Last Updated: March 2026

Purpose and Scope
Scale Investors Pty Ltd (ACN 662 038 968) (Scale, we, us, our) is a Corporate Authorised Representative (No. 001299272) of True Oak Investments Pty Ltd (ABN 81 002 558 956, AFSL 238184). We are committed to protecting the privacy and security of personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Policy applies to our interactions with clients, prospective investors, founders pitching for investment, founders who receive investment from Scale, and visitors to our online channels. By interacting with us, you acknowledge and agree to the terms of this Policy.

Types of Personal Information We Collect
We collect personal information that is reasonably necessary for our functions as a venture capital fund manager.

• For Investors/Prospective Investors: Name, contact details, date of birth, financial information, Tax File Number (TFN), and government identifiers (e.g., passport or driver's license) required for ‘Know Your Customer’ (KYC) and Anti-Money Laundering (AML) compliance.

• For Founders/Pitching and Portfolio Companies: Name, career history, employment qualifications, links to professional profiles (e.g., LinkedIn), and information provided in pitch decks or founder surveys.

• For Website Visitors: IP addresses, browser types, and anonymized web traffic information collected via cookies to analyze site usage.

Sensitive Information and Diversity Tracking
In line with our mission to drive diversity and inclusion in the venture capital ecosystem, we collect sensitive identity-based data from founders.

• What we collect: This may include gender identity, age, sexual orientation, ethnicity (e.g., person of colour), or disability status.

• Purpose: We collect this information to track funding allocations for under-represented groups and to compel industry-wide change.

• Our Commitment: This information will only be disclosed in anonymised, aggregated form.

• Voluntary Disclosure: Providing this information is strictly voluntary. You will not be penalized in any way for choosing not to disclose sensitive information.

• Express Consent: Apart from this specific founder initiative, we are unlikely to collect other sensitive information unless required by law or provided with your express consent for a specific purpose.

How We Collect Information
Where practical, we collect information directly from you via application forms, pitch deck submissions, emails, or in-person meetings. We may also receive information from third parties, such as identification verification services, professional recruiters, or your authorized advisers.

Use of Personal Information
We use your information for the following primary purposes:

• Investment Assessment: Evaluating startup companies for potential venture capital investment.

• Compliance: Meeting our legal and regulatory obligations, including AML/CTF, FATCA/CRS, and AFSL requirements.

• Relationship Management: Administering your investments and responding to inquiries.

• Communication: Sending updates about our funds, programs, or events (which you may opt-out of at any time).

Disclosure of Personal Information
We do not sell or rent your personal information. We may disclose your information to:

• Our AFSL Licensee: True Oak Investments Pty Ltd, for regulatory oversight.

• Service Providers: Fund administrators, legal and professional advisers, CRM platforms, and SaaS providers used in fund management operations.

• Regulatory Bodies: Including ASIC, the ATO, or law enforcement where required by law.

• Investors and Advisory/Expert Network: Where we are introducing you to other prospective investors and/or our network for commercial and due diligence purposes.

Data Security
We take robust steps to protect your information from misuse, interference, loss, or unauthorized access.

• Storage: Personal information is stored on secure electronic systems provided by cloud service providers.

• Controls: We use encryption, firewalls, and restricted access protocols.

• Retention: We only retain information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal record-keeping requirements.

Your Rights: Access and Correction
You have the right to request access to the personal information we hold about you and to request corrections if the data is inaccurate or out of date. Requests should be sent to info@scaleinvestors.com.au. We will respond within a reasonable timeframe, typically 30 days.

Complaints and Contact
If you have questions about our privacy practices or wish to make a complaint, please contact us:

• Email:info@scaleinvestors.com.au

• Post: Level 3, 45 Wangaratta Street, Richmond, VIC 3121

We aim to resolve complaints within 5 to 30 days. If you are dissatisfied with our response, you may refer the matter to the Australian Financial Complaints Authority (AFCA) or the Office of the Australian Information Commissioner (OAIC).

Changes to this Policy
We may update this Policy from time to time by posting the revised version on our website. The version current at the time of information collection will apply