Please read all terms and conditions below carefully before you use this website. These terms and conditions apply each time you access or use this website. If you do not agree to all of these terms and conditions, you must immediately cease using this website and any information contained on this website. By accessing and using this website, you agree to be bound by this legal notice and all terms and conditions set out below. In particular, you acknowledge:
that you have read and accept this legal notice;
if you are located in Australia, that you are a Wholesale Investor (as defined below);
if you are located in the US, that you are a Sophisticated Investor (as defined below);
you agree to be bound by the terms and conditions contained in this disclaimer; and
that you will access and use the information without breaching any laws, rules, directives, regulations, or any other restrictions that apply in your local jurisdiction.
The content of this website (the “Information”) is issued by Brightlight Group Pty Ltd ABN 77 612 565 036, AFSL 493660 (“Brightlight”) unless expressly stated otherwise. Brightlight may change these terms and conditions at any time without notice to you. By continuing to access or use the website you accept any changed terms as they may apply from time to time. It is your responsibility to regularly check this disclaimer for any amendments.
In this disclaimer, references to “we”, “us” and “our” refer to Brightlight and references to “you” and “your” refer to each user of this website.
Brightlight Group Pty Ltd and various other affiliated entities are subsidiaries of Brightlight Impact Holdings Pty Ltd (collectively the “Brightlight Group”).
This website is directed only at persons to whom we can legally provide the Information in the jurisdictions in which they are located. In Australia this would include wholesale investors in accordance with section 761G of the Corporations Act 2001 (Cth) (“Wholesale Investor”). In the US only accredited investors and qualified purchasers may invest in the investment funds advised by Brightlight or its affiliates (“Brightlight Funds”). If you are not such a person, or are unsure, please take no further action in relation to this website without taking advice.
The Brightlight Group does not warrant that it holds any authorisations or approvals required in all jurisdictions where the Information may be accessed. The Brightlight Group does not and has no intention to offer or sell any funds, products or services in any jurisdiction where such an offer or sale would be unlawful under the relevant domestic law. You must satisfy yourself as to the laws which are in force in your jurisdiction and that access to the Information accords with the laws of your particular jurisdiction.
This material is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. Any products and services described in this website are only available to persons in jurisdictions in which the Brightlight Group are permitted to market and sell such products and services.
The Information is being issued to investors inside the US by Brightlight and is the only entity responsible for its contents in that jurisdiction.
Brightlight may work with registered investment advisers under the Investment Advisers Act of 1940, as amended, and regulated by the United States Securities and Exchange Commission (“SEC”) and broker-dealers who are members of the Financial Industry Regulatory Authority ("FINRA"). Brightlight’s investments have not been recommended by any US federal or state securities commission or regulatory authority. Furthermore, the foregoing authorities have not confirmed the accuracy or determined the adequacy of the Information. Any representation to the contrary is a criminal offense.
The Information is intended:
solely to provide general information about the Brightlight Group and its and the products and services available in the US where indicated
only for investors (each a “Sophisticated Investor”) that are both accredited investors within the meaning of the US Securities Act of 1933 (each an “Accredited Investor”); and qualified purchasers within the meaning of the US Investment Company Act of 1940 (each a “Qualified Purchaser”).
Brightlight does not intend to solicit or make its services available to the general public in the US and many of Brightlight’s products and services are not available in the US. Under no circumstances should the Information be considered as an offer to sell, a recommendation regarding or a solicitation of an offer to buy any securities or interests in products or services sponsored by Brightlight. Such offers or solicitations will be made in the US only to privately solicited investors that have been pre-qualified as an Accredited Investor or Qualified Purchaser (as applicable) and in accordance with relevant US securities laws. Accredited Investors and Qualified Purchasers are generally deemed sophisticated in financial matters such that they are capable of evaluating the merits and risks of prospective investments.
General information only
The Information provides general information only and does not take into account your individual objectives, financial situation, needs or circumstances. You should assume all information is written and prepared for large and experienced institutional investors with the highest degree of financial sophistication and knowledge and the capacity to withstand and assess any financial losses. Before making any investment decision, you should therefore assess whether the material is appropriate for you and obtain financial advice tailored to you having regard to your individual objectives, financial situation, needs and circumstances.
