Privacy Policy

Privacy Policy

Last updated: 30 June 2026

1. About this Privacy Policy

This Privacy Policy explains how BlackBriar collects, uses, stores and discloses personal information.

In this Privacy Policy, BlackBriar, we, us or our refers to BlackBriar Funds Management Pty Ltd, BlackBriar Investment Management Pty Ltd and, where relevant, other companies within the BlackBriar group.

We are committed to protecting your privacy and handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. 

2. About BlackBriar

BlackBriar Funds Management Pty Ltd ACN 686 521 022 acts as trustee of the BlackBriar Credit Fund and as an authorised intermediary under an Authorised Intermediary Agreement with Universal Securities Pty Ltd ACN 682 700 296, AFSL No. 564880.

BlackBriar Investment Management Pty Ltd ACN 686 519 602 is the investment manager of the Fund and a Corporate Authorised Representative, CAR No. 001315572, of Universal Securities Pty Ltd. 

BlackBriar may use third-party service providers, including online investment management platforms such as Caruso, to help provide services to investors. Where third parties process personal information on our behalf, we take reasonable steps to ensure that information is handled appropriately. 

3. What personal information we collect

The personal information we collect depends on your relationship with us.

We may collect:

• your name, address, phone number and email address; 
• date of birth, place of birth, citizenship and tax residency information; 
• tax identification information; 
• identification documents and verification information; 
• bank account details; 
• information about your financial circumstances, investment entity, source of funds and investment activity; 
• information required for wholesale investor, AML/CTF, tax or compliance purposes; 
• records of your communications with us; 
• website and portal usage information, including cookies and analytics data; 
• if you apply for a role with us, information about your employment history, qualifications and references. 

4. How we collect personal information

We may collect personal information directly from you when you:

• contact us by phone, email, website form or in person; 
• use our website or investor portal; 
• apply to become an investor; 
• submit documents or information to us; 
• make or manage an investment; 
• subscribe to updates or marketing communications; 
• apply for a role with BlackBriar. 

We may also collect personal information from third parties, including:

• your advisers, representatives or authorised signatories; 
• identity verification providers; 
• government agencies or verification databases; 
• banks, payment providers and service providers; 
• publicly available sources; 
• referees, if you apply for employment with us. 

If you do not provide information we reasonably require, we may not be able to provide services to you, process your application, verify your identity, communicate with you or meet our legal obligations.

5. Why we collect and use personal information

We collect, hold, use and disclose personal information to:

• communicate with you; 
• respond to enquiries; 
• assess investor eligibility; 
• create and manage investor accounts; 
• process investment applications, payments, transfers, reports and statements; 
• verify identity and carry out AML/CTF, sanctions, tax and compliance checks; 
• manage our relationship with investors, borrowers, brokers, advisers and service providers; 
• provide, maintain and improve our website, investor portal and services; 
• keep records and meet legal, regulatory and compliance obligations; 
• detect, prevent or investigate fraud, unlawful activity or misuse of our systems; 
• send administrative messages, reminders, notices, updates and security alerts; 
• send investment updates or information about investments that may be of interest, unless you ask us not to; 
• provide marketing or promotional information where permitted; 
• manage complaints and disputes; 
• protect our legal rights and interests. 

You may opt out of marketing communications at any time by using the unsubscribe function where available or by contacting us at investments@blackbriar.au. 

6. Who we may disclose personal information to

We may disclose personal information to:

• companies within the BlackBriar group; 
• Universal Securities Pty Ltd and other parties involved in the provision or oversight of financial services; 
• third-party technology and platform providers; 
• identity verification providers; 
• banks, payment providers and financial institutions; 
• professional advisers, including lawyers, accountants and auditors; 
• your authorised representatives, advisers, agents or signatories; 
• government agencies, regulators, law enforcement bodies or courts where required or permitted by law; 
• service providers who help us operate our business, website, investor portal, marketing, communications, administration and record keeping; 
• another party in connection with a restructure, merger, sale or transfer of all or part of our business; 
• any other person or organisation authorised by you or permitted by law. 

We do not sell personal information to third parties. 

7. Overseas disclosure

Some of our service providers may store or process personal information outside Australia.

Where this occurs, we take reasonable steps to ensure that personal information is handled in accordance with applicable privacy laws.

8. Website, cookies and analytics

We may use cookies, web beacons, pixels and analytics tools to understand how visitors use our website and investor portal.

Cookies are small files stored on your device. They help websites operate, remember preferences, improve user experience and provide usage information.

You can disable cookies through your browser settings. However, some parts of our website or investor portal may not work properly if cookies are disabled.

We may use tools such as Google Analytics to collect information about website traffic, pages visited and how users interact with our website. 

9. Protecting personal information

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure.

These steps may include physical, electronic and procedural safeguards, secure systems, access controls, staff training and the use of trusted service providers.

However, no method of transmission over the internet or electronic storage is completely secure.

10. How long we keep personal information

We keep personal information for as long as we reasonably need it for the purposes for which it was collected, or for as long as required by law.

For example, we may need to retain records for legal, tax, audit, regulatory, AML/CTF or dispute resolution purposes.

When we no longer need personal information, we will take reasonable steps to destroy or de-identify it.

11. Accessing and correcting your information

You may request access to the personal information we hold about you.

You may also ask us to correct information you believe is inaccurate, incomplete or out of date.

We will respond to access and correction requests within a reasonable time. In some circumstances, we may be legally permitted to refuse a request.

12. Privacy complaints

If you have a concern or complaint about how we handle personal information, please contact us first so we can try to resolve it.

Email: info@blackbriar.au
Phone: 1300 629 019
Address: Level 2, 627 Chapel Street, South Yarra VIC 3141

We will acknowledge your complaint within one business day and aim to provide a written response within 30 calendar days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au. 

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

The latest version will be published on our website. Where changes are significant, we may take additional steps to notify you.

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