Privacy Policy
Last updated: July 2026
Introduction
Trident Property recognises that your privacy is important and is committed to protecting the personal information we collect and hold.
The Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable privacy laws govern the way in which we handle personal information.
This Privacy Policy explains how Trident Property collects, holds, uses, discloses and otherwise manages personal information in connection with our websites, Investor Portal and the property advisory, funds management, investment, trustee, asset management, property management, transactions and related services we provide.
This policy applies to investors and prospective investors, beneficial owners, trustees, directors, authorised representatives, advisers, clients, suppliers, employees, job applicants and other individuals who interact with us.
We may update this Privacy Policy from time to time by publishing an updated version on our website and, where appropriate, through the Investor Portal. We encourage you to review this page periodically.
Key terms
In this Privacy Policy:
‘Authorised Representative’ has the meaning given in section 9 of the Corporations Act 2001 (Cth).
‘identification information’ means information used to verify an individual’s identity, including their name, date of birth, address, government identifiers and information contained in an identity document.
‘Investor Portal’ means the online platform used by investors and prospective investors to review investment opportunities, submit applications, provide identification and compliance information, and monitor or administer investments.
‘personal information’ has the meaning given in the Privacy Act 1988 (Cth), being information or an opinion about an identified individual, or an individual who is reasonably identifiable.
‘sensitive information’ has the meaning given in the Privacy Act 1988 (Cth).
‘Trident Property’ means Trident Property Advisory Pty Ltd ABN 46 074 003 991 and Trident Funds Management Pty Ltd ABN 93 113 469 006, AFSL 298979, including Trident Funds Management Pty Ltd when acting in its capacity as trustee or manager of a unit trust, fund or other investment vehicle, and, from time to time, each of their Authorised Representatives.
‘we’, ‘us’ and ‘our’ mean Trident Property.
A unit trust, fund or other investment vehicle is not included as a separate legal entity merely because Trident Funds Management Pty Ltd acts as its trustee or manager. References to Trident Funds Management include it acting in that capacity.
Types of personal information we collect
The kinds of personal information we collect and hold depend on your relationship and interactions with us. They may include:
name, residential and postal address, email address, telephone number, date and place of birth, citizenship, residency and tax residency;
identification information and government-related identifiers, including passport, driver licence, Medicare and tax identification details, where collection is authorised or required by law;
copies of identity documents, photographs, facial images and verification results used for identity verification;
information about companies, trusts, partnerships, superannuation funds and other investment structures, including their trustees, directors, partners, beneficiaries, members, beneficial owners, controllers, authorised signatories and representatives;
financial information, including bank account details, payment instructions, financial circumstances, income, assets, liabilities, source of funds, source of wealth, investment experience and investor classification;
investment information, including applications, commitments, unit or security holdings, transactions, capital calls, distributions, transfers, redemptions, valuations and tax reporting information;
anti-money laundering and counter-terrorism financing information, including customer due diligence, beneficial ownership, politically exposed person, sanctions, fraud, adverse media and risk-screening information;
information relating to property, advisory, asset management, property management, transactions and other services provided by us;
records of communications, enquiries, complaints, consents, instructions and meetings;
employment application information where you apply for a role with us;
technical and usage information, including IP address, device and browser details, cookies, portal authentication records, access logs and online activity; and
any other information reasonably necessary to provide our services, comply with our obligations or conduct our business.
Except where permitted by law, we will only collect sensitive information with your consent and where it is reasonably necessary for our functions or activities. This may include biometric or identity-verification information collected as part of an investment application or compliance process.
How we collect personal information
We generally collect personal information directly from you, including through our websites, Investor Portal, application forms, emails, telephone calls, meetings, correspondence and other interactions.
We may also collect personal information from:
your authorised representative, adviser, accountant, solicitor, trustee, employer or another person acting on your behalf;
issuers, responsible entities, trustees, custodians, registries, fund administrators, banks and other financial institutions;
identity-verification, document-verification, customer due diligence, sanctions, fraud-prevention and risk-screening providers;
government agencies, regulators and public registers, including ASIC, the Australian Business Register and other lawful databases;
our related entities, service providers and business partners;
publicly available sources; and
cookies, analytics tools, authentication logs and similar technologies when you use our websites or Investor Portal.