The Information is only intended to provide a general overview of the matters with which it deals. The Information is not intended to be comprehensive, nor does it purport to constitute legal, tax, financial product or investment advice. All Information available on this website should be assessed in consultation with your investment, financial, tax, accounting and legal advisors. To the extent that the Information on this website relates to a Brightlight Fund into which an investor may invest, the Information is qualified in its entirety by the reference to the applicable Offer Document (as described below) of the relevant Brightlight Fund and must be read in conjunction with that Offer Document in order to fully understand all of the implications and risks of investing in that Brightlight Fund. The achievement of any or all goals of any investment that may be described herein is not guaranteed. Risks of Brightlight Funds and Brightlight investment programs typically include but are not limited to:
assets of Brightlight Funds have limited liquidity;
no public market currently exists, and one may never exist for interests in Brightlight Funds;
distributions are uncertain;
a return on your investment is not guaranteed and you may lose all or a substantial amount of your investment;
substantial fees and expenses are typically paid to an offerings advisor, its affiliates and participating broker dealers;
unfavourable economic conditions in the markets in which Brightlight Funds operate could adversely affect your investment; and
assets acquired with leverage have risks including loss of value and limits on flexibility needed if there are changes in the business or industry.
For a more detailed list of applicable risk factors, please read the relevant Offer Document carefully and consult your own investment, financial, accounting, legal and tax advisors prior to undertaking an investment in interests in a Brightlight Fund. An investment in any of these investment programs should be made only after careful review of the risk factors described in the Offer Document.
Prospective investors should conduct their own investigation and analysis of an investment with the Brightlight Group (or any of its related bodies corporate) and the Information and make their own assessment of the appropriateness of the Information and any proposed investment having regard to their own objectives, financial situation and needs, independently and without reliance on the Brightlight Group or its directors, employees, agents and affiliates. In addition, prospective investors are strongly urged to consult their own legal counsel and financial, accounting, regulatory and tax advisers before making any investment decisions.
No offer or advice
The Information is general in nature and is provided for informational purposes only. It does not constitute legal, tax, financial product or investment advice and does not constitute a recommendation, solicitation, or offer of any securities, product or service and should not be relied upon as securities advice. The Information does not contain anything in it that forms the basis of any contract or commitment. No consideration has been given to the impact of any tax and revenue laws on investors. Investors should consult their own tax advisers in relation to any such consequences.
The Information is not a securities recommendation or an offer or solicitation with respect to the purchase or sale of any securities in any jurisdiction.
Additionally, the Information on this website does not constitute a representation that the solutions described herein are suitable or appropriate for any person.
All forward-looking statements should be evaluated with an understanding of their inherent uncertainty and are not a guarantee of future performance, and actual results, performance or achievements may vary materially from those expressed or implied. Forward looking statements in the Information involve known and unknown risks and uncertainties and other factors which may be beyond the control of the Brightlight Group. Investors are reminded that past performance is not a reliable indication of future returns and is not constant over time.
Any potential investor should consider the latest product disclosure statement, prospectus, information memorandum, confidential or private placement memorandum or other offer document (“Offer Documents”) before deciding whether to acquire, or continue to hold, an investment in any Brightlight Fund. Offer Documents can be obtained by contacting Brightlight at email@example.com.
To the extent permitted by law, this website, the Information and any services provided via this website are provided “as is" and without representations or warranties of any kind (either express or implied) including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. If any statute implies terms into this disclaimer which cannot be lawfully excluded, then those terms will apply and, to the extent permitted by law, the liability of the Brightlight Group for breach of any such term will be limited (at the option of the Brightlight Group) to resupply of the services or payment of the cost of resupply.
The Brightlight Group and its officers, employees and agents believe that the information in this material and the sources on which the information is based (which may be sourced from third parties) are correct as at the date of publication. While every care has been taken in the preparation of this material, no warranty of accuracy or reliability is given and no responsibility for this information is accepted by the Brightlight Group or its officers, employees or agents. Except where contrary to law, the Brightlight Group excludes all liability for this information.
