Privacy Policy

Luxivana Pty Ltd ACN 689 348 454 and its related bodies corporate ("Luxivana", "we", "us" or "our") are committed to protecting and respecting your privacy.

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

This Privacy Policy applies to:

• visitors to the Luxivana website;
• individuals who join our waiting list;
• subscribers to newsletters and updates;
• prospective investors;
• wholesale and sophisticated investors;
• representatives of institutional investors and business partners;
• users of Luxivana digital platforms; and
• individuals who interact with our products and services.

By accessing our website or providing information to us, you acknowledge that your personal information may be handled in accordance with this Privacy Policy.

Luxivana is a technology-enabled platform focused on facilitating access to private market and real-world asset opportunities through modern digital infrastructure and tokenisation technologies.

Luxivana may work with licensed financial service providers, responsible entities, trustees, custodians, fund administrators, registry providers, compliance providers and other regulated service providers in connection with products and services made available through the Luxivana platform.

The personal information we collect depends on the nature of your interaction with Luxivana.

General Information

We may collect:

• full name;
• email address;
• telephone number;
• residential or business address;
• occupation and employer details;
• company information;
• communication preferences;
• investor category information;
• records of communications with us; and
• information voluntarily provided through forms, enquiries or subscriptions.

Website and Technical Information

We may collect:

• IP address;
• browser type and version;
• operating system;
• device information;
• website activity;
• pages viewed;
• referral sources;
• session duration;
• cookies and analytics data; and
• interactions with website content.

Investor and Verification Information

Where you apply to invest or participate in investment opportunities, we may collect:

• date of birth;
• citizenship and residency details;
• tax residency information;
• government-issued identification documents;
• beneficial ownership information;
• source of funds information;
• bank account details;
• trust, company or SMSF information;
• investor classification information; and
• information required under applicable laws.

Sensitive Information

We will only collect sensitive information where:

• required by law;
• reasonably necessary for our activities;
• authorised by applicable legislation; or
• you have provided consent.

Luxivana may utilise distributed ledger technology, blockchain networks, tokenisation infrastructure, smart contracts, digital wallets and related technologies in connection with certain products and services.

In connection with these activities, Luxivana may collect, process and retain information relating to:

• digital wallet addresses;
• blockchain transaction records;
• token ownership records;
• smart contract interactions;
• investor eligibility controls;
• digital identity verification processes;
• transaction audit records; and
• transfer and settlement records.

Blockchain transactions may be publicly visible on distributed ledger networks.

While wallet addresses may not directly identify an individual, Luxivana may be able to associate wallet addresses with specific investors where necessary to comply with legal, regulatory, operational or compliance obligations.

We may collect information directly from you when you:

• visit our website;
• register your interest in Luxivana;
• join our waiting list;
• subscribe to updates or newsletters;
• complete online forms;
• attend events, webinars or presentations;
• apply for investment opportunities;
• communicate with us;
• engage with our products and services; or
• interact with our digital infrastructure.

We may also collect information from third parties including:

• identity verification providers;
• AML/CTF service providers;
• professional advisers;
• public registers;
• corporate registries;
• trustees;
• fund administrators;
• referral partners;
• responsible entities;
• digital wallet providers;
• compliance providers; and
• publicly available sources.

We collect personal information to:

• provide products and services;
• assess investor eligibility;
• administer investment opportunities;
• facilitate onboarding processes;
• verify identity;
• conduct AML/CTF checks;
• communicate with users and investors;
• manage customer relationships;
• improve website functionality;
• improve products and services;
• administer digital asset infrastructure;
• facilitate tokenisation-related activities;
• manage risk;
• prevent fraud;
• comply with legal obligations; and
• conduct business administration activities.

Certain Luxivana products and services may only be available to wholesale, sophisticated or professional investors under Australian law.

To determine eligibility, Luxivana may collect and verify:

• accountant certificates;
• income information;
• asset information;
• company and trust details;
• trustee information;
• beneficial ownership information;
• SMSF information; and
• other information reasonably required to assess investor classification.

