Privacy Policy

Privacy Policy Statement

Tenacious Ventures is an Australian AgriFood Tech venture capital firm. We believe that technology is a key enabler of the long-term economically, environmentally, and socially sustainable future. We provide entrepreneurs with the capital and hands-on support they need to transform agrifood supply chains. We invest all along the agrifood supply chain, across areas such as farm inputs, soil, on-farm, supply chain, alternative systems, and new value chains.

Established in 2019, Tenacious Ventures originates and transacts on investments which generate financial performance with sustained environmental and social impact. Tenacious Ventures regularly reports to its investors on the financial, social and environmental returns generated by its assets.

In this policy:

  • "us", "we", "our" or “the company” means Tenacious Ventures and its related bodies corporate including:
  • Tenacious Ventures UGP Pty Ltd — ACN 632 840 049
  • Tenacious Ventures Fund I, LP — NSW ILP1900013
  • Tenacious Ventures Management Partnership, LP  — NSW ILP1900012
  • Tenacious Ventures Fund II Staple Co Pty Ltd  — ACN 660 378 110
  • Tenacious Ventures Fund II UGP Pty Ltd — ACN 660 377 739
  • Tenacious Ventures Fund II, LP  — NSW ILP2200052
  • Tenacious Ventures Fund II Management Partnership, LP  — NSW ILP2200051
  • Tenacious Ventures Group Pty Ltd  — ACN 620 932 292
  • Tenacious Insights Pty Ltd  — ACN 650 616 612
  • Tenacious Ventures Management Pty Ltd  — ACN 632 839 368

and where Tenacious Ventures Management Pty Ltd is a Corporate Authorised Representative (CAR 001275760) of Sandford Capital Pty Ltd (AFSL 461981).

  • "you" or "your" means:
  • prospective limited partners of the fund
  • limited partners of the fund
  • portfolio companies
  • prospective portfolio companies 
  • any party who submits information via our website or email

We recognise an individual’s right to privacy and understand that the protection and confidentiality of your Personal Information is important to you. This policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). These govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au

This Privacy Statement outlines the types of Personal Information we collect, how that information is collected, used, stored, and protected and to whom we may disclose Personal Information.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. In the course of providing products and services we may collect and hold Personal Information that is reasonably necessary for the performance of our functions and activities. 

The types of Personal Information that we may collect from you can include your name, contact details (such as your address, email telephone number), date of birth, nationality, country of birth, individual investment details, bank account information and government identifiers such as tax file number.

Pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act(AML/CTF Act) we may also be required to collect additional Personal Information from you to verify your identity.

We may also collect ‘Sensitive Information’. Sensitive Information is a subset of Personal Information that is given a higher level of protection under the Australian Privacy Principles. 

‘Sensitive information’ is defined in the Privacy Act to mean information or an opinion about an individual’s: racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, health information or biometric information.

Your Sensitive Information may only be used and disclosed:

  • For purposes you have consented to or which are directly related to the primary purpose for which the Sensitive Information was collected.
  • For a secondary purpose that is directly related to the primary purpose and within the reasonable expectations of the individual.
  • For the purpose of data compilation or analysis for internal purposes.
  • In an anonymised format for the purpose of data compilation or analysis to share with third parties. 

Sensitive information may also be used or disclosed where required or authorized by law.

‘Sensitive information’ cannot be shared by ‘related bodies corporate’ in the same way that they may share other ‘Personal Information’.

Use and Disclosure of Personal Information

We collect, use, hold and disclose your Personal Information for the purpose of providing you with our products and services. Collection of your Personal Information allows us to identify you and assess your applications. This includes:

  • Checking whether you are eligible for the product or service or suitable as a prospective investee.
  • Verifying your identity
  • Helping to manage the product or service.
  • Managing relationships with our client
  • Providing our clients with information about our products, services, the markets and developments that may interest them.
  • Facilitating our internal business operations, including to fulfill our legal requirements.

Where applicable, your Personal Information will also be used for related purposes which include, the administering and ongoing management of investments, communication with you and compliance with Australian taxation laws, the Corporations legislation, the AML/CTF Act and other laws and regulations.

Throughout the life of the investment product or service, we may collect and hold additional Personal Information about you. This may include transaction information or making a record of queries or complaints you make. We may also collect Personal Information about individuals who are not clients of Tenacious Ventures (e.g. business contact details of a company representative with whom we deal).

We take steps to ensure that our agents and third parties (e.g.: consultants, advisors and partners) keep your Personal Information confidential and use it only for the purposes for which they, and Tenacious Ventures are authorized.

You may also authorize us to disclose information to other persons nominated by you. These persons may include accountants, financial planners and investment managers. Your express consent is required in these circumstances. We reserve the right to contact you directly pursuant to our statutory obligations under the AML/CTF Act.

Collection of Your Personal Information

We collect most Personal Information directly from you. For example, we will collect your Personal Information when you apply to invest in one of our funds, submit contact information via our webform, via email, or talk to us in person or on the phone.

Sometimes we collect Personal Information about you from other people or organizations. This may happen without your direct involvement subsequent to your consent being provided. For example, we may collect Personal Information about you from:

  • your representatives (including your legal or financial advisor, administrator, trustee, or attorney); and
  • other organizations, who jointly with us, provide products to you.

Disclosure Of Your Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

  • To our employees, contractors, related entities and back-office providers.
  • Third parties who supply services to assist us in performing our administrative functions and in fulfilling our legal and regulatory obligations (e.g. legal and accounting firms, data storage systems and certain SaaS providers).
  • Other organizations, who jointly with us, provide products or services to you.
  • Your representatives (including your legal or financial adviser, accountant, trustee, or attorney).
  • Fraud bureaus or other organizations to identify, investigate or prevent fraud or other misconduct.
  • Where we are authorized or required to do so by law;

In certain limited circumstances, such as where there are foreign indicia on your account, your Personal Information may be shared with the Australian Tax Office and/or ASIC which will then exchange this information with similar overseas regulatory bodies as a result of Australia’s participation in the Common Reporting Standard and Foreign Account Tax Compliance Act. We may also, in accordance with this Privacy Policy, disclose your Personal Information to other third parties who reside outside Australia. In this instance, we will take reasonable steps to ensure that the third party recipient does not breach the Australian privacy laws.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Accessing Or Correcting Your Personal Information

You may contact us to request access to the Personal Information we hold about you at any time.  If you wish to access your Personal Information, please contact us in writing.

We take all reasonable precautions to ensure that the Personal Information that we collect, use and disclose is accurate, complete and current. If you find that the information we have is incomplete, not up to date or is inaccurate, please advise us as soon as practicable so we can update our records. 

In order to protect your Personal Information we may require identification from you before releasing the requested information. In certain circumstances, we may not be able to correct or provide you with access to your information. In these circumstances, we will write to you to explain and provide the reasons as to why access cannot be granted.

We do not charge for receiving a request for access to Personal Information or for complying with a correction request.

Policy Updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints & Enquiries

If you have a query or a complaint regarding your Personal Information, please contact us in writing (contact details provided below). 

We will acknowledge your query or complain within 10 business days of receipt of your written correspondence. We aim to resolve queries and complaints as quickly as possible, so please include enough information to help us with this.

If a complaint remains unresolved, you may apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. www.oaic.gov.au

Contact Details

If you have any queries or complaints about our Privacy Policy, your Personal Information or wish to make a complaint about how we have handled your Personal Information, please contact us at:

Email: manager@tenacious.ventures

Postal Address:
Tenacious Ventures Management Pty Ltd
401/10 West Promenade
Manly, NSW 2095