Privacy Policy

1. About this policy

TY Capital Group Pty Ltd ACN 647 012 593 (AFSL 528626) and its related bodies corporate (together, TY Capital, we, us or our) are committed to protecting the personal information we hold about you, in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).

This policy describes how we collect, hold, use and disclose personal information. It is not intended to cover categories of information that are not regulated by the Privacy Act.

The entities covered by this policy include:

• TY Capital Group Pty Ltd ACN 647 012 593
• TYCG Fund Alpha Pty Ltd ABN 86 661 135 986
• Tycoon Investment Management Pty Ltd
• Tycoon Funds Management Pty Limited ACN 651 361 045
• TYCG Security Pty Ltd ACN 698 568 231

[FOR LEGAL REVIEW] Confirm this entity list, including the current registered name of each. TYCG Fund Alpha Pty Ltd and Tycoon Investment Management Pty Ltd appear to share company number 661 135 986, which needs resolving before this list is published.

To provide our products and services we rely on personal information submitted by you, or by someone acting with your authority. By using our products or services, or by otherwise providing your personal information to us, you consent to our collecting, holding, using and disclosing that information in accordance with this policy.

2. Funds operated by third parties

Some of the products we manage are issued by a third party. The Tycoon Real Income Fund is issued by Primary Securities Ltd ACN 089 812 635 (AFSL 224107) as responsible entity. Where Primary Securities Ltd collects and holds your personal information as the issuer of that fund, its own privacy policy applies to that information in addition to this policy.

Primary Securities Ltd may be contacted on (08) 9430 5262 or at trustee@noncorrelatedgroup.com.

[FOR LEGAL REVIEW] Confirm with the responsible entity how this boundary should be described, and whether they require specific wording.

3. What is personal information

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether recorded in a material form or not.

4. What personal information we collect

In order to provide our products and services, we may collect and hold personal information about you including:

• your name, date of birth and, where relevant, gender
• your contact details, including postal address, email addresses and telephone numbers
• your tax file number, Australian Business Number and details of your tax residency, where you choose to provide them
• a copy of your driver licence, passport or other identification documents, collected to verify your identity and to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and with tax reporting and withholding obligations
• your bank account details, for the payment of distributions and the processing of applications and withdrawals
• your investment amount, chosen investment term, distribution election and, for individually managed accounts, your stated risk and return objectives
• copies of trust deeds, company constitutions, partnership agreements and accountant’s certificates, where relevant to your investment
• where you apply as a wholesale client, information supporting that status
• if you apply to borrow from us, financial and business information relating to the loan, the security offered and any guarantors
• your IP address and information about your use of our website

5. Why we collect personal information

We collect personal information that is reasonably necessary for one or more of our functions or activities, including to:

• establish and administer your investment, and process applications, distributions and withdrawals
• assess and administer loan applications, and manage loans and security
• verify your identity and confirm your investor status
• meet our obligations under the Corporations Act 2001 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), taxation law and the conditions of our Australian Financial Services Licence
• report to the Australian Taxation Office as required under the Foreign Account Tax Compliance Act and the Common Reporting Standard
• communicate with you, respond to your enquiries and provide reporting on your investment
• promote and market our products and services
• improve our products, services and website
• manage recruitment and employment

If you choose not to provide personal information to us, we may be unable to provide you with the information, products or services you have requested. In particular, we cannot issue an investment to you unless we have received and verified the identification information the law requires.

6. How we collect personal information

We usually collect personal information directly from you, including when you:

• complete an application form, an identification form or an enquiry form
• visit our website at www.tycapital.com.au or use our investor portal
• subscribe to our reports, updates or newsletter
• apply for a loan or provide a guarantee
• contact us by telephone, email, post or in person
• apply for employment with us

We may also collect personal information about you from third parties, including from your financial adviser, accountant or broker, from our administrator, custodian or responsible entity, from credit reporting and identity verification providers, from valuers and legal advisers in connection with a loan, and from publicly available sources.

If you provide us with personal information about another individual, you confirm that you are authorised to do so and that you have met your own obligations under the Privacy Act in collecting and disclosing that information.

If we receive personal information that we did not request, we will deal with it in accordance with the Privacy Act, and may de-identify or destroy it unless we are required to retain it by law.

7. Our website

You can browse the public areas of our website without providing personal information. We collect personal information from our website only where you knowingly provide it, or as described below.

Website analytics. When you visit our website, our hosting and analytics providers may collect information for statistical, reporting and maintenance purposes, including the number of visitors and pages viewed, the date, time and duration of a visit, your IP address, and the path taken through the site. This information is generally not used to identify you.

Cookies. We may use cookies and similar technologies. Cookies are small text files placed on your device that record information about your browser and your use of a site. You can set your browser to refuse cookies, though some parts of our website may then not work as intended.

Links to other sites. Our website may link to third party websites, including our investor portal and the platforms operated by our service providers. This policy does not apply to those sites. You should review the privacy policy of any site before providing personal information to it.

[FOR LEGAL REVIEW] Confirm whether Google Analytics, advertising pixels or remarketing tags will be installed on the new site. The client has confirmed no analytics accounts currently exist. If any are added, an advertising clause should be included here.

