, the pages you visit and how you arrived at them. See “Cookies and analytics” below.
You can contact us without giving your name, but we usually cannot respond to an enquiry or provide investment documents without contact details.
How we use it
- to respond to your enquiry and send documents you request;
- to assess whether an investment opportunity can be offered to you, including your wholesale status;
- to administer your investment, report to you and pay distributions;
- to meet our legal and regulatory obligations, including under the Corporations Act 2001 (Cth) and anti-money laundering and tax laws;
- to tell you about investment opportunities that may interest you, where you have agreed to this;
- to protect our website from spam and misuse, and to understand how it is used so we can improve it.
Tax file numbers are only collected, used and disclosed as permitted by tax law and the Privacy (Tax File Number) Rule 2015. You can ask us to stop sending you marketing at any time.
Who we share it with
We do not sell personal information. We share it only as needed with:
- our fund administrators, registry, auditors, accountants and legal advisers;
- service providers who run our website and communications: Vercel (website hosting), Resend (email delivery) and Google (Google Workspace, Google Analytics and reCAPTCHA spam protection);
- regulators, government agencies and others where the law requires or permits it.
Overseas disclosure
Some of our service providers, including Vercel, Resend and Google, store or process information outside Australia, mainly in the United States. We take reasonable steps to ensure they handle it consistently with the Australian Privacy Principles.
Cookies and analytics
Our website uses Google Analytics to understand how visitors use the site. It sets cookies and collects information such as pages viewed, approximate location and device type. It does not tell us who you are. Our forms use Google reCAPTCHA, which assesses whether a submission comes from a person and is subject to Google’s Privacy Policy and Terms of Service. You can block or delete cookies in your browser settings, or install the Google Analytics opt-out browser add-on.
Storage and security
We store personal information electronically with reputable providers and take reasonable steps to protect it from misuse, loss and unauthorised access. Investment documents are sent by email; any download links we include are personal and expire. We keep information only as long as we need it, or as long as the law requires, and then securely delete it.
Access and correction
You can ask to see the personal information we hold about you, or ask us to correct it, by emailing hello@wahlcitadel.com.au. We will respond within a reasonable time, usually 30 days. If we refuse, we will tell you why.
Complaints
If you have a concern about how we have handled your personal information, please email hello@wahlcitadel.com.au or write to us at Level 30, South Tower, Rialto Building, 525 Collins Street, Melbourne VIC 3000. We will acknowledge your complaint and aim to resolve it within 30 days. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner at oaic.gov.au.
Changes to this policy
We may update this policy from time to time. The current version is always on this page. See also our Terms and Conditions.