CSIRO Financial Services Pty Ltd trading as Main Sequence (Main Sequence) is the fund manager of certain early-stage Australian venture capital funds (collectively, the Funds). We are committed to protecting your personal information and complying with the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APPs). Any reference to “we”, “us” or “our” is a reference to Main Sequence.
Please contact us via the "contact us" form below or email us at privacy@mseq.vc.
This document describes the policies and procedures that we have in place for the management and protection of personal information that we collect and hold.
We collect personal information from prospective investors, investors, prospective investee companies of the Funds, investee companies of the Funds and from the public.
The types of personal information that we collect depend on the nature of your dealings with us, but usually include your name, title, date of birth, your company, business address, email address and telephone number. It may also include further details, such as investor status, income, assets and liabilities, and any information you provide to us which are required for anti-money laundering and counter terrorism financing purposes (such as identification documents).
We may also collect certain information that you provide to us (for example, through feedback or surveys).
The personal information held by us may include sensitive information, including information about a person’s race or ethnic origin, membership of a professional or trade association, bankruptcy or criminal record. Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.
Where it is reasonably practicable to do so, we collect personal information directly from you. However, on occasions, we may need to collect personal information from other sources such as public records, parents or guardians of children under the age of 18 years and third parties. When dealing with children, we seek parental consent prior to the collection of personal information, including photographs.
We may collect personal information in various ways, including via:
We collect, hold and use personal information so we can establish, manage and administer the products and services provided by us or our affiliates, and comply with legal and regulatory obligations. We may also use and disclose your information for purposes related to those mentioned above, such as assisting with your questions, arranging for services to be provided by third parties, and internal operations (such as record keeping, auditing or training). We may also share your personal information with other entities within the Main Sequence group, for reasonable business purposes.
When we collect personal information from you for certain specific activities, where required, we will use a collection notice that deals specifically with that collection, including a description of the purposes for which we will use the personal information collected in that instance.
From time to time, we may need to disclose personal information to our limited partners or share information with contractors or agents who provide services to us, such as off-site file storage facilities and financial institutions which transmit payments on our behalf.
We will collect personal information from you for the purposes described in a collection notice and will only use or disclose your personal information for other purposes if:
Set out below is some further detail of how we may use personal information collected for certain of our main activities.
When visiting www.mseq.vc, a record of your visit is logged. The following information, supplied by your browser, is recorded for statistical purposes to help improve this website:
We may also use cookies, pixels and similar technologies, including third-party analytics tools, to understand how visitors interact with our website and to improve its performance. You can disable cookies in your browser settings, although some site features may not function correctly if you do so.
No attempt will be made to identify users or their browsing activities except in the unlikely event of an investigation required by law where a law enforcement agency may exercise a warrant to inspect the Internet Service Provider’s logs.
We will not release your personal information collected via the Main Sequence website to any person unless the law requires or permits it or your permission is given. We provide a secure environment and a reliable system but you should be aware that there are inherent risks associated with the transmission of information via the Internet.
When you send an email to a Main Sequence address (name@mseq.vc), the content and your details, including your email address, become part of our records. Your email address, acquired in this way, will not be added to any mailing list unless specified in a collection statement or unless we obtain your consent.
Should you decide to complete and submit an online form on any part of the Main Sequence website, we:
When you contact us for general information about our activities, we will:
We store the contact details of a range of clients and stakeholders. This information may be used to disseminate information and to facilitate participation in events and our activities. In managing this information, we will:
All personal information collected by us is stored securely. We hold your personal information in a combination of secure computer storage facilities, paper-based files and other formats.
We may use third parties to store some personal information on servers in Australia or overseas, but only where steps have been taken to ensure that the third parties comply with our privacy obligations.
We retain personal information only for as long as it is reasonably necessary for the purposes for which it was collected, or as required by law (including, for example, retention obligations under tax or AML/CTF legislation). Once personal information is no longer required and we are not legally required to retain it, we will take reasonable steps to destroy or de-identify the information, in line with our obligations under the Privacy Act.
We may disclose personal information overseas from time to time, for example, by storing information on a server located overseas. Where we may be transferring personal information overseas, we will either inform you and seek your consent to the arrangement or ensure that appropriate contractual measures are in place to ensure that the overseas entity protects the personal information to the same level as required of us under the Privacy Act.
We will provide you with access to your personal information that we hold, subject to any applicable exceptions under the Privacy Act. We will require you to verify your identity and specify, as clearly as possible, the information that you wish to access. We will not charge you for lodging a request for access to your own personal information, but may charge for reasonable administrative costs. The fee will be determined on a case-by-case basis, and you will be informed beforehand of the likely cost.
If you can establish that information held by us about you is inaccurate, irrelevant, out of date, incomplete or misleading, we will take reasonable steps to amend it. If we disagree with your view about the status of this information, we will provide reasons for the refusal and record a statement in our records of your view.
Main Sequence has procedures in place to identify, contain, assess and respond to data breaches. Where we suspect an eligible data breach (as defined in the Privacy Act), we will assess the breach promptly and, where required, notify affected individuals and the Office of the Australian Information Commissioner (OAIC).
If you are in the EU or the UK, the GDPR and the UK GDPR may apply to how we handle your personal information, alongside the Privacy Act. Where they apply, Main Sequence is the data controller, and we process your personal information on one or more of the following bases, depending on the context: our legitimate interests in running the Funds and our investor and portfolio relationships, performance of a contract with you, compliance with a legal obligation, or your consent.
You can ask us what personal information we hold about you and how we use it, ask us to correct or delete it, restrict or object to how we process it, transfer it to you or another organisation, or stop using it for automated decisions that have a legal or similarly significant effect on you. Where we rely on your consent, you can withdraw it at any time. To make any of these requests, contact us at privacy@mseq.vc. Where we transfer personal information out of the EU or UK, we put in place safeguards consistent with what we describe under “Disclosures of personal information overseas” above.
If you have a concern about how we handle your personal information, please raise it with us first so we can try to resolve it. You can also lodge a complaint with the supervisory authority for the country where you live.
From time to time, Main Sequence may use automated tools, including AI-assisted tools, to support our analysis of investments, deal flow, portfolio performance and operations. Where automated processes use personal information to make, or substantially influence, decisions that significantly affect an individual, we will provide additional disclosure consistent with our obligations under the Privacy Act, including any automated decision-making transparency requirements.
If you have a privacy-related complaint about us, please contact privacy@mseq.vc. We will acknowledge your complaint within 7 days of receipt, and aim to provide a substantive response within 30 days. If you are not satisfied with how we have handled your complaint, you may raise the matter with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.
