Privacy Policy

1. About This Policy

Manesh Investment Holdings Pty Ltd (ABN 84 697 004 792 / ACN 697 004 792) ("Manesh Investment Holdings", "we", "us", or "our") is committed to protecting the privacy of individuals who interact with us.

This Privacy Policy explains how we collect, hold, use, and disclose personal information in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs") contained in Schedule 1 of the Privacy Act.

By using our website (maneshiinvestmentholdingspty.site), contacting us, or engaging our services, you consent to the handling of your personal information as described in this Policy.

2. Who We Are

Manesh Investment Holdings Pty Ltd is an investment holding and advisory company registered in Western Australia, Australia.

• Company Name: Manesh Investment Holdings Pty Ltd
• ABN: 84 697 004 792
• ACN: 697 004 792
• Address: WA 6171, Australia
• Email: [email protected]

3. Information We Collect

We may collect the following types of personal information:

• Identity information: full name, date of birth, and identification documents (where required for verification purposes)
• Contact details: email address, phone number, and postal address
• Financial information: investment objectives, risk tolerance, financial situation details, and tax file number (where required for reporting purposes)
• Business information: company name, ABN, business structure, and director details (for corporate clients)
• Communication records: emails, enquiry form submissions, meeting notes, and any other correspondence with us
• Website usage data: IP address, browser type, pages visited, time on site (collected through standard server logs or analytics tools)
• Sensitive information: we generally do not collect sensitive information; where it is required (e.g. for anti-money laundering verification), it is only collected with consent and used only for the stated purpose

We collect personal information by lawful and fair means, and where practicable, directly from you.

4. How We Collect Information

We collect personal information through:

• Enquiry and contact forms submitted on our website
• Direct email, telephone, or in-person communications
• Investment advisory or portfolio management engagement documents
• Identity verification processes (as required by anti-money laundering and counter-terrorism financing legislation)
• Automatically via cookies and server logs when you visit our website
• Third parties such as referral partners, professional advisers, or publicly available registers

Where it is reasonable and practicable, we will notify you of the information we collect and why at or before the time of collection.

5. How We Use Your Information

We use personal information to:

• Respond to your enquiries and provide investment advisory services
• Manage client accounts, portfolios, and investment holdings
• Comply with legal and regulatory obligations, including under the Corporations Act 2001 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and the Australian Consumer Law
• Conduct identity verification and due diligence checks as required by law
• Send communications about our services, portfolio updates, and regulatory changes that may affect your investments
• Improve our website, services, and client experience
• Where you have consented, send marketing communications about relevant services or events
• Conduct internal business administration and record-keeping

We will not use your personal information for purposes other than those for which it was collected, unless you consent or it is required or authorised by law.

6. Disclosure of Personal Information

We may disclose your personal information to:

• Our employees, contractors, and professional advisers (on a need-to-know basis)
• Third-party service providers (e.g. IT/hosting, accounting, legal, custodians) who assist us in operating our business — subject to confidentiality obligations
• Financial institutions and custodians for transaction processing and asset holding
• Government agencies, regulators (including ASIC, AUSTRAC, and the ATO), or law enforcement bodies where required by law
• Courts or tribunals, if we are a party to legal proceedings

We do not sell or rent your personal information to third parties for their own marketing purposes.

We do not generally disclose personal information to overseas recipients. If we do, we will take reasonable steps to ensure the recipient complies with the APPs or a comparable privacy regime, or we will obtain your consent.

7. Data Security

We take reasonable steps to protect the personal information we hold from misuse, interference, and loss, and from unauthorised access, modification, or disclosure. These measures include:

• Secure email and password-protected document storage
• Access controls restricting personal information to authorised personnel
• HTTPS encryption on our website
• Regular security reviews of our systems

No data transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act.

8. Cookies and Website Analytics

Our website may use cookies — small text files stored on your device — to improve your browsing experience and understand how visitors use our site. You can configure your browser to refuse cookies; however, this may limit some website functionality.

We may use third-party analytics tools to collect aggregated, non-personally identifiable information about website traffic and usage patterns.

9. Access and Correction

Under APP 12 and APP 13, you have the right to:

• Request access to the personal information we hold about you
• Request correction of information that is inaccurate, out of date, incomplete, irrelevant, or misleading

To exercise these rights, please contact us at [email protected]. We will respond within 30 days. We may require you to verify your identity before providing access.

In some circumstances, we may refuse access or correction as permitted by the Privacy Act. Where we refuse, we will provide written reasons.

10. Marketing Communications

We may send you marketing communications about our services, investment insights, and events where you have consented to receive them, or where permitted by the Spam Act 2003 (Cth). You may opt out at any time by contacting us at [email protected] or by using the unsubscribe link included in any marketing email.

11. Links to Other Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies independently.

12. Complaints

If you believe we have breached the APPs or this Privacy Policy, you may lodge a complaint by contacting us at:

• Email: [email protected]
• Address: WA 6171, Australia

We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Updated versions will be published on our website with a revised effective date. Continued use of our services after any changes constitutes acceptance of the updated Policy.

14. Governing Law

This Privacy Policy is governed by the laws of Western Australia and the Commonwealth of Australia. Any disputes arising under this Policy shall be subject to the jurisdiction of the courts of Western Australia.

15. Contact Us

For any privacy-related queries or concerns, please contact:

• Manesh Investment Holdings Pty Ltd
• ABN: 84 697 004 792
• WA 6171, Australia
• [email protected]