Privacy policy
Who are we?
For the purposes of this Privacy Policy, the words “Supra”, “we”, “our” and “us” refer to Supra Capital Limited ACN 112 331 361 and its related entities.
Our commitment to protect your privacy
We understand how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of personal information we hold about you and what we do with that information.
We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.
Our commitment in respect of personal information is to comply with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act), the Privacy (Credit Reporting) Code 2025 where applicable, and any other relevant laws.
Personal information
When we refer to personal information, we mean information or an opinion about an identified individual, or an individual who is reasonably identifiable.
The kinds of personal information we may collect about you include your name, date of birth, address, email address and other contact details, identification and verification information, bank and account details, occupation, tax residency or status, financial information, information about your directorships, ownership or control interests, and any other information we reasonably need to identify you or provide our products or services. The personal information we hold about you may also include credit information.
We may verify your identity using information held by a credit reporting body (CRB). To do this, we may disclose personal information such as your name, date of birth, and address to the CRB to obtain an assessment of whether that personal information matches information held by the CRB. The CRB may give us a report on that assessment and, to do so, may use personal information about you and other individuals in its files. Alternative means of verifying your identity are available on request. If we are unable to verify your identity using information held by a CRB, we will provide you with a notice to this effect and give you the opportunity to contact the CRB to update the information it holds about you.
If you are applying for finance, or are a director, guarantor, beneficial owner, controller or other person associated with an applicant for finance, we may also collect information about your financial position, assets and liabilities, employment and business experience and other information relevant to assessing the application, the creditworthiness of the borrower or the value of any guarantee or security.
Why we collect your personal information
Investor information
We collect personal information for the purposes of assessing applications to invest in our financial products and managing and administering those investments, including processing applications, maintaining investor records, making distributions and redemptions, communicating with investors and meeting tax and regulatory reporting obligations. Where an investor or prospective investor is an entity, we may also collect personal information about individuals associated with that entity, including its directors, trustees, beneficial owners and authorised representatives.
Borrower and related person information
We collect personal information in connection with assessing applications for finance and structuring, providing, managing, monitoring and enforcing that finance. This may include personal information about borrowers, guarantors, directors, shareholders, beneficial owners and other persons associated with a borrower or proposed borrower. Where reasonably necessary, we may use and disclose borrower and related person information to investors and prospective investors in connection with assessing or providing information about an investment opportunity or managing or reporting on an investment.
Other purposes
We may also collect, hold, use and disclose your personal information for the purposes of:
-
complying with our legal and regulatory obligations, including obligations relating to anti-money laundering and counter-terrorism financing, sanctions, the United States Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS);
-
preventing, detecting and investigating fraud, unlawful activity and other conduct that may give rise to financial or regulatory risk;
-
managing our relationship with you and communicating with you about our products, services and activities;
-
operating our business, including engaging service providers and professional advisers, managing risk, conducting audits and maintaining our systems and records; and
-
direct marketing and offering products and services that we consider may be of interest to you, subject to applicable law and your right to opt out.
How do we collect your personal information?
Where reasonable and practical, we will collect your personal information directly from you. We may also collect personal information from other persons and organisations, including our related entities, investors, borrowers, finance brokers, credit reporting bodies, identity verification and screening service providers, accountants, lawyers and other professional advisers. We may also collect personal information from publicly available sources, including public registers.
When you access our website or other online services, we may automatically collect certain information about your use of those services, including your Internet Protocol address, browser information, the date and time of your request and information collected through cookies. You can manage or delete cookies from your browser settings. However, doing so may limit your use of some features of our online services.
Do we disclose your personal information?
Depending on your relationship with us and the product, service or transaction involved, we may disclose your personal information to:
-
our related bodies corporate and related entities, including entities involved in the management or operation of funds managed by the Supra group;
-
investors and prospective investors, where the information relates to a borrower, proposed borrower, guarantor or other person associated with a financing transaction and the disclosure is relevant to an investment opportunity or the management or reporting of an investment;
-
trustees, custodians, fund administrators, registry providers, investment managers and other persons involved in establishing, administering or operating our funds or financial products;
-
banks and other financial institutions or payment service providers involved in receiving, holding or paying investment or finance monies;
-
credit reporting bodies and service providers that assist us with identity verification, anti-money laundering and counter-terrorism financing, sanctions screening and fraud prevention;
-
finance brokers, valuers, quantity surveyors, surveyors, accountants, auditors, lawyers and other professional advisers or consultants involved in assessing, documenting or managing a finance transaction or investment;
-
receivers, controllers, insolvency practitioners, recoveries firms and debt collectors where relevant to enforcement or recovery;
-
any person who represents you, or acts on your behalf, including your finance broker, lawyer, accountant or other adviser; and
-
government departments, regulators, law enforcement agencies, courts, tribunals and taxation authorities where required or authorised by law.
We may also disclose your personal information where:
-
disclosure is reasonably necessary to protect Supra’s legal rights or interests, or to protect the safety of Supra’s employees or the public, where required or permitted by law;
-
we reasonably believe disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of an individual, or to public health or safety;
-
we are otherwise permitted by law to disclose your information;
-
the disclosure is otherwise permitted under the Privacy Act, including where it is for a related purpose that you would reasonably expect;
-
you have provided us with consent.
We may verify information or documents provided to us by disclosing relevant personal information to the person or organisation that provided or issued the information or document, or to a service provider that assists us with identity or other verification. This may include verification undertaken for the purposes of complying with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
We may use service providers that are located outside Australia or that store or process personal information outside Australia. Where personal information is likely to be disclosed to overseas recipients, we will handle that disclosure in accordance with the Privacy Act.
