The following Privacy Policy for Lakehouse Capital Pty Ltd ACN 614 957 603, AFSL 526842 (“Lakehouse Capital”, “we,” “us” or “our”) sets out Lakehouse Capital’s current data processing practices including how we collect, hold, use and disclose your personal information. If you have any queries or concerns regarding these practices, please contact us via email at [email protected].
We know that while you as investors (i.e., “you”) are entrusting us to manage your money, you are also entrusting us with the privacy and security of your personal information. We take that trust seriously.
Lakehouse Capital is the investment manager of the Lakehouse Small Companies Fund and the Lakehouse Global Growth Fund (together “the Funds”). Equity Trustees Limited (ACN 004 031 298, AFSL number 240975) (EQT) is the Funds’ Responsible Entity. If you are an investor in the Fund(s), please read this Privacy Policy in conjunction with EQT Privacy Policy.
The Information We Collect
- Subscribe: When you subscribe on our website, we ask for your first name, last name, email address, and the type of investor you are. By subscribing you agree to receive email communications from Lakehouse Capital
- Registering your interest: When you register your interest on our website, we ask for your first name, last name, email address, phone number, type of investor you are and your potential investment size.
- Information we automatically track: While on Lakehousecapital.com.au, we automatically log certain information about how you’re using our site. This information may include the URL that you just came from, your internet protocol (IP) address and the pages you visit while on our site. Lakehouse Capital may place a pixel on pages on our site or those of other companies that are presenting advertisements. This enables us to record in our server logs that a specific user ID has visited a particular page. This data allows us to analyse and determine our audience’s behavioural characteristics, which helps us to optimise our site, advertisement placements, and marketing focus. Only anonymous, non-personally identifiable information is collected in this way, and it cannot, by itself or in combination, be tracked to a specific individual.
- Surveys: On occasions we conduct surveys and we collect the answers provided.
Where Your Information is Stored
Your personal information (as outlined above) is processed and stored by Lakehouse who may use 3rd party applications to assist with this including for communication and marketing purposes. Use of such 3rd party applications to process data may involve data being stored on servers outside of Australia. All data stored by 3rd parties is held securely for the exclusive use of Lakehouse Capital and for the purposes outlined below. By providing your personal information you consent to this transfer and usage.
Our Use of this Information
- Provide Our Services: Lakehouse Capital use your information to deliver, and provide access to the information and features that you have registered for, or otherwise requested. We also use your information for administrative purposes such as customer support. When necessary, we will use your information to investigate any complaints or possible violations of our Terms of Service.
- Internal Research: Cookies and the other information we automatically track are used to help us better understand how our audience uses our site as well as for internal research on users’ demographics and interests. Each browser accessing Lakehouse Capital is given a unique cookie which is then used to determine usage patterns and to help in targeting content based on user interests.
- To Contact You: We may subsequently email you about our products and services, or other products and services we feel may interest you. If you’d rather not receive these marketing communications, unsubscribe here.
Use of IP Addresses and Cookies
IP Addresses
Your Web browser or email application automatically provides your IP address to other computers with which you communicate over the Internet so that they know where to send you information.
We receive an IP address each time you view one of our Web pages because the browser automatically reports it to us. We also may store the IP address when you register with Lakehouse Capital.
We may use IP addresses for various purposes, including:
- Diagnosing service or technology problems.
- Assessing and maintaining system security.
- Studying how people use our site and how we can improve it.
Cookies
If your browser is set up to accept them, we also use a feature known as a cookie. Cookies contain bits of information that Web sites transfer to your computer’s hard drive for record-keeping purposes. Cookies can make the Web more useful by storing information about your preferences on a particular site such as ours.
At Lakehouse Capital cookies are primarily used in the following ways:
- To automatically access your previously stored account information, so that we don’t ask for your information multiple times.
- To estimate our audience size and usage patterns.
In addition, if you provide us with your email address anywhere on the site, we may place a cookie on your device that temporarily stores your email address. We may use this information to subsequently contact you. Most browsers are set up to accept cookies, but you can configure your browser to refuse cookies or to notify you when you’ve received one.
Information Sharing and Disclosure
Except as set out in this Policy, Lakehouse Capital does not disclose, give, lend or sell your personal information to any third party. We only provide aggregate, non-identifiable information to our current and prospective business partners.
We may share personal information about you as follows:
- We may provide information to the Fund’s Responsible Entity or other service providers that otherwise help service or administer the Fund or third party providers that aid in certain aspects of our operations (such as distribution of our email products). Our service providers must agree to use the personal information we share with them only to provide the services we specify. Some of these providers may be located overseas including the United States.
- We may provide information to government agencies, other regulatory bodies, and law-enforcement officials (for example, for tax purposes or for reporting suspicious transactions).
- We may disclose your personal information to protect our rights or property, or our safety or that of others.
Security
Lakehouse Capital and its associates take reasonable steps to ensure that your personal information is protected from misuse, interference and loss and from unauthorized access, modification and disclosure. While we do our best to protect your personal information, Lakehouse Capital and its associates cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. What does all this mean? Just as in the investing world, you must protect yourself. You are responsible for maintaining the secrecy of any passwords and account information you reveal on the internet.
Access to Your Information
In accordance with the Australian Privacy Principles, upon written request, Lakehouse Capital will (other than as permitted by law) provide you access to the personal information we hold about you as well as grant you the opportunity to correct any incorrect personal information. If your access request is denied, we will give you the reasons for denying your request. You can submit your request to [email protected], or:
Privacy
Lakehouse Capital
GPO Box 498
Sydney NSW 2001
Complaints
While we always endeavour to get things right, we accept that we can get things wrong. If you have a complaint regarding your privacy you may make a complaint to us and we will investigate your concerns as soon as possible. To make a complaint, please contact us at [email protected], or:
Privacy
Lakehouse Capital
GPO Box 498
Sydney NSW 2001
If you are not satisfied with our handling of your complaint, you may complain to the Privacy Commissioner.
Other Parties Collecting Information
If you follow or click on links to any third party websites from www.lakehousecapital.com.au, you should be aware that these other sites have their own privacy and data processing practices. Lakehouse Capital and its associates have no responsibility or liability for these independent policies. For more information regarding a site and its privacy policies, check that site.
Changes to this Privacy Policy
Lakehouse Capital and its associates may amend this Privacy Policy from time to time. If we make any substantive changes to this policy, we’ll announce it on our site. Your continued use of our website, services or provision of further personal information to us once you have been notified of the revised Privacy Policy constitutes your deemed acceptance of the revised Privacy Policy.
Effective: 11 November 2016
Last Reviewed: 01 October 2023