Where it is unreasonable or impracticable to collect information directly from you, we may collect it from a third party. We will notify you where required by law.
If you provide personal information about another person, you must ensure that you are authorised to do so and, where appropriate, that the person has been informed of this Privacy Policy.
How we use personal information
We may collect, hold, use and disclose personal information to:
respond to enquiries and provide, administer and improve our services;
assess, process and administer applications for investment opportunities, funds, trusts and other investment products;
establish and administer investor accounts and maintain investor, unit-holder or security-holder registers;
determine investor eligibility, including wholesale, sophisticated or professional investor status;
verify identity, beneficial ownership and control, assess source of funds or wealth, conduct customer due diligence and undertake sanctions, politically exposed person, fraud and risk screening;
comply with obligations under anti-money laundering and counter-terrorism financing laws, the Corporations Act 2001 (Cth), taxation laws, trust laws and other applicable legal or regulatory requirements;
process subscriptions, capital calls, payments, distributions, transfers, redemptions and other transactions;
provide investor reports, statements, notices, tax information, valuations and communications;
manage funds, trusts, investments, properties, assets, transactions, service providers and related operations;
provide and secure our websites and Investor Portal, communicate service updates and investigate unauthorised or suspicious activity;
manage our client, supplier, employee and business relationships;
undertake risk management, audit, insurance, governance, legal and compliance activities;
respond to complaints, disputes, regulatory requests and legal proceedings;
send marketing information about our services or investment opportunities where permitted by law, subject to your right to opt out; and
carry out any other purpose authorised by you or permitted or required by law.
We do not sell personal information.
If we are unable to collect required information, we may be unable to process an application, verify identity, accept or administer an investment, provide a service, make a payment or comply with our legal obligations.
Secondary use
We may use or disclose personal information for a secondary purpose where you have consented, where the secondary purpose is related to the primary purpose and you would reasonably expect the use or disclosure, or where the use or disclosure is otherwise permitted or required by law.
Disclosure of personal information
We may disclose personal information where reasonably necessary for the purposes described in this Privacy Policy, including to:
related entities within Trident Property;
responsible entities, trustees, custodians, registries, fund administrators, investment managers, asset managers and property managers;
Caruso, which provides our Investor Portal and related fund-administration technology, and other technology, hosting, cybersecurity, data-storage and analytics providers;
banks, payment providers and other financial institutions;
Entrust and its Onfido identity-verification services, the Australian Government Document Verification Service through an approved gateway provider, and other anti-money laundering, sanctions, fraud-prevention and risk-screening providers;
accountants, auditors, solicitors, tax advisers, valuers, insurers, consultants and other professional advisers;
your authorised representatives, advisers, signatories and agents;
issuers, counterparties, lenders, prospective lenders and transaction parties where relevant to a fund, investment, property or transaction;
AUSTRAC, ASIC, the Australian Taxation Office, courts, law-enforcement bodies and other government agencies or regulators where required or authorised by law;
a prospective purchaser, successor, financier or adviser in connection with a proposed sale, restructure, merger, transfer or financing of our business, a fund or an investment; and
any other person authorised by you or permitted or required by law.
Where personal information is disclosed to a service provider, we take reasonable steps appropriate to the circumstances to require that it is handled securely and consistently with applicable privacy laws.
Further information about Caruso’s handling of personal information is available in its privacy policy.
Further information about Entrust and Onfido’s identity-verification services is available in the Entrust Identity Verification Services Product Privacy Notice.
Overseas disclosure and overseas investors
Some service providers or their systems may be located outside Australia. As a result, personal information may be disclosed to, stored in or accessed from overseas.
Our current service-provider arrangements may involve personal information being stored, processed or accessed in Australia and New Zealand.
Where we disclose personal information overseas, we will take reasonable steps to ensure that it is handled in accordance with applicable Australian privacy laws, unless an exception applies.
We may accept investors who are located outside Australia, including in New Zealand and Papua New Guinea. If you provide personal information to us from another country, Australian privacy laws will apply to our handling of that information and local privacy or data-protection laws may also apply depending on the circumstances.
Document Verification Service and identity verification
We may use the Australian Government’s Document Verification Service (DVS), through an approved gateway service provider, to match identification information with records held by the relevant issuing authority.
