Privacy Policy

INTRODUCTION

Generation Development Group Limited ABN 90 087 334 370 (GDG) respects and upholds your rights to privacy protection under the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

This Privacy Policy (Policy) describes how GDG collects, holds, uses, and discloses Personal Information provided to it as part of its business operations in accordance with the standards, rights and obligations of the Australian Privacy Principles in the Privacy Act 1988 (Cth).

This policy applies to all your dealings with us.

The terminology, “we”, “us” and “our” are references to GDG. For the privacy policies of the related bodies corporate of GDG, please refer to their websites.

For the avoidance of doubt, your Personal Information is the responsibility of the relevant body corporate within the GDG group that you provided the Personal Information to.

WHAT IS PERSONAL INFORMATION?

In this policy, “Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable – whether the information or opinion is true or not, and is recorded in a material form or not.

Information that is not about an individual on its own, can become Personal Information when it is combined with other information and the combination results in an individual becoming ‘reasonably identifiable’ as a result.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Generally, the Personal Information that we collect, and then may use and disclose, in relation to an investor or other customer including a party we potentially or actually may contract with (a Client) will depend on the nature of the actual or potential dealings between us and a Client.

We only collect Personal Information that is reasonably necessary to:

issue, transfer or redeem shares or units to or in relation to a Client or their representative;
consider the Client’s application for one or more of our products and services;
provide and/or discuss and consult with, a Client about our products and services;
inform a Client of changes to our products and services and in marketing, communicating to, accepting and facilitating a Client as part of our events, offers and opportunities;
let a Client know of information that may be relevant to them;
verify the Client’s identity, for customer due diligence purposes and carry out further enquiries to provide the Client with our products and services;
consider any concerns or complaints a Client may raise against us and/or manage any legal action involving us;
participate in activities or other dealings relevant to our products, services and our business. For example, this may be part of our assessment of a third party during our procurement and due diligence practices, or as part of assessing candidates applying for a position with us;
engage with our consultants such as auditors, legal and accounting firms, and agents, as appropriate to conduct our business;
enable compliance with our legal, regulatory and supervisory obligations, any court/tribunal orders;
conduct, manage and analyse our businesses, and amongst our related bodies corporate, where sharing of Personal Information between us is on a confidential basis; and/or
any other purpose related to the above or for which the Personal Information was provided to us.

All of the above are collectively referred to herein as “our Products and Services”.

As an example, if Generation Life interacts with the financial adviser of a Client about their submitted application for an investment bond, Generation Life will, amongst other things, have collected details of the Client’s name and signature, the registered postal and email addresses of the Client and their financial adviser and the Client’s bank account details.

Generally, we do not collect sensitive information; being information or an opinion that is or implies Personal Information such as race, religion or political preferences, unless in the (unlikely) other case, we expressly inform the Client and obtain their consent, or law permits us to collect Personal Information in the situation without the Client’s consent (rarely) (Sensitive Information).

For the avoidance of doubt, even though certain surnames may imply an ethnic origin, a surname alone will not constitute Sensitive Information.

OPENNESS AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION

We only collect Personal Information in a lawful and fair way.

In general, we will only collect Personal Information directly from the Client, usually from our initial dealings with them in relation to our Products and Services (as set out above), or otherwise when the Client expressly provides us with their Personal Information or expressly engages with us, or we need to update our records in relation to the Client.

In certain circumstances, we may collect Personal Information (maybe from third parties) when you access our websites, tools and social media pages, and when you mention us on the internet.

Circumstances in which we may collect Personal Information from third parties include:

to verify their identity and for customer due diligence purposes – such as, a third party provider that conducts money laundering checks explained above;
to comply with our legal, regulatory or supervisory obligations; and
when we interact with their representative acting on their behalf.

We may collect Personal Information being images and recordings of individuals via security video surveillance when they enter the building(s) in which our offices are located. We may also collect such Personal Information before entry into our secure working offices and upon entry into meetings that may be recorded.

We may communicate with a Client and collect their Personal information via phone calls, emails, SMSs or other communication platforms.

Third parties’ links

We may provide links to other websites and tools that may use “cookies”. Cookies are small files a website transfers to the user’s computer hard drive usually for record keeping, to make the website easier to use by storing information about preferences and to store basic statistical data, that will help understanding how the website or tool is being used. Please refer to the policies of the relevant other websites and tools for more information about their use of cookies.

Third party websites used in or accessible via our websites may collect the user’s Personal Information. For example, part(s) of Generation Life’s website may be protected by reCAPTCHA and the Google Privacy Policy -https://policies.google.com/privacy and Terms of Service – https://policies.google.com/terms apply.

