Last updated: 26 November 2025
Our approach to privacy
Bellinger Asset Management Pty Limited, Bellinger Aviation Pte Limited and Bellinger Aviation (Ireland) Limited (referred to collectively in this privacy policy as “we”, “us”, “our” or “Bellinger”) are committed to complying with the Privacy Act 1998 (Cth) (the “Privacy Act”).
We may amend this policy from time to time by publishing updates on our website. Please check our website for the most current version.
What information do we collect?
We aim to collect personal information directly from you, however, on occasion we may also collect information about you from other individuals or organisations.
We may collect personal information when:
- you visit our website or online services (including the investor portal);
- you enquire about or use our products or services;
- you contact us or do business with us;
- you register for or attend one of our events or subscribe to one of our mailing lists;
- you enquire about or apply for a role at Bellinger or otherwise work temporarily or on contract for Bellinger;
- we have other business dealings with you or an organisation related to you; or
- you are an employee, partner or contractor of Bellinger.
The types of personal information we collect may include:
- your name, address, job title, email address and telephone number;
- information about your business relationship with us;
- information about your professional role and background;
- if you apply for a role with us, information about your work history, references and information about your right to work in Australia or one of our other office locations;
- you or your organisation’s financial or billing information, such as billing address, bank account, payment and credit card details; and
- user names and passwords where they are required on our website or for access to our systems as part of our services (collectively, “Business Data”).
You do not have to provide us with your Business Data, but this may impact the services we may provide to you. For example, we may not be able to provide or receive (or continue to provide or receive) services to or from you.
If we need to conduct identification verification and authorisation checks or anti-money-laundering or similar background checks involving you, this may require more extensive personal data about you – for example, a copy of your passport, and details such as your date of birth and signature. We sometimes collect personal data from third party data providers, international sanctions lists or other publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations (collectively, “Verification Data”).
If you exchange emails, telephone conversations or other electronic communications with us and our staff members, our information technology systems may record details of those communications, including their content (collectively, “Communication Data”).
If you visit our websites, our servers will collect some information about you and your visit, including the internet protocol (“IP”) address used to connect your device to the internet and some other information such as your browser type and the pages on our site that you visit (collectively, “Technical Data”). Our website may also download “cookies” to your device as described in the Using our Website and Cookies section below.
Why do we collect, use and store your personal information?
We may use your information to:
- provide our products and services to you, your organisation and our customers;
- check whether there is any conflict of interest between us and you and/or between you and another customer;
- improve our business and services;
- manage and monitor our business and internal operations, including security, risk and crime prevention;
- comply with our legal and regulatory obligations and to exercise or defend our legal rights;
- provide information for audits or quality checks;
- send you event details (however, if you do not want to receive invitations to our events, you can opt out at any time by emailing us at the address set out in the Contact us section below;
- perform analytics on transaction management and financial performance using online resources or technology; and
- deal with requests, enquiries or complaints.
Who do we share your personal information with?
We may share your personal information where reasonably necessary for the various purposes set out above or where the law otherwise allows us or requires us to.
The types of third parties we may share your personal information with include:
- Bellinger’s direct and indirect shareholders, subsidiaries and other affiliates;
- your colleagues representing the customer with whom you are associated or from whom we received personal data about you, or our other customers (where we have a lawful basis to do so);
- counterparty financial institutions, and other persons from whom we receive, or to whom we make, payments, or with whom we conduct other transactions;
- our auditors and our legal, accounting and other professional advisors, so that they can advise us;
- other service providers who hold or process your personal data on our behalf, under strict conditions of confidentiality and security;
- third parties who will or may take control or ownership of some or all of our business or assets in connection with a significant corporate transaction, restructuring or insolvency (and professional advisors acting on our or their behalf); or
- regulatory, tax, law enforcement or other governmental agencies, courts or litigation counterparties, in any country or territory.
Sending information overseas
Sometimes we may send your information overseas, including to:
- Bellinger group members that are located in Singapore or Ireland;
- professional advisors, service providers or third parties who store data or operate outside Australia;
- complete international transactions;
- organisations we partner with to provide products and services; or
- comply with laws and help government or law enforcement agencies.
We will only transfer your information overseas where you have given us your consent or we reasonably believe there are appropriate privacy, data handling and security arrangements in place to protect your information.
While we aim to use services that are located within Australia, some of our suppliers and other parties we work with may receive, access, process, host or store your information in overseas locations.
How do we store and keep your personal information secure?
We may hold your personal information in electronic or hard copy form. We have implemented appropriate technical and organisational measures to keep your personal information confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. We use a variety of security measures to keep your personal information secure. For example, we restrict physical access to our offices, employ firewalls, use secure IT systems and use anti-virus software and cyber security services.
However, please note we cannot guarantee the security of your personal information so if you do send us personal information through our website or other electronic means, please be aware that this is at your own risk.
We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law. If we no longer engage with you, are no longer providing goods or services to you, or are no longer receiving goods or services from you, we will usually delete or anonymise your account data after seven years. Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Using our website and cookies
Cookies (small text files) may be placed on your computer to improve your experience on the [bellingergroup.com] website (the “website)”. No attempt will be made to identify individual users based on cookies or browsing activities, except in the unlikely event of an investigation or where compelled by a law enforcement agency to provide access to internet web server logs. You may configure your web browser to accept all cookies, reject all cookies, use only necessary cookies or notify you when a cookie is sent. If you disable the use of cookies on your web browser or remove or reject specific cookies from the website, then you may not be able to gain access to all content and facilities on the website or your browsing experience and functionality may be affected.
Accessing or correcting your personal information
You can contact us and ask to view the personal information we hold about you, ask us to update or correct any information that is inaccurate or needs updating or opt out of receiving direct marketing communications from us. There is no fee to ask for your information, but we sometimes may charge a fee to cover the time spent gathering the information you want. If there is a fee, we will inform you beforehand.
Contact us
If you have any questions about this privacy policy or our processing of your personal information, or if you wish to exercise any of your rights under the Privacy Act, our contact details are below. We are committed to working with you to obtain a fair resolution of any complaint or concerns about privacy, and endeavour to respond to all queries within 30 days of receipt.
Bellinger
Level 4, 255 Crown Street
Surry Hills, NSW, 2010, Australia
Attention: Privacy Officer
enquiries@bellingeram.com
Making a complaint
If you are not satisfied with the outcome of any internal investigation we conduct, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at enquiries@oaic.gov.au. More information is available on the OAIC’s website at https://www.oaic.gov.au/.