Privacy Policy

Last updated September 2026

How Kamoa Capital collects, uses, stores and protects the personal information you provide through the Investor Register.

1. Who we are

Kamoa Capital Pty Ltd (ABN 74 687 919 884) operates kamoacap.com and publishes The Drill Down. In this policy, “we”, “us” and “our” refer to Kamoa Capital Pty Ltd, trading as Kamoa Capital.

We are not the holder of an Australian Financial Services Licence.

2. What this policy covers

This policy applies to personal information collected through the Kamoa Capital Investor Register at kamoacap.com/investor-register/ and to our subsequent communications with people on that register.

It does not cover our newsletter subscriber list, which operates under separate consent and is managed on a separate platform.

We apply the standards set out in the Australian Privacy Principles to register data. Where the Privacy Act 1988 (Cth) does not bind us as a matter of law, we treat these standards as our operating commitment.

3. What we collect

When you complete the Investor Register form we collect:

• Full name
• Email address
• Mobile number
• Country of residence
• Investor type, as self-declared
• Whether you consider yourself eligible to participate in wholesale or accredited investor offers in your jurisdiction, as self-declared
• Typical investment amount, as a band
• Market interest, being the markets in which you wish to receive opportunities

We do not collect identity documents, certificates or proof of wealth through this form. Investor status is self-declared. If a future opportunity requires verification, we will request it separately and tell you why at that time.

Alongside your submission we automatically record your IP address, the date and time of submission, and standard browser information. Our website also collects usage data through analytics and security services, described in section 10.

4. Why we collect it

We collect this information to:

• Assess whether you may be eligible for future investment opportunities in your jurisdiction
• Send you information and marketing material about placements, initial public offerings, corporate opportunities, company updates and investor events in the markets you have selected
• Understand the composition of our register so we can shape what we distribute
• Maintain a record of your consent
• Meet our record keeping obligations

Registering does not create any obligation on us to present you with any opportunity, and does not create any obligation on you to participate in one.

5. How we use it

We use your details to contact you about opportunities and information relevant to the markets you have selected. You can update your details, or withdraw entirely, at any time using the contact details in section 14.

6. Who we disclose it to

We do not sell, rent, trade or disclose your information to third parties for their own purposes. We do not provide your details to issuers, brokers, corporate advisers or clients of Kamoa Capital. The register is for Kamoa Capital’s own use.

Where we distribute information about an opportunity, we do so ourselves. The company or party behind that opportunity does not receive your details from us.

To operate the register we use service providers who handle data on our behalf, under instruction, and who are not permitted to use it for their own purposes:

We may also disclose your information where we are required to do so by law, or where disclosure is necessary to protect our legal rights.

7. Where your information is stored, and overseas access

Register entries are stored in our website database, hosted by Kinsta in a Sydney data centre.

Some of our service providers are headquartered outside Australia and your information may be accessed, processed or stored overseas, including in the United States, in the course of providing those services. By submitting the form you consent to that disclosure. Where information is handled overseas, the protections available to you may differ from those under Australian law.

8. Security

We maintain access controls, encrypted connections and managed hosting security to protect register data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme.

9. How long we keep it

We retain register entries for five years from your last engagement with us, being your most recent form submission, reply to our correspondence, or update to your details.

At the end of that period we delete or de-identify your information unless we are required to retain it by law. You can request deletion at any time before then.

10. Cookies and analytics

Our website uses Google Analytics 4 to understand how visitors use the site, and Cloudflare for security and performance. These services set cookies and collect information including IP address, pages viewed, referring source and device type.

This information is used in aggregate to improve the site. You can block cookies through your browser settings, though parts of the site may not function correctly if you do.

11. Electronic messages

Our communications to you are commercial electronic messages under the Spam Act 2003 (Cth). We send them on the basis of the consent you provide when registering. Every message identifies Kamoa Capital as the sender and includes a functional unsubscribe facility. If you unsubscribe we will stop sending you commercial messages, and you can also ask us to remove your register entry entirely.

12. Accessing, correcting or deleting your information

You may ask us to:

• Provide a copy of the personal information we hold about you
• Correct information that is inaccurate, out of date or incomplete
• Delete your register entry

Contact us using the details in section 14. We will respond within 30 days. We may ask you to verify your identity before acting on a request. If we decline a request we will explain why in writing.

13. Registrants outside Australia

Canada

If you are in Canada, we handle your information in a manner consistent with the Personal Information Protection and Electronic Documents Act. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, and you may request access to and correction of your personal information.

European Union and United Kingdom

If you are in the EU or the UK, our lawful basis for processing your information is your consent, which you may withdraw at any time by contacting us. You have the right to request access to, correction of, deletion of, or restriction of processing of your personal information, to object to processing, and to request portability of the information you provided. Your information will be transferred to and stored in Australia. Australia is not the subject of an adequacy decision, and by registering you consent to that transfer. You may lodge a complaint with your local supervisory authority.

14. Contact and complaints

Privacy enquiries, access requests, correction requests and deletion requests:

Kamoa Capital Pty Ltd
81-83 Campbell Street
Surry Hills NSW 2010
Australia
Email: scott@kamoacap.com

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at oaic.gov.au, or to the relevant authority in your jurisdiction.

15. Changes

We may update this policy from time to time. The current version is always available at kamoacap.com/privacy-policy/, with the date of last update shown at the top. Material changes affecting how we use register data will be notified to registrants by email.

Kamoa Capital Pty Ltd, ABN 74 687 919 884. This policy applies to the Investor Register only.