Our Commitment to Privacy

hCapital Pty Ltd (ACN 694 953 421) ("hCapital", "we", "us" or "our") is committed to protecting the privacy of personal information that we collect, hold, use and disclose. This Privacy Policy explains how we manage personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

hCapital currently operates as a Corporate Authorised Representative (CAR 001320011) of Eminence Global Asset Management Pty Ltd (AFSL 305573) (EGAM). Where hCapital provides financial services, it does so as an authorised representative on behalf of EGAM.

Purpose and Scope

This Privacy Policy applies to personal information collected by hCapital in connection with our business activities, including where we act as an investment manager, asset manager, financial services provider or otherwise deal with clients, prospective clients, investors, counterparties, service providers and other business contacts.

What is Personal Information?

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether it is recorded in a material form or not.

Some personal information may also be sensitive information under privacy law. We only collect sensitive information where reasonably necessary and permitted by law, including where you consent or where collection is otherwise authorised or required by law.

The Kinds of Personal Information We Collect

The kinds of personal information we collect depend on the nature of your dealings with us, but may include:

• name, date of birth and contact details;

• residential, postal and business address;

• telephone number and email address;

• employment, role and professional details;

• identification information and, where applicable, identity verification materials;

• bank account and payment details;

• investor, applicant, transaction and holding information;

• financial information, including personal financial statements, evidence of wholesale client status and tax file numbers;

• information relevant to AML/CTF, sanctions, fraud and compliance checks;

• beneficial owner, controller, trust, company and related party information;

• correspondence, enquiry, complaint and dispute-related information;

• where we provide lending or financing services, credit-related information including income verification, asset and liability declarations and credit history; and

• website, device, browser, IP address and usage information.

How We Collect Personal Information

We may collect personal information directly from you or from other persons or organisations connected with your dealings with us, including:

• when you contact us or provide documents or information to us;

• when you apply for or enquire about our services;

• from persons authorised to act on your behalf;

• from authorised intermediaries, trustees, administrators, registries, custodians and other service providers;

• from your employer, company, trust or other organisation with which you are associated;

• from professional advisers, referrers and business counterparties;

• from identity verification, compliance and due diligence providers; and

• from public sources, including regulatory and corporate searches, where permitted by law.

Why We Collect, Hold, Use and Disclose Personal Information

We collect, hold, use and disclose personal information for purposes including:

• providing financial and related services, including financial product advice, dealing in financial products and providing lending and financing services, to wholesale clients;

• managing and administering investments and assets on behalf of clients, including capital management, reporting, valuations and investor communications;

• onboarding, due diligence and account establishment;

• verifying identity, authority and wholesale client status;

• conducting AML/CTF, sanctions, fraud and other compliance checks;

• managing the employment relationship, including recruitment, payroll, performance management and workplace health and safety;

• risk management, governance, audit, legal and compliance functions;

• investigating incidents, complaints or suspected unlawful conduct; and

• complying with legal and regulatory obligations.

If you do not provide requested personal information, we may not be able to provide services, assess an application, respond to an enquiry or otherwise deal with you effectively.

How We Hold and Protect Personal Information

We may hold personal information in physical and electronic form, including in files, databases, email systems, document management systems and other business applications used by us.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps may include physical security measures, restricted access, password protections, multi-factor authentication, encryption of data in transit and at rest, staff training, confidentiality obligations and appropriate controls over service providers.

We also take reasonable steps to destroy or de-identify personal information when it is no longer needed for any permitted purpose, unless we are required or authorised by law to retain it.

Disclosure of Personal Information

We may disclose personal information for the purposes described in this Privacy Policy to:

• our related bodies corporate;

• trustees, custodians, registries, administrators, brokers, banks and payment providers;

• identity verification, screening, compliance and due diligence providers;

• technology, cyber security, communications and data storage providers;

• professional advisers, including lawyers, accountants, auditors, consultants and insurers;

• your nominated representatives, advisers, attorneys, agents or intermediaries;

• counterparties, lenders and their advisers, in connection with investment transactions;

• credit reporting bodies, where we provide lending services and are permitted to exchange credit-related information under the Privacy Act;

• regulators, law enforcement bodies, courts, tribunals and government agencies; and

• other persons where disclosure is permitted or required by law.

hCapital does not sell personal information to third parties. hCapital also does not disclose personal information to third parties so that they can market their own products or services to you.

Overseas Disclosure and Data Location

hCapital primarily operates in Australia and stores data using cloud-based systems. Where personal information may be stored on or transmitted through servers located outside Australia, we will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to that information.

If this position changes materially in the future, we will update this Privacy Policy and take reasonable steps required by applicable privacy law.

Website, Cookies and Analytics

When you visit our website, we or our service providers may collect technical and usage information such as your IP address, browser type, operating system, referring pages, pages viewed and general website interaction data.

We may use cookies and similar technologies to enable website functionality, improve website performance and security, and understand website traffic and usage patterns. You can usually manage cookies through your browser settings.

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those third-party websites.

Automated Decision-making

From 10 December 2026, the Privacy and Other Legislation Amendment Act 2024 (Cth) requires organisations to provide transparency about the use of automated processes in making decisions that substantially affect individuals.

hCapital does not currently use automated decision-making systems that make, or substantially assist in making, decisions affecting individuals' rights, entitlements or access to services. If we introduce such systems in the future, this Privacy Policy will be updated accordingly.

Our use of artificial intelligence tools for internal productivity, research and document preparation does not constitute automated decision-making affecting individuals within the meaning of the Privacy Act, as these tools assist our team in their work rather than making or substantially assisting in decisions about individuals.

Access to and Correction of Personal Information

You may request access to personal information we hold about you, and request correction of that information, by contacting us using the details below. We may need to verify your identity before processing your request.

There may be circumstances where we are permitted or required by law to refuse access or decline a correction request. If that occurs, we will provide reasons where required by law.

Australian Privacy Principles

Under the Australian Privacy Principles (APPs), you have certain rights regarding your personal information, including the right to:

• Access: Request access to the personal information we hold about you.

• Correction: Request that we correct any inaccurate or incomplete personal information.

• Opt-out of Marketing: Request that we stop sending you direct marketing communications.

• Complaints: Lodge a complaint with us if you believe we have breached the Australian Privacy Principles. You also have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC). To exercise these rights, please contact us using the contact details provided below. We may require you to verify your identity before processing your request.

Complaints

If you believe that we have breached the Privacy Act 1988 (Cth) or the Australian Privacy Principles, or you wish to make a privacy complaint, you may contact us using the details below.

Please provide as much detail as possible about the complaint, including your contact details, the relevant circumstances and the outcome you are seeking. We will investigate the complaint and respond as soon as practicable.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au).

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, legal obligations or technology. The current version of this Privacy Policy will be made available on our website.

Contact Us

If you have any questions about this Privacy Policy, wish to access or correct your personal information, or make a privacy complaint, please contact:

Privacy Officer

hCapital Pty Ltd

Email: info@hcapital.com.au

Website: www.hcapital.com.au

Last Updated:

April 2026