CSIRO Financial Services Pty Ltd trading as Main Sequence Ventures is the fund manager of CSIRO Innovation Fund 1, LP and CSIRO Innovation Follow-on Fund 1 (the Fund). We are committed to protecting your personal information and complying with the Privacy Act 1998 (Cth) (Privacy Act) and Australian Privacy Principles (APPs). Any reference to “we”, “us” or “our” is a reference to CSIRO Financial Services trading as Main Sequence Ventures.
Purpose of document
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.
What types of personal information do we collect and hold?
We collect personal information from investors, prospective investee companies of the Fund, investee companies of the Fund and from the public.
The types of personal information that we collect depends on the nature of your dealings with us, but usually includes your name, title, date of birth, your company, business address, email address and telephone number. It may also include details about your company, such as income, assets and liabilities.
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 or criminal record.
How do we collect and hold personal information?
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:
- Online forms (such as enquiries forms);
- Surveys (hard copy or online);
- Information associated with accessing and using the Main Sequence Ventures website;
- Over the telephone;
- In person in a meeting or interview scenario;
- Via emails or other correspondence sent to us;
- By taking photographs or videos at our events;
- Third parties, for example reports relating to ownership of IP; or
- From publicly available information, such as interactions with Main Sequence Ventures via social media sites.
For what purposes do we collect, hold and use personal information?
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 CSIRO 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:
- you have consented to the other use;
- you would reasonably expect, or have been told, that your personal information is usually passed on to other entities;
- it is required or authorised by law;
- it will prevent or lessen a serious threat to someone’s life, health or safety (including public health and safety);
- required to take appropriate action in relation to suspected unlawful activity or serious misconduct;
- required to locate a missing person; or
- required to assert a legal or equitable claim or to conduct an alternative dispute resolution process.
Set out below is some further detail of how we may use personal information collected for certain of our main activities.
Visiting the Main Sequence Ventures website
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:
- user’s server address (IP address)
- user’s internet service provider (ISP)
- user’s operating system (for example Windows, Mac etc)
- user’s top level domain name (for example .com, .gov, .au, .uk etc)
- date and time of the visit to the site
- pages accessed and the documents downloaded
- previous site visited if you visited from a hyperlink to our website via another web page
- exit link
- screen resolution
- type of browser used.
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 Ventures 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 e-mail to a Main Sequence Ventures address (firstname.lastname@example.org), the content and your details, including your e-mail address, become part of our records. Your e-mail 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.
Completing an online form
Should you decide to complete and submit an online form on any part of the Main Sequence Ventures website, we:
- may record personal details provided by you such as: e-mail address, street address, telephone number, occupation, company, areas of interest etc to the extent they are relevant to the purpose for which we are collecting them;
- will only used this information for the purpose for which it was collected; and
- will not disclose this information without your consent except where CSIROFS may be required by law to disclose the information.
When you contact us for general information about our activities, we will:
- log the contact (online or otherwise) in a secure database;
- record your name and other contact details, and information about the nature of the enquiry and response provided;
- record phone calls for the purpose of quality assurance and coaching;
- not add you to a mailing list, but may seek consent to contact you to provide feedback on the service provided; and
- not disclose the information collected without your consent except where CSIROFS may be required by law to disclose the information.
Direct communication from us
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:
- hold all personal information in secure databases, both at onsite and offsite locations;
- ensure that at any time, a recipient of e-mailed mass communication may ask to “unsubscribe” from our central marketing/communication database; and
- ensure that a direct link to “unsubscribe” is generally made available in mass communications from us. Alternatively, unsubscribe requests can be made via our Enquiry form.
How do we store personal information?
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.
Disclosures of personal information overseas
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.
Access to and amendment of personal information held by us
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.
If you have a privacy related complaint about us, please contact email@example.com.