The information we collect from you is strictly confidential for use within Segue Financial Services. Segue Financial Services use your personal information to establish and administer the financial products and services Segue Financial Services provides to you and communicate with you on an on- going basis about those financial products and services.

Personnel may use personal information to verify your identity over the telephone.

Unless you choose to opt out, Segue Financial Services may also send you educational or marketing material about new products or services or other opportunities. You may contact us at any time and ask that we not send this material.

Segue Financial Services may need to disclose personal information to external persons or entities:

• Segue Financial Services may be required to provide details to a governmental or regulatory body to fulfil its legal requirements (for example, disclosure to enforcement bodies such as the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO), the Australian Transaction Reports and Analysis Centre(“AUSTRAC”).
• Segue Financial Services may be required to disclose certain information pursuant to a court order.

Segue Financial Services uses agents and external service providers, (such as registry providers, printing companies, external consultants) to assist it with the delivery of the financial products and services Segue Financial Services provides to you.

Segue Financial Services will take steps to ensure that its agents and external service providers keep the personal information confidential and that the information is only used for the purpose Segue Financial Services has authorised. Those parties must undertake to comply with our confidentiality requirements under privacy law.

Where personal information is passed to external parties that perform specific services for Segue Financial Services, for example mailing, Segue Financial Services limit the disclosure to the information needed to perform the service.

• In 2010, the United States enacted a law (the HIRE Act) which included provisions commonly referred to as the “Foreign Account Tax Compliance Act” or FATCA. While the final regulations have not yet come into effect, FATCA will require participating non-US financial institutions to report certain information about financial accounts held directly or indirectly by US persons to the US Internal Revenue Service (IRS). To comply with these requirements, these participating financial institutions will be required to:

• undertake certain identification and due diligence procedures with respect to its existing and new account holders;
• report annually to the IRS on US persons who directly or indirectly own financial accounts; and
• generally withhold and pay 30% of US source income to the IRS, as well as gross proceeds from the sale of property that generates US source interest, or dividends made to US account holders failing to provide certain information. Beginning in 2017, withholding may also be required by participating non-US financial institutions on certain other payments of foreign source income
• FATCA and potentially any intergovernmental agreement may affect the Responsible Entity and how it uses information you provide to us. Accordingly, when you apply to invest you agree to:
• provide us certain identification and other information that we may need in order for us to comply with our obligations under FATCA including obligations under any agreement with the IRS:
• waive any provision of foreign law that would, absent a waiver, prevent us from complying with our obligations under FATCA including obligations under any agreement with the IRS and acknowledge that, if you fail to provide such a waiver, we may withhold any payments to you;
• acknowledge that if you fail to provide information on a timely basis, you may be subject to a 30% US withholding tax;
• acknowledge that if you fail to comply with such obligations and such failure could result in us being unable to enter into or comply with any agreement with the IRS, we can terminate your investment; and
• acknowledge that you will indemnify us and the other Investors for any losses resulting from your failure to meet your obligations under this provision, including any withholding tax imposed by FATCA as a result of such failure.

Depending upon the products or service you select, Segue Financial Services may exchange information about you with, for example:

• other financial institutions, including stockbrokers, custodians and fund managers,

• insurance companies,
• superannuation funds,
• other organisations or firms, who jointly with us, provide products or services to you.

You may authorise us to disclose personal information we hold to your financial adviser or other person nominated by you. Your express consent is required prior to disclosure being made.

Segue Financial Services will only disclose personal information where we are allowed to by law and have your express or implied consent, or where we are obliged to by law.

Segue Financial Services may rely on some of the exemptions permitted in the Privacy Act, such as the exemption for disclosing information to a related body corporate.