The Brightlight Group assumes no responsibility for, and make no warranty that, functions contained at this site will be uninterrupted or error-free, that defects will be corrected, that the website is suitable for any particular purpose or has any performance, functionality or security features, or that the site or the server that makes it available will be free of viruses or other harmful components. While Brightlight will use reasonable endeavours to ensure that its site is free from viruses or other harmful components, you must take your own precautions to ensure that the way you access and use this website, or any linked website does not expose you to viruses or other harmful components that may damage your own computer or other IT infrastructure. The Brightlight Group is not responsible or liable for any damage caused by any virus or other harmful component, whether or not that virus or other harmful component resulted from you accessing this site or any linked website. You are responsible for the cost of all services, repairs and corrections that must be performed on your computer on account of your accessing this site or any linked website.
Limitation of liability
To the extent permitted by law, the Brightlight Group will not be liable for loss or damage of any kind whatsoever arising as a result of any opinion, advice, recommendation, representation or information expressly or impliedly contained on this website or any linked website notwithstanding any negligence, default, or lack of care by it or that such loss or damage was foreseeable.
Investments are subject to risk
Any investment is subject to investment risk, including delays on the payment of withdrawal proceeds and the loss of income or the principal invested. While any forecasts, estimates and opinions in this material are made on a reasonable basis, actual future results and operations may differ materially from the forecasts, estimates and opinions set out in this material. No guarantee as to the repayment of capital or the performance of any product or rate of return referred to in this material is made by Brightlight or its affiliates.
Links to material
This material may contain links to third party websites. The Brightlight Group does not control and is not responsible for the information contained within these websites. None of these links imply the Brightlight Group’s support, endorsement or recommendation of any other company, product or service, nor do they necessarily indicate any affiliation between us and such parties or businesses.
If you access any linked website through this website or because it is referred to in this website, you do so at your own risk.
No part of this material may be reproduced or distributed in any manner without the prior written permission of Brightlight.
This website is the Brightlight Group’s copyright property. You are provided with access to it only for your personal and non-commercial use.
Other than for the permitted purposes above, and for the purposes of and subject to the conditions prescribed under the Copyright Act 1968 (Commonwealth of Australia) and similar statutes that apply in your location, you may not, in any form or by any means:
adapt, reproduce, store, distribute, transmit, print, display, perform, publish or create derivative works from any part of this site, without Brightlight’s written permission; or
commercialise any Information, products or services obtained from any part of this site, without Brightlight’s written permission.
You may, however, download, where specifically permitted, one copy of the materials on any single computer for your personal, non-commercial use only.
All trade names, trademarks, service marks and other product and service names and logos (the "Marks") displayed on this site are proprietary to their respective owners and are protected by applicable trademark and copyright laws. These Marks, the name Brightlight and the stylised Brightlight logos are registered trademarks of the Brightlight Group in Australia and elsewhere. All other trademarks are those of their respective owners.
Nothing contained on this site should be construed as granting any licence or right of use of any other person's or entity's trade mark which is displayed on this site without their express permission.
These terms and conditions will be governed by and construed in accordance with the laws of New South Wales, Australia, and you submit to the non-exclusive jurisdiction of the courts of New South Wales, Australia and any courts competent to hear appeals from those courts.
Brightlight Group Pty Ltd ABN 77 612 565 036, AFSL 493660 (“Brightlight”, “we”, “us”, and “our”) is a subsidiary of Brightlight Impact Holdings Pty Ltd. Brightlight Impact Holdings Pty Ltd and its various subsidiaries and affiliates are referred to as the “Brightlight Group”.
The Brightlight Group is committed to ensuring the confidentiality and security of your personal information and acting in accordance with your rights under data protection law.
Information we collect
In the course of our activities, we collect and hold personal information about you. We will only collect personal information that is necessary to provide our products and services to you, including information needed to comply with legal and regulatory requirements.
