Privacy Policy

Last updated: July 2026

A.C.N. 690 928 995 Pty Ltd trading as All In Capital Partners (ABN 69 690 928 995), corporate authorised representative (CAR No. 001322188) of Wexted Financial Services Pty Ltd (AFSL 528444) ("All In Capital Partners", "AICP", "we", "us", "our").

This Privacy Policy explains how we collect, hold, use and disclose personal information, and how you can access and correct your information or make a complaint. We are committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"), and with our obligations under anti-money laundering and counter-terrorism financing laws.

We provide corporate advisory and capital raising services to wholesale clients only within the meaning of sections 761G and 761GA of the Corporations Act 2001 (Cth). We do not provide financial services to retail clients. Nothing in this Privacy Policy or on our website constitutes financial product advice or an offer of securities or other financial products.

1. Kinds of Personal Information We Collect

Depending on your dealings with us, we may collect and hold:

• Identity and contact information — name, job title, company, business and residential address, phone numbers, email address.
• Wholesale client and investor certification information — qualified accountant certificates and supporting information used to establish wholesale client status under sections 761G and 761GA of the Corporations Act (financial services) and sophisticated or professional investor status under section 708 of the Corporations Act (offers of securities) (which may include information about your net assets and gross income), professional investor confirmations, and related acknowledgments.
• Know Your Customer (KYC) and anti-money laundering (AML) information — government-issued identification documents (such as passport or driver licence), date of birth, beneficial ownership and control information, company and trust records, ASIC extracts, and the results of screening checks including adverse media, sanctions and politically exposed person checks.
• Financial and transactional information — information about your investment history, objectives at a general level, holdings, and transactions relevant to a mandate or capital raising in which you participate.
• Deal and business information — information you provide about your company, its directors, officers and shareholders in connection with an advisory or capital raising mandate.
• Communications and website data — records of your correspondence with us, and technical information collected when you use our website (see section 9).

We do not generally collect sensitive information (such as health information). Some screening results (for example, criminal record or adverse media checks conducted for AML/CTF purposes) may include sensitive information; we collect this only where permitted or required by law.

If you do not provide the information we request, we may be unable to provide services to you, verify your wholesale client status, or allow you to participate in a transaction.

2. How We Collect Personal Information

We collect personal information:

• directly from you — in meetings, calls, correspondence, onboarding forms, and documents you provide;
• from your advisers, employer or the company you represent, where you are a director, officer, shareholder or contact of a client or counterparty;
• from third-party sources used in verification and due diligence — including ASIC and other public registers, sanctions and adverse media screening databases, and our AML/KYC onboarding partner (see section 4);
• from our licensee, Wexted Financial Services Pty Ltd, and co-advisers on a transaction; and
• automatically through our website via cookies and analytics tools (see section 9).

Where reasonably practicable, we collect personal information about you directly from you.

3. Purposes of Collection, Holding, Use and Disclosure

We collect, hold, use and disclose personal information to:

• provide corporate advisory and capital raising services under our mandates;
• assess and verify wholesale client status under sections 761G and 761GA, and sophisticated or professional investor status under section 708, of the Corporations Act before providing services or deal information;
• conduct customer due diligence and comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), including identity verification, beneficial ownership checks and screening;
• introduce clients to investors, lenders and other counterparties, and manage transactions through to completion;
• comply with our obligations as a corporate authorised representative of Wexted Financial Services Pty Ltd, including compliance monitoring, conflicts management and record-keeping;
• comply with other legal and regulatory obligations, including under the Corporations Act and requests from regulators such as ASIC, AUSTRAC and the OAIC;
• manage our business relationships, respond to enquiries and maintain our records; and
• with your consent or where you would reasonably expect it, keep you informed about our services and, in the case of persons whose wholesale client or sophisticated/professional investor status has been verified, relevant transaction opportunities. We do not send information about specific securities or financial product opportunities to retail clients. You may opt out of marketing communications at any time by contacting us or using any unsubscribe facility provided (Australian Privacy Principle 7).

We will not use or disclose your personal information for purposes other than those described above unless you consent or the use or disclosure is otherwise permitted or required by law.

4. Disclosure of Personal Information

We may disclose personal information to:

• Wexted Financial Services Pty Ltd (AFSL 528444) — our Australian financial services licensee — for supervision, compliance, conflicts management, complaints handling and record-keeping purposes;
• Mercurium Analytics — our AML/KYC onboarding partner — for customer due diligence, including identity verification, beneficial ownership checks, ASIC extracts and adverse media screening;
• co-advisers and transaction parties — lawyers, accountants, other advisers, investors, lenders and counterparties involved in a transaction, to the extent necessary for that transaction and typically under confidentiality obligations;
• service providers — providers of IT, cloud hosting, document management, communications and professional services that support our business, under obligations to handle information appropriately;
• regulators and government bodies — where required or authorised by law, including ASIC, AUSTRAC and the OAIC; and
• our professional advisers and insurers, where reasonably necessary.

Overseas disclosure

We are an Australian business and hold personal information in Australia. Some of our service providers (for example, cloud hosting and email providers) may store or process data on infrastructure located outside Australia. Where we disclose personal information to overseas recipients, we take reasonable steps to ensure the recipient handles it consistently with the APPs, except where an exception under APP 8 applies.

5. Storage and Security

We hold personal information in electronic systems (including cloud-based document and email systems) and, to a limited extent, in hard copy at our office. We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure, including access controls, secure systems and confidentiality obligations on staff and service providers.

We retain personal information for as long as needed for the purposes described in this policy and as required by law — including record-keeping obligations under the Corporations Act and the AML/CTF Act (generally seven years). When personal information is no longer required, we take reasonable steps to destroy or de-identify it.

Notifiable data breaches

If a data breach occurs that is likely to result in serious harm to individuals, we will comply with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner ("OAIC") where required.

6. Access and Correction

You may request access to the personal information we hold about you, and ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, contact our Privacy Officer using the details in section 10.

We will respond within a reasonable period (generally within 30 days). We do not charge a fee for making a request; we may charge a reasonable fee for giving access to cover our costs. In limited circumstances permitted by the Privacy Act we may refuse access or correction — if we do, we will give you written reasons and information about how to complain.

7. Complaints

If you believe we have breached the APPs or mishandled your personal information, please contact our Privacy Officer (section 10) with details of your concern. We will acknowledge your complaint promptly, investigate it, and aim to respond with our decision within 30 days.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:

• Web: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

8. Anonymity and Pseudonymity

You may deal with us anonymously or under a pseudonym for general enquiries. However, we cannot provide financial services, verify wholesale client status, or meet our AML/CTF obligations without identifying you, so anonymity is not practicable for clients, investors or transaction counterparties.

9. Cookies, Analytics and Website Data

Our website may use cookies and similar technologies to make the site work and to understand how visitors use it. Information collected may include your IP address, browser type, device information, pages visited and time spent on the site.

You can configure your browser to refuse cookies or alert you when cookies are being used; parts of the website may not function fully without them. Analytics information is used in aggregate form to improve the website and is not used to identify you personally.

10. Contact — Privacy Officer

The Privacy Officer All In Capital Partners Level 17, 68 Pitt Street, Sydney NSW 2000 Email: enquiries@allincapitalpartners.com.au Phone: +61 2 9099 1769

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or the law. The current version will always be available free of charge on our website at allincapitalpartners.com.au, and we will provide a copy in another form on request where reasonable. We encourage you to review it periodically.