Privacy Policy

Effective Date: 16 June 2025
Last Updated: 16 June 2025

Westbourne Asset Management Pty Ltd ("Westbourne", "we", "our", "us") respects your privacy. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you interact with us or invest in the Westbourne Absolute Return Fund ("the Fund").

By visiting our website or investing in the Fund, you agree to the terms of this Privacy Policy.

1. What Information We Collect

We collect personal information necessary to provide and manage your investment. This may include:

• Name, address, email and phone number

• Date of birth and identification documents (e.g. passport, driver’s licence)

• Tax File Number (TFN) or Australian Business Number (ABN)

• Bank account details for investment transactions

• Information required for regulatory compliance (AML/CTF, FATCA, CRS)

• Investment and transaction history

2. How We Collect Your Information

We collect information through:

• Application forms submitted via our website or platform

• Communications with you by phone, email, or online form

• Third parties such as advisers or administrators (with your permission)

• Our administration partners and compliance systems

3. Why We Collect It

Your personal information is collected to:

• Process applications, redemptions, and distributions

• Verify your identity and meet legal obligations

• Maintain your investment account

• Communicate with you and provide reporting

• Meet compliance obligations with ASIC, ATO, AUSTRAC and other regulators

We do not sell your information to third parties.

4. Who We Share It With

We may share your information with:

• Our fund administrator (SILC Funds Administration Pty Ltd)

• The Fund trustee (Specialised Investment and Lending Corporation Ltd)

• Legal, tax and compliance advisers

• Government and regulatory bodies (e.g. ATO, ASIC, AUSTRAC)

• Technology service providers who assist in website or platform operations

Where required, information may be shared with overseas recipients in compliance with privacy laws.

5. How We Protect Your Information

We use appropriate security measures including encryption, secure servers, and access controls to protect your data. Personal information is stored securely and only accessed by authorised personnel.

If information is no longer needed, we securely destroy or de-identify it.

6. Accessing or Updating Your Information

You have the right to access or correct your personal information at any time.

To request access or updates, please email investors@silcgroup.com or info@westbourneam.com. We will respond within a reasonable timeframe.

7. Cookies & Website Analytics

Our website may use cookies to enhance your browsing experience and collect non-identifiable usage data (e.g. IP address, browser type). This helps us understand how users interact with our site and improve its functionality.

You can adjust your browser settings to refuse cookies, but this may limit your experience.

8. Complaints

If you believe we have breached your privacy rights, please contact us. We will acknowledge your concern within 5 business days and aim to resolve it within 30 days.

If you're not satisfied, you can contact the Office of the Australian Information Commissioner (OAIC).

9. Changes to This Policy

We may update this policy from time to time. The latest version will always be available on this page.

10. Contact Us

Investment Manager – Westbourne Asset Management Pty Ltd
Level 3, 489 Toorak Road, Toorak VIC 3142
Phone: +61 459 704 088
Email: info@westbourneam.com
Website: www.westbourneam.com

Trustee – Specialised Investment and Lending Corporation Ltd
Level 14, 356 Collins Street, Melbourne VIC 3000
Phone: +61 3 9600 2828
Email: investors@silcgroup.com