Privacy Policy

1. Introduction

Skale Capital Pty Ltd ("Skale Capital", "we", "us", "our") is committed to protecting the privacy of personal information we collect, use, and disclose. We are bound by the Privacy Act 1988 (Cth) ("Privacy Act"), including the Australian Privacy Principles ("APPs").

Skale Capital operates under Brindabella's Australian Financial Services Licence (AFSL 510735). This Privacy Policy explains how we handle personal information in connection with our private credit fund management and lending activities.

2. What Personal Information We Collect

The types of personal information we may collect include:

• Identity information: name, date of birth, residential address, email address, phone number, and government-issued identification (e.g. driver's licence, passport)
• Financial information: income details, bank statements, tax returns, asset and liability statements, loan and mortgage details
• Credit information: credit history, credit scores, default information, repayment history, and court records (where applicable)
• Business information: ABN/ACN, company extracts, trust deeds, directorship details, and beneficial ownership information
• Property information: property valuations, title searches, rates notices, contracts of sale, and development approvals
• Employment information: employer details, position, and employment history
• Technical information: IP address, browser type, device information, and website usage data collected via our online platform

3. How We Collect Personal Information

We collect personal information:

• Directly from you — via our website contact form, email, phone, or in person
• From your finance broker or financial adviser acting on your behalf
• From third-party service providers — including credit reporting bodies, property valuation firms, identity verification providers, and legal practitioners
• From publicly available sources — including ASIC registers, land title registries, court records, and business directories
• Through our online platform — when you interact with our broker, investor, or borrower portals

Where practicable, we will collect personal information directly from you. If we collect information from a third party, we will take reasonable steps to ensure you are aware of this collection.

4. Why We Collect Personal Information

We collect and use personal information for the following purposes:

• Assessing loan applications and credit risk
• Managing our lending portfolio and fund operations
• Verifying your identity in accordance with Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) requirements
• Preparing and issuing loan documentation
• Communicating with you about your loan or investment
• Processing payments and managing settlements
• Complying with our legal and regulatory obligations
• Managing investor relationships and reporting
• Improving our products, services, and platform functionality
• Responding to enquiries submitted through our website

5. Disclosure of Personal Information

We may disclose your personal information to:

• Finance brokers: who introduced or are managing your loan application
• Legal practitioners: for loan documentation, settlements, and enforcement
• Valuers: for property valuation and assessment purposes
• Credit reporting bodies: to obtain or provide credit reports (see Section 6)
• Identity verification providers: to verify your identity under AML/CTF legislation
• Our wholesale funding partners: as required under our funding arrangements
• Regulatory bodies: including ASIC, AUSTRAC, and the Australian Taxation Office where required by law
• Our AFSL holder: Brindabella, for compliance and licensing obligations
• Technology service providers: who support our platform and operations (subject to confidentiality agreements)
• Professional advisers: including accountants and auditors

We will not sell your personal information to third parties for marketing purposes.

6. Credit Reporting

Skale Capital provides business purpose, non-regulated commercial loans only. In the course of assessing a loan application, we may:

• Obtain commercial credit reports from credit reporting bodies (e.g. Equifax) for borrowing entities and their directors/guarantors
• Use credit information to assess the creditworthiness of a borrowing entity and its associated parties
• Disclose credit-related information to our wholesale funding partners as part of the loan assessment process

As we provide non-regulated commercial lending only, the Credit Reporting Privacy Code 2014 consumer credit reporting provisions do not apply to our lending activities. However, we still handle all credit information in accordance with the Australian Privacy Principles.

7. Anti-Money Laundering and Counter-Terrorism Financing

Skale Capital is required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ("AML/CTF Act"). As part of our obligations, we must:

• Verify the identity of borrowers, guarantors, directors, and beneficial owners before providing a designated service
• Collect and retain identification documents (e.g. driver's licence, passport, company extracts)
• Monitor transactions for suspicious activity
• Report suspicious matters and threshold transactions to AUSTRAC as required by law

Personal information collected for AML/CTF purposes is retained for a minimum of 7 years after the end of the business relationship, as required by the AML/CTF Act.

8. Data Security

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. Our security measures include:

• Encryption of data in transit and at rest (AES-256)
• Access controls and authentication on our platform and systems
• Regular security reviews and monitoring
• Staff training on privacy and data handling obligations
• Secure document storage and retention practices

When personal information is no longer needed for the purpose for which it was collected, and we are not required by law to retain it, we will take reasonable steps to destroy or de-identify that information.

9. Notifiable Data Breaches

In the event of a data breach that is likely to result in serious harm to any individual whose personal information is involved, we will comply with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act. This includes notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) as required.

10. Access and Correction

You have the right to:

• Access the personal information we hold about you
• Request correction of any information that is inaccurate, incomplete, out-of-date, or misleading

To make a request, please contact us using the details in Section 12 below. We will respond to your request within 30 days. In some circumstances, we may refuse access or correction — if so, we will provide you with written reasons.

11. Overseas Disclosure

We primarily store and process personal information within Australia. If we disclose personal information to an overseas recipient (for example, a cloud service provider with overseas servers), we will take reasonable steps to ensure the recipient handles the information in accordance with the APPs.

12. Use of Artificial Intelligence

Skale Capital uses artificial intelligence (AI) tools to assist in the assessment and processing of loan applications. This may include:

• Automated extraction of data from documents you provide (e.g. financial statements, identification documents, credit reports, valuations)
• AI-assisted credit analysis to identify risks, inconsistencies, or missing information across your application
• Generation of assessment summaries for review by our credit team

Important: AI tools are used to assist our team — not to make lending decisions. All credit decisions are made by authorised human decision-makers. AI outputs are reviewed, and you have the right to request a fully human review of any assessment at any time.

We take reasonable steps to ensure our AI tools process your information accurately and securely. Document data processed by AI is handled in accordance with this Privacy Policy and is not used to train third-party AI models.

13. Cookies and Website Analytics

Our website may use cookies and similar technologies to improve your browsing experience and to analyse website traffic. You can manage your cookie preferences through your browser settings. We do not use cookies to collect personally identifiable information without your consent.

14. How to Contact Us

If you have any questions about this Privacy Policy, wish to make a privacy-related complaint, or would like to request access to or correction of your personal information, please contact us:

Skale Capital
Level 1, 84 Elizabeth Street
Melbourne VIC 3000
Email: admin@skalecapital.com.au

We will acknowledge your complaint within 7 business days and aim to resolve it within 30 business days.

15. Complaints to the OAIC

If you are not satisfied with our response to a privacy complaint, you may lodge a complaint with the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
Website: www.oaic.gov.au
Phone: 1300 363 992
Email: enquiries@oaic.gov.au

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated policy will be published on our website with the revised date. We encourage you to review this policy periodically.

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This Privacy Policy is provided for informational purposes. Skale Capital operates under Brindabella's Australian Financial Services Licence (AFSL 510735). For matters relating to the AFSL, please contact Brindabella directly.