Cheviot Investment Management Pty Ltd | Last updated: May 2026
Cheviot Financial Services 1 Pty Ltd (ACN 693 885 639, AFSL 700248) and Cheviot Financial Services 2 Pty Ltd (ACN 693 885 684, AFSL 700255) provide private equity investment services to wholesale and sophisticated investors. Cheviot Investment Management Pty Ltd (ACN 693 886 047) is the corporate authorised representative of Cheviot Financial Services 1 Pty Ltd (ASIC AR No. 001320385). In this policy, “Cheviot”, “we”, “us” and “our” refer to those entities and their related entities.
We handle personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”), the Australian Privacy Principles (“APPs”) and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”), each as amended. This public-facing policy is read together with our internal Privacy and Confidentiality Policy, which forms part of our Compliance Policy Suite.
Members of the Cheviot group are reporting entities under the AML/CTF Act. The group is a reporting group, with Cheviot Financial Services 2 Pty Ltd designated as the lead entity responsible for AUSTRAC reporting on behalf of the group. Certain collections, uses and disclosures of personal information are required or authorised by law and are therefore permitted under the APPs (in particular APP 3.4 and APP 6.2(b)). The Privacy and Other Legislation Amendment Act 2024 has, among other things, increased disclosure obligations in relation to automated decision-making, and we have updated our practices accordingly.
Depending on your relationship with us we may collect: identity and contact details (including identification documents); investor qualification information; financial information, bank account details and tax file numbers; information collected for customer due diligence under the AML/CTF Act, including beneficial ownership, source of funds, source of wealth, politically-exposed-person status and sanctions screening results; professional background information gathered during due diligence; records of transactions and communications; and technical data from your use of our website. We do not ordinarily collect sensitive information, and we do not collect more than we need.
We collect personal information by lawful and fair means: directly from you, from our affiliates and service providers, from public and licensed sources, and automatically through cookies and analytics when you visit our website. Before collecting your personal information we will, where practicable, give you a collection notice.
We use personal information to assess your eligibility, process applications, conduct customer due diligence under the AML/CTF Act, manage your investments, comply with regulatory obligations (including AML/CTF, FATCA and CRS reporting), maintain records required by law, and communicate with you. Where we send you marketing, you can opt out at any time using the link in the email. Where we collect personal information for a purpose not described in this policy, we will tell you at the time and obtain your consent if required.
We use technology tools and automated systems to support our operations, including in research, due diligence, drafting and administrative tasks. Where these systems are used in connection with personal information, we apply safeguards including human oversight (no decision with legal, financial or regulatory implications is taken without human validation), anonymisation where practicable, accuracy review, security parity with other personal information, and documentation. If an automated system is used to make, or substantially to assist in making, a decision that significantly affects your rights or interests, we will tell you, and you may request human review.
We may disclose personal information to members of the Cheviot group (including the lead entity for AUSTRAC reporting), to service providers (fund administrators, custodians, registrars, auditors, advisers and IT providers), to business partners and transaction counterparties where necessary, to regulators and law-enforcement bodies (including ASIC, AUSTRAC, the ATO and the OAIC) as required or authorised by law, and to any other party with your consent. We do not sell or rent your personal information.
We may transfer personal information outside Australia to our IT and cloud providers, typically hosted in the United States, the United Kingdom, Singapore or the European Union. When we do, we take reasonable steps to ensure handling consistent with the APPs.
We protect personal information through access controls, multi-factor authentication where appropriate, encryption in transit and at rest, secure storage, staff training, and oversight by our Compliance Officer and Cyber Security Officer.
We comply with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act. Any breach or suspected breach involving personal information is assessed (generally within 30 days). Where a notifiable data breach is identified, we notify the Office of the Australian Information Commissioner (“OAIC”) and affected individuals as soon as practicable, ideally within 72 hours of becoming aware of the breach.
We retain personal information for as long as is necessary to fulfil the purposes for which it was collected and to comply with legal and regulatory requirements, in particular the seven-year retention requirements that apply to taxation, AML/CTF and transactional records. The full schedule is set out in our internal Records Retention Policy. When personal information is no longer required, we securely destroy or de-identify it.
You may request access to, or correction of, the personal information we hold about you; complain about how we have handled your information; and request human review of any technology-assisted decision that significantly affects you. We respond to access and correction requests within 30 days. We may need to verify your identity. In some circumstances we may refuse access, including where doing so would prejudice an investigation or disclosure under the AML/CTF Act; where we refuse, we will provide written reasons.
If you have concerns about how we have handled your personal information, please contact our Privacy Officer. We will acknowledge your complaint promptly and respond within 30 days. If you are not satisfied with our response, you may lodge a privacy complaint with the OAIC at www.oaic.gov.au. As we provide financial services only to wholesale and sophisticated investors, our authorisations do not require us to be a member of an external dispute resolution scheme for retail clients.
For privacy enquiries, access requests or complaints:
Privacy Officer
Cheviot Investment Management Pty Ltd
Email: enquiries@cheviot.com.au
Licensees
Cheviot Financial Services 1 Pty Ltd | AFSL 700248
Cheviot Financial Services 2 Pty Ltd | AFSL 700255
We may update this policy from time to time to reflect changes in law, our business practices or technology. Changes will be posted on this page with an updated effective date. For material changes, we will notify you directly.