Privacy Policy

Our commitment to Privacy

Ironbark Capital Limited recognises that your privacy is important. Ironbark Capital Limited is collectively referred to in this Privacy Policy as “we” or “us”.

We are bound by the Privacy Act 1988 (Cth) and bound by, and committed to supporting the Australian Privacy Principles (APPs) set out in the Privacy Amendment (Enhancing Privacy Protection) Act 2012.

This Privacy Policy applies to all of your personal information we collect, use, hold and disclose. By providing/submitting this personal information and using our services, you will be taken to have agreed and consented to the use, collection and disclosure of your personal information by us for the purposes detailed in this Privacy Policy.

From time to time we may change our Privacy Policy. We will notify you about any such changes by posting a notice on our website Please regularly check our website for updates to our Privacy Policy. By continuing to use our services after amendments have been made to the Privacy Policy, you will be deemed to have accepted the terms of the amended Privacy Policy.

Collection of personal information

We have arrangements with companies to provide administrative services and support. Provision of these services includes collecting personal information such as names, addresses, phone numbers, bank account details, tax file numbers and shareholdings. Specifically, the information is used by our share registry, Boardroom Pty Limited (“Share Registry”), and us to enable your shareholding to be administered and maintained, and to respond to shareholder queries and comply with legal and regulatory obligations. We may also collect personal information about you via our website, telephone calls, faxes, emails, letters and/or other means as a means of identification in response to our obligations.

Why do we collect your personal information and how do we use it?

We will only use your personal information for business purposes, for purposes related to your investment, to perform our services, and for any other purposes set out in this Privacy Policy or permitted by law. Your personal information may also be used by us to administer, monitor and evaluate products and services, gather, aggregate and report statistical information, assist you with any queries and take measures to detect and prevent fraud and other illegal activity. Any third party that we disclose personal information to will have its own specific privacy policy, which you should refer to.

We may also disclose personal information for purposes related to your investment to:

(a) our Share Registry for the purposes of managing your investment(s). Where we disclose your personal information to the Share Registry, such personal information will be collected, held, used and disclosed by the Share Registry in accordance with the Share Registry’s privacy policy policy

(b) serviceprovidersincludingauditorsandmailinghouses;

(c) authorities and regulators where we are required or authorised to make disclosures of personal information by law or by/under a court/tribunal (for example, to report on compliance matters to regulators such as the Australian Securities & Investments Commission, the Australian Securities Exchange Limited or the Australian Taxation Office) or where permitted to make such disclosures under the Privacy Act 1988 (Cth) (“Privacy Act”); and

(d) our Company Secretary, where such person is an external third party (ie not an employee of ours), the Board of Directors and our Managers for the purposes of assessing your application and managing your investment(s) and our business. Where our Company Secretary is an external third party we require the Company Secretary to (i) only use your personal information for the purposes of providing company secretarial services to us and (ii) comply with the terms of this Privacy Policy.

We may also disclose your personal information in circumstances where you have consented to the disclosure or where required or permitted by law. The Corporations Act 2001 (Cth) requires certain information about you (including your name, address and details of the securities you hold) to be included in the public register (as applicable). This information is accessible by the public and must continue to be included in the public register even if you cease to be a security holder.

Security of information

We take reasonable steps to protect the personal information we hold about you from misuse, interference, loss, unauthorised access, modification or disclosure. No personal data is stored on our website.

Accuracy of and access to your personal information

We will take reasonable steps to ensure that any personal information we retain about you is accurate, complete, relevant, and up-to-date, but we request your assistance to help us do so. If you believe that any personal information we hold about you is inaccurate, misleading, irrelevant, incomplete or out of date, please contact us at the contact details set out below.

You may request access to your personal information that we hold by contacting us via the details set out below.

Internet Privacy

In general, you can visit our website without revealing personal information about yourself. When you visit our website, our internet service provider and website managers may make a record of your visit, logging information such as your email address (if this is disclosed) and/or IP address (if applicable), the date and time of your visit, the pages accessed, the domain where you clicked through from, and the type of browser you have used. This information is collected for trend and statistical purposes, and so that we can analyse and enhance its website’s functions and capabilities.

Our website may make use of cookie technology to provide you with better and more efficient service next time you visit our website. Cookies are unique identifiers which are sent from our website to your computer or system (PC), tracking the web pages you have visited. Cookies enable us to relate your use of the website to information that you have specifically provided to us (such as a member password for any service we may provide via the website) and allow your web browser to track searches you have performed on our website. Cookies are stored on your PC, not on our servers. You can elect to disable cookies through your browser setting options.


If you wish to make a complaint about a breach of this Privacy Policy or the Privacy Act and its privacy principles by us, you can contact us using the contact details set out below. You will need to provide sufficient details regarding your complaint in addition to any supporting evidence and information.

We will refer your complaint to the Company Secretary who will investigate the issue and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any further information from you and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns or contact the Australian Privacy Commissioner via

Contact Details

If you have any questions or would like further information on our privacy and information handling practices, please use the contact details below:

Ironbark Capital Limited: Company Secretary

Telephone Number: (02) 8917 0399


Address: Suite 607, 180 Ocean St, Edgecliff NSW 2027