8. How we use personal information

We generally use your personal information only for the purpose for which it was provided. We may also use it to:

• administer your investment or loan and maintain our records
• provide you with reporting, statements and tax information
• respond to your requests and enquiries
• tell you about our other products and services
• research the needs of our investors and improve our products and services
• comply with our legal and regulatory obligations
• recruit and manage our personnel
• any other purpose required or permitted by law, or notified to you at the time of collection

We may use your personal information for a related secondary purpose where the Privacy Act permits us to do so, or where you have consented.

9. Direct marketing

We may use your personal information to send you information about our products and services, including by email or SMS. Where we have obtained your personal information from a third party, we will seek your consent before doing so.

You may opt out of receiving marketing communications at any time by using the unsubscribe function in the communication, or by contacting our Privacy Officer using the details in clause 16. We do not sell personal information to third parties for marketing purposes.

10. When we disclose personal information

We may disclose your personal information to:

• our officers, employees and related bodies corporate
• the responsible entity, trustee, custodian, administrator and auditor of the relevant fund
• your financial adviser, accountant or broker, where you have authorised this
• identity verification, banking and payment providers
• brokers and trading platforms used to hold and transact your investments
• valuers, lawyers, and other professional advisers engaged in connection with a loan or an investment
• IT, hosting, mail house and other service providers who assist us to operate our business
• government agencies and regulators, including the Australian Securities and Investments Commission, the Australian Taxation Office, AUSTRAC, the Australian Financial Complaints Authority and the Office of the Australian Information Commissioner
• any other person where you have consented, or where the disclosure is required or authorised by law

The parties that currently perform these roles for our funds include:

Where we disclose personal information to a service provider, we take reasonable steps to ensure that the provider handles it in accordance with the Privacy Act or with standards consistent with this policy.

We may share de-identified and aggregated information for research and reporting purposes.

11. Overseas disclosure

Our business operates in Australia. However, some of our service providers are located overseas, or use affiliates located overseas, and your personal information may be disclosed to them.

In particular:

• Our fund administrator, NAV Fund Services (Australia) Pty Ltd, engages affiliates in the United States and India to perform some of its services. Personal information is exported to and processed in those countries.
• The Individual Managed Account Service is operated through Interactive Brokers, whose systems are located in the United States.
• Our information technology, hosting and cloud storage providers may store or process information outside Australia, including in the United States and the European Union.

The privacy protections available in these countries may differ from those in Australia, and an overseas recipient may be required to disclose information under a foreign law. Where information is held in cloud or networked storage, it may be accessible from more than one country, and it is not always possible to identify every country from which it may be accessed.

We take reasonable steps to ensure appropriate security and contractual arrangements are in place with overseas recipients.

[FOR LEGAL REVIEW] Confirm the full list of overseas recipients, including the location of the website host and any customer relationship management system used for enquiry form submissions.

12. Employee records

Our obligations under the Privacy Act differ in relation to employee records. This policy may not apply to the handling of information about our current and former employees. Please contact us if you would like information about our employee information handling practices.

13. Storage and security

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Information held in hard copy is stored securely at our premises. Information held electronically is held on systems protected by access controls.

No transmission of information over the internet can be guaranteed as completely secure, and while we take reasonable steps to protect your information we cannot give an absolute guarantee of its security.

The Privacy Act requires us to notify affected individuals and the Office of the Australian Information Commissioner about a data breach that is likely to result in serious harm. Where that occurs, we will notify in accordance with our obligations.

14. Accuracy, access and correction

We take reasonable steps to ensure the personal information we hold is accurate, complete and up to date, but we rely on you telling us when your details change. Please tell us promptly if your address, email address, bank account details or adviser change.

You may request access to the personal information we hold about you by contacting our Privacy Officer. We will grant access unless providing it would unreasonably affect the privacy of another person, or unless we are permitted or required by law to refuse. If we refuse, we will give you our reasons in writing.

If information we hold about you is inaccurate, out of date or incomplete, we will correct it at your request.

15. How long we keep personal information

We keep personal information for as long as we need it for the purposes described in this policy and for as long as the law requires us to retain it. Records relating to investors and borrowers are generally retained for at least seven years after the relationship ends, as required under the Corporations Act and anti-money laundering law.

Some information must be retained even after you cease to be an investor. The Corporations Act requires that details recorded in the register of a registered scheme remain there after you cease to hold units.

Where we no longer need to retain your personal information, we take reasonable steps to destroy or de-identify it.

16. Contact us, and how to make a privacy complaint

If you have a question about this policy, wish to access or correct your information, or believe we have not handled your personal information in accordance with this policy or the Privacy Act, please contact our Privacy Officer:

Privacy Officer, TY Capital
Suite 1202, 52 Alfred St, Milsons Point NSW 2061
Telephone: 1800 878 898
Email: info@tycapital.com.au

[FOR LEGAL REVIEW] Confirm whether a dedicated privacy address, such as privacy@tycapital.com.au, should be used instead, and who is appointed as Privacy Officer.

We will investigate your complaint and tell you the outcome in writing, generally within 30 days. If you are not satisfied with our response, or you do not receive one within 30 days, you may refer the matter to the Office of the Australian Information Commissioner.

Office of the Australian Information Commissioner
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au

A privacy complaint is separate from a complaint about a financial product or service. Complaints about our products or services are handled under our complaints policy and may be referred to the Australian Financial Complaints Authority.

17. Changes to this policy

We may review and update this policy from time to time to reflect changes in law, regulation, technology or our business. The current version is published at www.tycapital.com.au and applies to all personal information we hold. Please check the website periodically for changes.

Last updated: September 2026 (draft)