1. About this policy
MAD Management Pty Ltd ("MAD", "we", "us", "our"), respects your privacy. This policy explains how we collect, hold, use, and disclose personal information. We are bound by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) and we comply with our obligations under that Act.
This policy applies to personal information collected through this website, through MAD's investor and member platforms (including the MAD-CO community and the MAD Ambassador Network), through events, and in the ordinary course of our business.
2. What personal information we collect
We collect personal information that is reasonably necessary for our functions, including:
- Identity and contact information (name, residential and business addresses, email, telephone numbers).
- Professional information (organisation, role, professional biography, areas of interest, network affiliations).
- Wholesale client qualification information (financial information necessary to confirm wholesale client status under section 761G of the Corporations Act 2001 (Cth), provided privately where applicable).
- Engagement information (records of correspondence, event attendance, expressions of interest, programme participation, contributions to advisory or ambassador activities).
- Technical information (IP address, browser type, device, navigation behaviour on our website, collected through cookies and similar technologies described in our Cookie Policy).
3. Sensitive information
We do not generally collect sensitive information (as defined in the Privacy Act, including information about health, racial or ethnic origin, political opinions, religious or philosophical beliefs, or membership of professional or trade associations). Where we do collect sensitive information, we will only use it for the primary purpose for which it was collected, for a directly related secondary purpose, with your consent, or where required or authorised by law.
4. How we collect personal information
- Directly from you, when you complete an expression of interest or contact form, subscribe to communications, register for an event, or correspond with us.
- Indirectly, when third parties (including referrers, our back-office and fund administration providers, our regulatory service providers, and your professional advisers) provide information to us in the course of their dealings with us.
- Automatically, when you visit our website, through cookies and similar technologies. See our Cookie Policy for details.
5. Why we collect personal information
- To respond to your enquiries and correspondence.
- To assess and process expressions of interest, including in MAD-CO membership.
- To verify your status as a wholesale client where applicable to any private offer.
- To provide information about MAD and its activities to those who have requested it.
- To administer relationships with members, ambassadors, investors, portfolio companies, and counterparties.
- To comply with our legal obligations, including those under the Corporations Act 2001 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and applicable taxation law.
- To improve our website, services, and offerings.
- For internal record-keeping, governance, and management purposes.
6. Who we disclose personal information to
We may disclose personal information to:
- Our service providers, including IT, hosting, customer relationship management, email distribution, and analytics providers.
- Our back-office, fund administration, and accounting providers.
- Our professional advisers (legal, accounting, audit, tax).
- Regulators, government agencies, and law enforcement bodies where required or permitted by law.
- Other parties where you have consented or as otherwise permitted under the APPs.
We do not sell personal information.
7. Third-party websites
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites and we encourage you to review their privacy policies before providing personal information.
8. Disclosure of personal information overseas
Some of our service providers operate from, or store information in, locations outside Australia. We take reasonable steps to ensure that overseas recipients handle personal information consistently with the APPs. The countries to which we may disclose personal information typically include the United States, the United Kingdom, Singapore, and member states of the European Union, depending on the location of the service provider.
9. Cookies and similar technologies
Our website uses cookies and similar technologies to operate and to help us understand how visitors use it. For details of the cookies we use and how to manage them, see our Cookie Policy.
10. Security
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. These steps include technical safeguards, access controls, staff training, and contractual obligations on our service providers. No system is completely secure and we cannot guarantee the security of personal information transmitted to us by you.
11. Retention
We retain personal information for as long as it is reasonably needed for the purposes for which it was collected, or for as long as is required by law. Records relating to regulated activity are retained in accordance with applicable record-keeping obligations imposed by law. When personal information is no longer needed, we take reasonable steps to destroy or de-identify it.
12. Your rights
You have the right to:
- Request access to the personal information we hold about you.
- Request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading.
- Request that we cease to hold personal information that is no longer needed, subject to our legal record-keeping obligations.
- Withdraw consent where we have relied on your consent as the basis for processing, noting that withdrawal does not affect the lawfulness of prior processing.
To protect your personal information, we may require you to verify your identity before we release any information to you. We will respond to your request within a reasonable time, ordinarily within 30 days. In some cases we may charge a reasonable fee for processing a request for access. If we refuse a request, we will tell you in writing why we have done so.
13. Complaints
If you believe we have breached the APPs or otherwise mishandled your personal information, please contact our Privacy Officer using the details below. We will acknowledge your complaint within five business days and aim to resolve it within 30 days.
If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by phone on 1300 363 992.
14. Changes to this policy
We may update this policy from time to time. The current version is published on our website with the effective date shown above. We will notify subscribers of material changes.