For this purpose, we may disclose identification information to the gateway service provider, government bodies and database owners and receive a match result. The Privacy Act 1988 (Cth), the Identity Verification Services Act 2023 (Cth) and applicable DVS terms govern this process.
We use Entrust’s Onfido identity-verification services and may use other third-party providers to perform electronic identity verification, facial or biometric verification where authorised, beneficial ownership checks, sanctions screening, politically exposed person checks, fraud detection and related compliance activities.
If you do not provide required identification information or do not consent to an available electronic verification method, we may be unable to provide the relevant service. You may contact us to discuss whether an alternative verification method is available.
Access and correction
You may request access to personal information we hold about you or ask us to correct information that you believe is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, contact us using the details below. We may ask you to verify your identity.
We will respond within a reasonable period. We may charge reasonable costs of providing access where permitted by law, but we will not charge you for making the request.
In some circumstances, we may refuse access or correction where permitted or required by law. If we do, we will generally provide written reasons and explain the available complaint options.
Retention
We retain personal information for as long as reasonably necessary for the purposes for which it was collected and to satisfy our legal, regulatory, taxation, audit, dispute-resolution and record-keeping obligations.
Certain customer due diligence and transaction records may be required to be retained for at least seven years under applicable anti-money laundering and other laws.
When personal information is no longer required for a permitted purpose and we are not legally required to retain it, we will take reasonable steps to destroy or de-identify it.
Security and data breaches
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. These steps may include physical security, access controls, authentication, encryption, monitoring, staff training, confidentiality obligations, secure service-provider arrangements and incident-response procedures.
No method of electronic transmission or storage is completely secure. You should protect your Investor Portal credentials and notify us promptly if you suspect unauthorised access.
We maintain procedures for identifying, assessing and responding to suspected data breaches. Where a breach is an eligible data breach under the Notifiable Data Breaches scheme, we will notify affected individuals and the Office of the Australian Information Commissioner as required by law.
Websites, Investor Portal, cookies and analytics
Our websites and Investor Portal may use cookies, web beacons, pixels, log files and similar technologies to operate securely, remember preferences, authenticate users, analyse use and improve functionality. These technologies may collect information such as IP address, browser and device details, pages viewed, session duration, referral source and portal activity.
You may be able to block or delete cookies through your browser settings. Some functions may not operate correctly if cookies are disabled.
Our websites or Investor Portal may contain links to third-party websites or services. Those third parties have their own privacy practices, and we recommend reviewing their privacy policies before providing personal information.
The supply of personal information over the internet is at your own risk. We take reasonable steps to maintain secure systems and connections but cannot guarantee that internet transmissions will always be secure.
Direct marketing
We may use your contact details to send you information about our services, investment opportunities, events or developments that we reasonably consider may be of interest to you, where permitted by law.
You may opt out at any time by using the unsubscribe facility in a communication or contacting us. We will not charge you for making an opt-out request. Opting out of marketing does not prevent us from sending service, investment administration, legal or regulatory communications.
Privacy complaints
If you believe that we have breached your privacy or have concerns about how we have handled personal information, please contact our Privacy Officer. Your complaint should include enough detail for us to understand and investigate the issue.
We will acknowledge your complaint and aim to respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner.
Contact us
Privacy Officer
Trident Property
GPO Box 2533, Brisbane QLD 4001
Telephone: 07 3222 3000
Email: privacy@tridentproperty.com.au
Further information about privacy in Australia is available from the Office of the Australian Information Commissioner at www.oaic.gov.au.
Investor Portal privacy collection notice
The following short notice may be displayed at registration and at points where significant identity, financial or compliance information is collected:
Trident Property collects your personal information to establish and administer your Investor Portal account, process investment applications and transactions, manage your investments, verify your identity and beneficial ownership, conduct anti-money laundering, sanctions and fraud checks, comply with taxation and regulatory obligations, and communicate with you. We may disclose your information to Caruso, Entrust and Onfido, our fund-administration and identity-verification providers, responsible entities, trustees, custodians, registries, banks, professional advisers and government or regulatory authorities. Personal information may be stored, processed or accessed in Australia and New Zealand. If you do not provide required information, we may be unable to process your application or provide the relevant service. This Privacy Policy explains how you may access or correct your information and make a privacy complaint.