Our social media pages have their own privacy policies, terms and conditions and other policies/community guidelines that a Client or other user can view and agree to upon access and use of the social media pages.

We are not responsible for any such third party’s policies and their collection, use and disclosure of Personal Information.

We recommend each user make their own enquiries in relation to third parties’ privacy policies as they are not covered by this Policy.

What do we do with Personal Information?

Depending on the Products and Services we provide to the Client, we may disclose their Personal Information to:

any related bodies corporate of GDG;
any agent, contractor or service provider we consult, engage to assist with or carry out our functions and activities (such as registry service providers, information technology providers, suppliers of printing and mail-house services, other ordinary administration providers, auditors, legal and accounting firms and insurance companies);
parties to whom we are authorised or required by law or court/tribunal order to disclose information to, including supervisory and regulatory authorities such as, ASX, ASIC, APRA and AUSTRAC; and
the Client’s authorised agents; their executor, administrator or trustee in bankruptcy; their legal representative; their attorney; their financial adviser or anyone acting for them in connection with their dealings with us.

We take reasonable steps to ensure that where we disclose Personal Information to a third party recipient that we consider to be ‘carrying on business’ in Australia, that recipient is compliant with Australian privacy law including by engaging third parties on terms and conditions such as, that the recipient:

must comply with Australian privacy law;
is to let us know about privacy breaches;
is expected to satisfy minimum security standards; and
must comply with our requirements about retention and destruction or return of Personal Information.

We will not sell, exchange or trade to third parties any Personal Information obtained from a Client. In any (unlikely) other case, we will expressly inform the Client and endeavour to obtain their consent to the disclosure.

We only use Personal Information as is reasonably necessary to provide our Products and Services – as described in this Policy above.

As an example, we may de-identify Personal Information so it’s no longer Personal Information. To de-identify we remove direct identifiers and then change other information that may potentially be used to re-identify the Client and/or change use access controls to prevent re-identification. For example: we may break down and aggregate Personal Information into statistical data with no link to the Clients that the Personal Information related to.

As is reasonably necessary to enhance and/or deliver our Products and Services, we may use Artificial Intelligence (AI) tools, including generative AI (which are tools capable of learning to generate content), for the purpose of record reviews and analysis, for example, to alert us in aid of safe handling of information.

We use AI by lawful and fair means in compliance with Australian privacy law, with controls relating to the use of AI tools and for Staff to proactively identify and mitigate privacy risks when using AI tools, including to take reasonable steps to factcheck AI results to confirm their accuracies.

By a Client interacting with us, they consent to our use of AI as described above. For information about requesting us to opt out of AI use as it relates to you, please contact our Privacy Officer as outlined in this Policy.

ANONYMITY AND PSEUDONMITY

Except in certain circumstances, we may provide a Client with the opportunity to interact with us anonymously or by pseudonym, however this may restrict the Products and Services we are able to provide to you.

We will not provide a Client with the option of dealing with us anonymously or by pseudonym where our legal or regulatory obligations require us to deal with identified Clients or where it is impracticable for us to deal with Clients who have not identified themselves.

DIRECT MARKETING

We may collect, use and disclose Personal Information for direct marketing as explained by our Products and Services listed above.

Upon a Client’s request, we will notify them of our source of their Personal Information that we used or disclosed as part of direct marketing unless it is unreasonable or impracticable to do so.

A Client may also choose to opt out of receiving certain commercial electronic messages that have a direct marketing purpose. Each Client acknowledges that we may nonetheless may be required to communicate information to them that we have determined to be reasonably necessary to provide them with our Products and Services.

DEALING WITH UNSOLICITED PERSONAL INFORMATION

Unsolicited Personal Information is usually Personal Information that we receive without taking active steps to collect it. For example, misdirected mail or a promotional flyer with an individual’s Personal Information on it, sent to us by that individual to promote their business.

If we receive unsolicited Personal Information, we generally will promptly destroy (if permitted by law) or return it to you. However, we may also consider whether we could have nonetheless collected that Personal Information, to retain the Personal Information.

NOTIFICATION OF THE COLLECTION OF PERSONAL INFORMATION

Where we collect information about a Client other than set out in this Policy, we will let you know and also, provide them with other information determined relevant to satisfy our legal obligations.

ADOPTION, USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS

We will not adopt, use or disclose a Client’s government related identifier unless a legal exception applies such as, where it is reasonably necessary to verify identity or fulfil obligations to an agency or a State or Territory authority.

CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION

In general, we do not disclose Personal Information to overseas recipients.

But, in the event we will disclose Personal Information to overseas recipients – for example, third party service providers, we will take reasonable steps to ensure that where we consider the recipient to be ‘carrying on business’ in Australia, it is complying with Australian privacy law.

In any (unlikely) other case, we nonetheless take reasonable steps to ensure the recipient is risk assessed, subject to and complies with similar laws and is not in breach of the Australian privacy principles.

SECURITY OF PERSONAL INFORMATION

We take reasonable precautions and implement controls to protect Personal Information from unauthorised access or use, misuse, changes or disclosures, interference and loss.

Our Staff and those we engage are expected to consider our processes as relevant to:

matters and policies relevant to protecting Personal Information, including whether they should collect the Personal Information at all;
access and security policies and our incident and breach program; and
comply with confidentiality undertakings to keep Personal Information private and to handle confidential Personal Information appropriately.

A Client must notify us if they provide us Sensitive Information or other information that must be handled in accordance with specific requirements.

Each Client is responsible for maintaining the confidentiality of their account and client numbers, their passwords and login details and for all activities (if any) carried out under their password and login.

Clients are to be aware that electronic communications of messages and their attachments may not be successfully or promptly delivered, confidential, secure or free of virus or defects. By communicating with us online, transmission and recipient is at the Client’s own risk.

Where Personal Information is related to a legal matter, it is generally retained for seven years and then destroyed. Personal Information that is part of a Commonwealth record is also to be retained and not de-identified.

Generally, Personal Information is destroyed or de-identified at the end of it’s lifecycle by taking reasonable steps to make that happen. Such as, shredding, sanitizing hardware, clearing and purging processes.

QUALITY OF PERSONAL INFORMATION

A Client must provide us with information that is complete, and obtained by them and provided to us lawfully.

We will take reasonable steps to correct Personal Information to ensure that it is accurate, up-to-date, complete, relevant and not misleading.

If a Client believes that their Personal Information we hold is incorrect or incomplete, then they may request us to amend it, at no charge to them.

If we do not agree that there are grounds for amendment, then we will, at the Client’s request, add a note to the Personal Information stating that they disagree with it.

Requests for correction to Personal Information should be made in writing to our Privacy Officer at the address below

CLIENT’S ACCESS TO PERSONAL INFORMATION

A Client may request access to their Personal Information, and we will endeavour to provide them with a suitable range of choices as to how they can access it (e.g. by email or post) unless a statutory exception applies.

This includes requesting a copy of their Personal Information and we usually will provide a copy, free of charge or not – as permitted by law.

We will take reasonable steps to correct a Client’s Personal Information to ensure that it is accurate, up-to-date, complete, relevant and not misleading. If a Client believes that Personal Information we hold about them is incorrect, then they may request us to correct it. If we do not agree that there are grounds for correction, then we will, at at the Client’s request, add a note to the Personal Information stating that the Client disagrees with it.

Requests for access and correction to your personal information should be made in writing to our Privacy Officer at the address below.

QUESTIONS, FEEDBACK AND COMPLAINTS

This has been a summary of the material terms of our (lengthier) Privacy Policy that can be requested in in writing to:

Privacy Officer

Generation Development Group Limited

GPO Box 263

Collins Street West

Melbourne Victoria 8007

Email: privacy@genlife.com.au

Our Privacy Officer also addresses any other questions or feedback about our Privacy Policy or complaints in relation to the way in which we handle your Personal Information.

If we receive a complaint from you, we will acknowledge receipt of it and aim to resolve it within 30 days. We will write to you to explain our decision and any further avenues of recourse.

If we have not resolved your complaint within a reasonable time or you are not satisfied with our determination of such complaints, you may refer the complaint about the financial services of GDG and/or GDS to the Australian Financial Complaints Authority (AFCA), an independent body established to resolve complaints in the financial services industry. Contact details for AFCA are:

Australian Financial Complaints Authority

GPO Box 3, Melbourne, Victoria 3001

www.afca.org.au

Telephone 1800 931 678

CHANGES TO THIS POLICY

This Policy may change from time to time. We encourage you to check our website regularly for any updates. Any information that we collect after an amended version of this Policy has been posted on our website will be subject to the Policy as amended.

This policy was last updated on 19 October 2025.

JURISDICTION

This website and its contents are governed by and construed in accordance with the laws of the Commonwealth of Australia. Any disputes concerning this website are to be resolved by the courts having jurisdiction in in the Commonwealth of Australia.

If this disclaimer is invalid or unenforceable, in its entirety or in part(s), the offensive terms are severed and the remaining terms and conditions of the disclaimer continue in force.

If you have any queries about these terms and conditions, please contact us here https://gendevelopmentgroup.com.au/contact/.