Privacy Policy

This Privacy Policy explains how Single Asset Exposure Limited (ABN 26 617 371 310, AFSL 564987) (we, us, our) handles personal information collected through this website, universusfund.com.au (the Website).

We are the Investment Manager of the Universus Master Income Fund (the Fund) and the operator of this Website. We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This policy covers the Website only. The Fund’s Responsible Entity, One Managed Investment Funds Limited (AFSL 297042), and the Fund’s registrar and administrator each handle unitholder information under their own privacy policies. If you complete an application to invest, that application is submitted to, and handled by, the Fund’s registrar rather than through this Website, and their privacy policy will apply to it.

1. What personal information we collect

We only collect personal information that is reasonably necessary for the purposes set out in this policy. Through the Website we may collect:

Information you give us

• Enquiry and call-back forms: your name, email address, telephone number, the indicative investment amount you select, and any message you choose to write.
• Direct correspondence: any information you include if you email or telephone us using the details on the Website.

Information collected automatically

• Technical and usage data: IP address, browser and device type, pages viewed, referring page, and approximate location derived from your IP address.
• Advertising identifiers:where you arrive from an online advertisement, a click identifier supplied by the advertising platform (for example Google’s gclid, gbraid or wbraid parameter). We store this in your browser for the duration of your visit and, if you submit an enquiry, include it with that enquiry so we can understand which advertising led to it.
• Cookies and similar technologies: see section 5.

We do not collect sensitive information through the Website, and we do not ask for financial account details, tax file numbers or identification documents through this Website.

2. How we collect it

We collect personal information directly from you when you complete a form or contact us, and automatically through cookies, tags and analytics tools when you use the Website. We may also receive information about your interaction with our advertising from the advertising platforms described in section 5.

You can browse the Website without providing personal information. You may deal with us anonymously or under a pseudonym where it is lawful and practicable, although we generally cannot respond to an investment enquiry without contact details.

3. Why we collect, hold, use and disclose it

• To respond to your enquiry or arrange a call with our team.
• To send you information you have requested about the Fund, including the Product Disclosure Statement (PDS) and Target Market Determination (TMD).
• To assess, and keep records demonstrating, whether our marketing is consistent with the Fund’s Target Market Determination under our Design and Distribution Obligations.
• To measure and improve the performance of the Website and our advertising, including which advertisements and pages lead to genuine enquiries.
• To comply with our obligations under the Corporations Act 2001 (Cth), our Australian Financial Services Licence, anti-money laundering laws and other applicable law.
• To detect and prevent spam, misuse and fraud.

We may disclose your personal information to: our related entities and personnel; the Fund’s Responsible Entity, registrar, administrator, custodian and auditors; our professional advisers; our IT, hosting, email, customer-relationship and marketing service providers; and to any person where required or authorised by law. We do not sell your personal information.

4. Direct marketing

If you provide your details through the Website, we may contact you about the Fund and related investment opportunities. Every marketing email we send includes an unsubscribe facility, and you can opt out at any time by contacting us using the details in section 11. We will act on your request promptly and at no cost to you.

5. Cookies, advertising and remarketing

The Website uses cookies and similar technologies. Cookies are small files stored on your device that let a website or advertising platform recognise a browser across pages and visits. We use them for the following purposes.

Strictly necessary and functional

Used to make the Website work — for example, storing an advertising click identifier in your browser’s session storage so it can be attached to an enquiry you choose to submit. These are cleared when you close your browser.

Analytics and performance

We use privacy-oriented analytics provided by our hosting provider to measure page views, traffic sources and page-loading performance in aggregate.

Advertising, conversion measurement and remarketing

We use Google Ads(including the Google tag, gtag.js, and Google’s conversion and remarketing cookies) to measure the effectiveness of our advertising and to show you advertisements for the Fund on Google Search, YouTube, and websites and apps in Google’s display and partner networks after you have visited this Website. This practice is commonly called remarketing or retargeting.

We may also use equivalent advertising, conversion-measurement and remarketing technologies provided by other advertising platforms from time to time, including Meta Platforms (Facebook and Instagram), LinkedIn, Microsoft Advertising and other advertising networks and demand-side platforms. Where we do, those platforms may set their own cookies or similar identifiers and may combine information about your visit to this Website with information they already hold about you, in accordance with their own privacy policies.

We may also provide an advertising platform with information about an enquiry — including the click identifier described in section 1 and, in hashed form, contact details you have given us — so the platform can report which advertisements produced genuine enquiries. This is used for measurement and audience purposes only.

Your choices

• Most browsers let you block or delete cookies through their settings. Blocking cookies may affect how parts of the Website function.
• You can manage Google’s advertising personalisation at myadcenter.google.com and review how Google handles data from sites that use its services at policies.google.com/technologies/partner-sites.
• You can manage Meta’s ad preferences in your Facebook or Instagram account settings.
• You can opt out of interest-based advertising from participating providers at optout.aboutads.info.

6. Overseas disclosure

The Website is hosted on infrastructure that may store or process data outside Australia, and the analytics and advertising providers described in section 5 are global businesses. As a result, your personal information may be disclosed to, or accessible from, recipients located overseas — most commonly in the United States and the European Union. We take reasonable steps to ensure overseas recipients handle personal information consistently with the APPs.

7. Security

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These include encrypted connections to the Website (HTTPS), encrypted transmission of enquiries to our mailbox, restricted access to information on a need-to-know basis, and spam filtering on our forms.

No method of transmission or storage is completely secure. If we become aware of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.

8. How long we keep it

We keep personal information only for as long as it is needed for the purposes described in this policy, or for as long as we are required to keep it by law. Financial services records are generally required to be retained for at least seven years. When information is no longer needed and we are not required to retain it, we take reasonable steps to destroy it or de-identify it.

9. Accessing and correcting your information

You can ask us for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details in section 11. We will generally respond within 30 days. We may need to verify your identity, and in limited circumstances permitted by law we may decline a request — if we do, we will explain why in writing.

10. Complaints

If you believe we have breached the APPs, please contact us using the details in section 11 and we will investigate and respond to you. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:

• Online: oaic.gov.au
• Telephone: 1300 363 992
• Post: GPO Box 5288, Sydney NSW 2001

11. How to contact us

12. Changes to this policy

We may update this policy from time to time to reflect changes to our practices or the law. The current version is always available on this page, and the date at the top shows when it was last updated. We encourage you to review it periodically.