Privacy policy

Who this applies to

This policy applies to personal information handled by HMH Investing Pty Ltd (ABN 97 701 390 589, ACN 701 390 589), a company registered in VIC, Australia. In this policy, we, us and our mean HMH Investing Pty Ltd, and you means any individual whose personal information we hold.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained in that Act. Where we are not otherwise bound by the Act, we apply this policy as a matter of practice.

Personal information has the meaning given in the Privacy Act 1988: information or an opinion about an identified individual, or an individual who is reasonably identifiable.

What personal information we collect

We collect only what we need in order to consider an approach and to meet our legal obligations as an Australian company. That is typically:

• Contact details — your name, email address, the organisation you act for, and any postal address or telephone number you choose to give us.
• Correspondence — the content of emails and enquiry messages you send us, and our replies.
• Transaction and counterparty information — where we progress to reviewing a business or property, information about the parties involved, including details contained in financial statements, title and lease documents and company records.
• Verification information — identity, tax and beneficial-ownership details where these are required to complete a transaction or to satisfy an obligation under Australian law.
• Technical information — limited server log information generated when you visit this website, as described under Cookies and this website.

We do not seek sensitive information as that term is defined in the Privacy Act 1988, and we ask that you do not send it to us unless it is genuinely necessary for a transaction. Where sensitive information is unavoidably provided, we will only collect and use it with your consent and where it is reasonably necessary for our functions.

How we collect it

We collect personal information directly from you wherever it is reasonable and practicable to do so — usually when you email us, submit the enquiry form on our contact page, or correspond with us during a review.

We may also collect information about you from third parties, including your accountant, solicitor or broker where they approach us on your behalf, and from publicly available sources such as the Australian Business Register, ASIC registers and land titles records. If we collect information about you from someone else, we will take reasonable steps to make you aware of that collection as required by the APPs.

Why we hold and use it

We use personal information for the following purposes:

• To respond to your enquiry and correspond with you about it.
• To assess whether a business, property or other asset is a fit for the company's own investment activities.
• To conduct a review of an asset, negotiate terms, and complete and administer a transaction.
• To manage and keep records for the holdings the company owns, including insurance, tax and reporting obligations.
• To meet our obligations under the Corporations Act 2001 (Cth), Australian taxation law and any other applicable law.
• To maintain the security and integrity of our systems and records.

We do not use personal information for direct marketing. We do not operate a mailing list, and we do not sell, rent or trade personal information to anyone.

When we disclose it

We disclose personal information only where it is necessary for a purpose set out above, and only to:

• Our professional advisers — solicitors, accountants, valuers and auditors — engaged in connection with a transaction or with the company's own compliance.
• Service providers who host or maintain our systems, under obligations of confidentiality.
• Government agencies and regulators, including the Australian Taxation Office and the Australian Securities and Investments Commission, where disclosure is required or authorised by law.
• A counterparty or co-owner, where you have asked us to deal with them or where disclosure is a necessary part of completing an agreed transaction.

We will otherwise not disclose your personal information without your consent, unless required or authorised by or under an Australian law or a court or tribunal order.

Overseas recipients

Our records are held in Australia wherever practicable. Some of the technical services supporting our email and this website may store or process data on servers located outside Australia. Where that occurs, we take reasonable steps to ensure the overseas recipient handles the information in a manner consistent with the Australian Privacy Principles, as required by APP 8.

Cookies and this website

This website is a set of static pages. It sets no cookies, runs no analytics or tracking scripts, embeds no third-party content, and does not build a profile of visitors.

The hosting provider that serves these pages records standard server log information, which may include your IP address, the time of the request, the page requested and your browser type. This is used only for delivering the site and for security purposes, and we do not use it to identify you.

The enquiry form on our contact page does not transmit anything to a server. It opens a message in your own email application, addressed to [email protected], which you then choose to send or discard.

Security and how long we keep it

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Those steps include access controls on our systems and records, and limiting internal access to those who need it for a purpose set out in this policy.

No method of transmitting information over the internet is completely secure. Please bear that in mind when sending sensitive material by email.

We retain personal information only for as long as it is needed for the purpose it was collected, or for as long as we are required to keep it under Australian law — for example, records that must be kept under the Corporations Act 2001 (Cth) or taxation law. When information is no longer needed and we are not required to retain it, we take reasonable steps to destroy it or to ensure it is de-identified, in accordance with APP 11.

Access and correction

Under APP 12 and APP 13 you may ask us to give you access to the personal information we hold about you, and to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading.

To make a request, email [email protected] with enough detail for us to identify the information. We will respond within a reasonable period, normally within 30 days. There is no charge for making a request; if a charge applies to giving access, we will tell you what it is before we incur it.

We may decline a request for access or correction where the Privacy Act 1988 permits us to do so — for example where giving access would unreasonably affect another person's privacy. If we refuse, we will tell you why in writing and explain how you may complain.

Complaints

If you believe we have breached the Australian Privacy Principles or otherwise mishandled your personal information, please tell us first. Email [email protected] with the details and mark your message "Privacy complaint". We will acknowledge your complaint, investigate it, and write to you with the outcome, ordinarily within 30 days.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC), which oversees the Privacy Act 1988. Contact details and the complaint process are published on the OAIC website.

Changes to this policy

We may update this policy from time to time to reflect changes in our practices or in the law. The current version is always the one published on this page, and the date it was last updated appears at the top of it.

Contact us about privacy

Privacy enquiries, access and correction requests, and complaints should all go to the same address: