Privacy and Credit Reporting Policy
This Privacy and Credit Reporting Policy outlines how KD Capital (QLD) Pty Ltd (ACN 667 474 517), as Corporate Authorised Representative (No. 001312717) of Brindabella Investment Group Pty Ltd (AFSL 510735), collects, uses, and discloses personal information (including credit-related information) in connection with the operation of the Incrementum Mortgage Fund.
Our Commitment to Protect Your Privacy
We are committed to handling your personal information responsibly and in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the Privacy (Credit Reporting) Code 2014. This includes ensuring that personal and credit-related information is collected, used, and disclosed only for lawful purposes.
What Personal Information We Collect
We may collect:
-
Full name, date of birth, and contact details
-
Identity verification documents (e.g. driver licence, trust deeds)
-
Financial details for wholesale investor eligibility (e.g. income, assets)
-
Employment and residency details
-
Bank account information
-
Credit-related information (as defined below)
Credit-related information may include:
-
Details of credit arrangements, repayment history, defaults, hardship variations
-
Publicly available court proceedings or insolvency information
-
Information derived from credit reporting bodies (CRBs)
Why We Collect This Information
We collect your personal and credit-related information to:
-
Assess your eligibility as a wholesale investor
-
Manage your participation in the Incrementum Mortgage Fund
-
Comply with Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws
-
Communicate investment and fund information
-
Meet legal, regulatory, and reporting obligations
-
Provide updates and direct marketing (where permitted)
How We Collect Information
We typically collect personal information directly from you. We may also collect information from:
-
Mortgage brokers, advisers, or other referrers
-
Credit reporting bodies
-
Public registers, social media, or identification services
-
Your legal, financial, or tax advisers
Disclosing Your Information
We may disclose your personal or credit-related information to:
-
Brindabella Investment Group Pty Ltd
-
Service providers (e.g. IT, accounting, cloud storage, CRM platforms)
-
External compliance, legal and auditing partners
-
Regulatory bodies (e.g. ASIC, AUSTRAC) when required
-
Potential investors, advisers, and fund administrators
-
Any person you authorise, such as your lawyer or accountant
-
Offshore IT or cloud providers (with safeguards)
Overseas Disclosure
Your information may be stored or processed using secure cloud-based systems, which may involve offshore data centres. While reasonable steps are taken to ensure data security, overseas jurisdictions may not always offer the same level of protection as Australian law.
Credit Reporting
We may exchange credit-related information with credit reporting bodies such as Equifax to:
-
Assess wholesale investor eligibility
-
Verify your identity
-
Confirm your financial standing if you are providing a guarantee or funding application
You may contact Equifax (www.equifax.com.au) to access or correct your credit information or to report suspected identity fraud.
Access and Correction
You have the right to access or request correction of the personal or credit-related information we hold about you. We aim to respond within 7 days. Requests may be sent to info@regi.loans.
Direct Marketing
We may use your contact details to offer you updates or investment opportunities. You may opt out of direct marketing at any time by contacting info@regi.loans or using the unsubscribe link in email communications.
Security and Storage
We maintain physical, technical, and administrative safeguards to protect your personal information from misuse, loss, or unauthorised access. Information may be stored in both paper and electronic formats.
Complaints
If you have concerns about how we handle your personal or credit information, please contact us at info@regi.loans. If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) via www.oaic.gov.au or call 1300 363 992.
Changes to This Policy
We may update this policy from time to time. The current version is available at www.regi.loans or upon request.
Last updated: 16 May 2025