Luxivana may use personal information to provide:

• newsletters;
• market updates;
• educational content;
• platform announcements;
• industry insights;
• event invitations;
• product updates; and
• marketing communications.

You may opt out of marketing communications at any time by:

• clicking the unsubscribe link included in electronic communications; or
• contacting us at hello@luxivana.com.

We will process opt-out requests within a reasonable timeframe.

Luxivana uses cookies and similar technologies to improve website functionality, user experience and security.

Cookies may be used to:

• remember user preferences;
• monitor website traffic;
• analyse website performance;
• improve website security;
• personalise content; and
• support platform functionality.

You may disable cookies through your browser settings; however, certain features of the website may not function correctly.

We may disclose personal information to:

• trustees;
• responsible entities;
• fund administrators;
• registries;
• custodians;
• digital asset infrastructure providers;
• wallet providers;
• identity verification providers;
• AML/CTF service providers;
• legal advisers;
• accountants;
• auditors;
• insurers;
• technology providers;
• cloud hosting providers;
• consultants;
• regulators;
• courts and tribunals;
• law enforcement agencies; and
• parties otherwise authorised or required by law.

Luxivana does not sell personal information.

Luxivana may engage service providers located outside Australia.

Personal information may be processed or stored in jurisdictions including:

• Australia;
• Singapore;
• United States;
• United Kingdom;
• European Union member states; and
• other jurisdictions in which our service providers operate.

These providers may include:

• cloud hosting providers;
• compliance providers;
• digital infrastructure providers;
• wallet providers;
• administrators;
• analytics providers; and
• technology service providers.

Luxivana will take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with Australian privacy requirements.

Where applicable, Luxivana may facilitate the creation, provisioning or integration of digital wallets through approved third-party providers.

Information may be shared with those providers solely for purposes including:

• wallet creation;
• digital asset custody;
• transaction processing;
• token transfers;
• ownership verification;
• compliance monitoring; and
• regulatory compliance.

Certain products may include functionality designed to support investor transfer requests, holding period restrictions, investor eligibility controls and regulatory requirements.

Luxivana may collect and process information necessary to:

• validate investor eligibility;
• administer transfer restrictions;
• maintain ownership records;
• satisfy regulatory requirements;
• facilitate approved transfer mechanisms; and
• support future secondary market functionality where permitted.

Luxivana and its service providers may be subject to obligations under:

• the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• the Corporations Act 2001 (Cth);
• taxation legislation;
• FATCA requirements;
• Common Reporting Standard obligations; and
• other applicable laws.

To comply with these obligations, Luxivana may collect, verify, monitor and disclose information to authorised service providers, regulators and reporting entities.

Failure to provide requested information may prevent us from providing products or services.

Luxivana implements reasonable administrative, technical and organisational measures to protect personal information.

These measures may include:

• encryption;
• access controls;
• secure hosting environments;
• multi-factor authentication;
• cybersecurity monitoring;
• staff training;
• confidentiality obligations; and
• vendor security reviews.

While we take reasonable steps to protect information, no system can guarantee absolute security.

Personal information is retained only for as long as reasonably necessary to:

• provide services;
• comply with legal obligations;
• satisfy regulatory requirements;
• resolve disputes;
• maintain records; and
• enforce agreements.

Where information is no longer required, it will be securely destroyed or de-identified.

You may request access to personal information held by Luxivana.

You may also request correction of inaccurate, incomplete or outdated information.

Requests should be directed to:

Luxivana may refuse access or correction requests where permitted by law.

Where required, written reasons for refusal will be provided.

If you believe Luxivana has breached privacy laws or mishandled your personal information, please contact:

We aim to investigate and respond to complaints within 30 days.

If you are not satisfied with our response, you may contact:

Luxivana may amend this Privacy Policy from time to time.

Any updated version will be published on the Luxivana website and will become effective upon publication.

© Luxivana Pty Ltd. All rights reserved.