Credit information
We may collect credit information about you where relevant to an application for finance, a guarantee or another financing arrangement. This may include information about your existing or previous credit arrangements, credit applications, payment or default history, insolvency or bankruptcy, court proceedings and other information relevant to assessing your creditworthiness.
We may obtain credit information from credit reporting bodies, publicly available sources and other persons or organisations involved in assessing or providing finance.
We may use credit information for purposes including assessing an application for finance or a guarantee, assessing creditworthiness and managing or enforcing finance arrangements.
Where permitted by law, we may exchange credit information with credit reporting bodies and other persons or organisations involved in the relevant finance arrangement.
Notifiable matters
Where we collect personal information about you that we are likely to disclose to a credit reporting body, we may be required by the Privacy Act and the Privacy (Credit Reporting) Code 2025 to notify you of certain matters relating to that disclosure. You may request to have these notifiable matters (and this privacy policy) provided to you in an alternative form.
We may exchange your credit information with CRBs for purposes permitted by law, including in connection with an application for commercial credit or the assessment of a proposed guarantor. An information request made to a CRB may be recorded on your credit report and may be taken into account by credit reporting bodies and other credit providers when assessing your creditworthiness.
Where permitted by law, information relating to payment defaults or serious credit infringements may also be disclosed to a CRB.
You have the right to request access to credit-related information that we hold about you and to request correction of that information. Please see the heading Access and correction to your personal and credit information, below.
CRBs may use credit reporting information for the purpose of pre-screening direct marketing offers requested by credit providers. You may request that a CRB not use your credit information for this purpose.
You may also request that a CRB not use or disclose credit reporting information about you if you reasonably believe that you have been, or are likely to be, a victim of fraud. The credit reporting body will apply a ban period in accordance with the Privacy Act.
We may disclose personal information to, and obtain credit reporting information from, Equifax Australia Information Services and Solutions Pty Limited
Equifax’s contact details are:
Website: www.equifax.com.au
Phone: 13 8332
Post: Equifax, Customer Resolutions Team, GPO Box 964, North Sydney NSW 2059.
Direct marketing
From time to time, where permitted by law, we may use your personal information to provide you with information about finance, investment opportunities, products or services that we consider may be of interest to you, or changes to our organisation.
If you do not wish to receive direct marketing communications, you may opt out at any time by telephoning us on
(03) 8691 4190 or writing to us at either:
-
Level 1, 1121 High Street, Armadale
If the direct marketing is by email, you may also unsubscribe by return e-mail with ‘unsubscribe’ in the heading. We will not charge you for making or giving effect to an opt-out request and will give effect to your request within a reasonable period.
Updating your personal information
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.
If you wish to update your personal information, you may contact us.
Access and correction to your personal and credit information
You may request access to the personal and credit information we hold about you. Subject to applicable law, we will provide access on request. We will not charge you a fee for making an access request, but we may charge a reasonable fee for our costs of providing access.
We will respond to your access request within a reasonable period. We may need to contact other entities to properly consider your request.
There may be circumstances where we are not required to provide you with access to your personal or credit information under the Privacy Act or other applicable law.
If we refuse to provide access, we will give you a written notice setting out the reasons for the refusal, except where it would be unreasonable to do so, and the available complaint mechanisms, as required by law.
If any of the personal or credit information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may request that we correct the information. We will take reasonable steps to correct the information where required by law.
We will respond to a request to correct personal information within a reasonable period. Where the request relates to credit information, different timeframes may apply under the credit reporting provisions of the Privacy Act.
We may need to consult with other finance providers, CRBs or other relevant entities as part of our investigation.
If we refuse to correct personal or credit information, we will provide you with a written notice setting out the reasons for the refusal and the available complaint mechanisms, as required by law.
Using government-related identifiers
If we collect government-related identifiers, such as your tax file number, we will only use or disclose them where permitted by law.
Business without identifying you
In most circumstances it will be necessary for us to identify you in order to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of dealing with us anonymously or by using a pseudonym, for example, if you make general inquiries about interest rates or current promotional offers.
Sensitive information
We will only collect sensitive information about you where you consent and the collection is reasonably necessary for one or more of our functions or activities, or where the collection is otherwise permitted, required or authorised by law. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation, criminal record, health information and certain biometric information.
How safe and secure is your personal information that we hold?
We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, interference, loss and unauthorised access, modification or disclosure.
We will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which it may be used or disclosed under the Privacy Act, unless we are required by law or a court or tribunal order to retain it.
Where we retain copies of identification documents for identity verification or anti-money laundering and counter-terrorism financing purposes, we will take reasonable steps to destroy or de-identify those copies when we are no longer permitted to retain them under the Privacy Act or required to retain them by law.
Complaints
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act and the Privacy (Credit Reporting) Code 2025, you may contact our Compliance Officer by writing to us at either:
-
Level 1, 1121 High Street, Armadale
We will consider your complaint and provide you with a response within 30 days.
If you are dissatisfied with the response of our Compliance Officer, or we do not respond within 30 days, you may make a complaint to the Office of the Australian Information Commissioner who can be contacted on enquiries@oaic.gov.au, at www.oaic.gov.au or 1300 363 992.
Further information
You may request further information about the way we manage your personal or credit information by contacting us.
Change in our privacy policy
We review this privacy policy from time to time to reflect changes in our practices, technology and applicable laws and regulatory requirements.
We may change this privacy policy from time to time.
You may request this privacy policy in an alternative form.