1. Introduction: 

We are a venture capital fund based in Sydney which invests in technology startups across both Australia and New Zealand.  Our operating entities, Shearwater Capital II Pty Ltd ACN 672 752 493 and Shearwater Capital Pty Ltd ACN 630 622 669, (Shearwater) are committed to protecting your privacy.  This Privacy Policy explains how we collect and use your personal data and which rights and options you have in this respect. 

2. What personal data do we collect?

The personal data we collect from you may include: 

• Contact information – including your email address, telephone number and links to your website and LinkedIn profile
• Business information –  information necessarily provided when you contact us for discussing an investment or which have been voluntarily provided by you in relation to an investment 
• Third party information – information from third party sources such as regulators, credit providers or data providers, where permitted by law
• Public Information – information collected from publicly available sources
• Technical information – information relating to the device you have used to access our website, including geo-location data, IP address and other data which may be collected automatically if you use our website
• Any other personal information required by us and/or provided by you or a third party

3. How do we collect your personal information?

We may collect personal data from you when you interact with Shearwater, including: 

• Directly from you when you provide personal information to us 
• Indirectly from a third party source.  This may include data from your organisation, other organisations to which you have dealings with, government agencies, credit reporting agencies or from a publicly available record. 

4. For what purposes do we use your personal information?

We may use your personal information for the following purposes: 

• Providing our services to you or as requested by you or your organisation
• To assess your business and complete due diligence 
• To invest in your company and undertake any transaction 
• To manage and administer you or your organisation’s business relationship with Shearwater
• To comply with our legal obligations 
• For internal recording keeping and administrative purposes including analytics and business development activities to improve our business 
• If otherwise required or authorised by law

5. Who will we share your personal information with?

While we do not routinely disclose personal information, we may share your personal information in the circumstances: 

• Where you direct us or give us permission to do so
• Where we are required by applicable laws, regulations or judicial orders
• Where you would reasonably expect us to use or disclose your personal information in this way
• As is required to investigate actual or suspected fraudulent or criminal activities

Specifically, we may disclose your personal information with: 

• Our employees, contractors or related entities, and
• Third party providers who supply services to us in connection with our administrative functions and in fulfilling our legal and regulatory obligations

6. Disclosure of personal information to overseas recipients. 

We do not disclose your personal information to overseas recipients.

7. How do we keep your personal information secure?

We have implemented and have taken appropriate measures to ensure that your personal information is secure from unauthorised access, including:

1. Encryption:
   • We utilize industry-standard encryption protocols to protect your personal information during transmission and storage. 
2. Access Control:
   • We implement strict access control measures to limit access to your personal information to authorized personnel only. 
3. Regular Audits:
   • We conduct regular security audits to identify and address any vulnerabilities in our systems.
4. Physical Security:
   • We maintain secure physical facilities to protect your personal information from unauthorized physical access.

8. User rights

If you provide your personal information to us, you agree that we will collect, hold, use and disclose your personal information in accordance with this privacy policy. 

Subject to certain legal conditions, you have a right to request a copy of your personal information and to have any inaccurate personal information corrected by contacting us.  You may also object to us using your personal information.   

Where you do make a request, we will require a form of identification so that we can verify you are the person with the right to access the personal information.

9. How to get in touch with Shearwater

If you would like to contact us, please do so via the contact form on our website.