We may collect the following types of personal information:
email address, mailing or street address and other contact details;
date of birth;
information to verify your identity such as your driver’s licence number;
tax file number;
bank account details to enable payment of distributions or redemptions; and
information about other products or services of ours or any related body corporate that you may hold or use.
We are required to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). We are authorised to collect tax file numbers under tax laws and the Privacy Act.
Method of collection of personal information
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:
from your completion of application forms for our products;
though your use of our website; and
during communications between you and our representatives; and
from our conduct of marketing activities.
We may also collect personal information from third parties including your financial or other professional advisor or authorised representative.
If we cannot collect your personal information
If we do not obtain all the information we need from you, some or all of the following may happen:
we may not be able to provide you with and subsequently administer some or all our products or services; or
we may not be able to provide you with information about our products and services.
How your personal information is used
We will only use your personal information for the purpose of providing you with our investment products and services. In managing your investment for you, we will use your personal information to:
assess your application and provide our products and services to you;
communicate with you in relation to your investment;
monitor, audit, evaluate and otherwise administer our products and services;
provide you with access to protected areas of our websites;
provide continuous service to you and to conduct business processing functions including by providing personal information to our related bodies corporate, contractors, service providers or other third parties;
to manage conflicts of interest; and
assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of the Brightlight Group and its contractors and service providers.
Who your personal information is shared with
To provide you with the services you require and for the purposes set out above, we may disclose your personal information to third party organisations. We take reasonable steps to ensure that third party organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
We may disclose your personal information to the following third parties:
service providers, such as your financial adviser;
other professional advisors such as accountants, lawyers, consultants and other business advisors as advised to us;
mail houses, archive providers, our related bodies corporate, contractors, or other third parties for the purposes specified above; and
other third parties where required, or allowed under law, or in connection with legal proceedings.
We will not sell your personal information to other organisations. We will not provide organisations outside the Brightlight Group with your personal information for purposes unrelated to the management of your investment or the scope of services for which you have, or are proposing to, engage us.
Security of your personal information
We invest considerable resources to keep your personal information secure from misuse, loss, interference, unauthorised access, modification or disclosure. Access to and the use of personal information is regulated to prevent misuse or unlawful disclosure of the information. We use security procedures such as encryption, firewalls, intrusion detection and anti-virus technology to prevent unauthorised access. We also use valid log-in identification and password-based security to achieve electronic information security. We retain information for as long as may be necessary to respond to issues that may arise at a later date, and longer where required by law. When personal information is no longer required by us, it is destroyed or de-identified.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
How you can access your personal information
You may contact us by mail or email using the details provided below and request access to your information. Before we give you access to information about you, we will ask you to verify your identity. In normal circumstances we will give you full access to your information, however, at times there may be a legal reason why we must deny access, such as where granting access would interfere with the privacy of others or it would result in a breach of confidentiality. If access is denied we will give you the reasons for any refusal in writing and the mechanisms available to complain about the refusal.
There may be some charge to you to access your information depending on the ease of its retrieval. We will advise you of any cost when you seek the information. We will not charge you for making a request or for making any corrections to your personal information.
Correction of your personal information
We will endeavour to ensure your personal information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change.
If you believe that the personal information we store about you is incorrect, incomplete, inaccurate or misleading, you may ask us to amend it. If we do not agree that there are grounds for amendment, we will give you the reasons for any refusal in writing and the mechanisms available to complain about the refusal, and we will add a note to the personal information stating that you disagree with the information.
We may use “cookies” to help us tailor our website to better suit your needs and to provide a more effective route to various components of our website. If you choose to disable cookies, some of our website’s functionality might be impaired. Cookies are small text files that are stored in your computer's memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website or other third parties which receive data obtained from that website. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalised web experience.
Analytical purposes: Analytical cookies allow us to recognise, measure and track visitors to the website. This helps us to improve and develop the way the website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of the site that are of the most interest to them.
Usage preferences: Some of the cookies on the website are activated when visitors to our sites make a choice about their usage of the site. Our website then ‘remembers' the settings preferences of the user concerned.
Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.
Advertising: Advertising cookies allow us (or third parties) to monitor the behaviour of users of our website. This information is used to ensure that products and services highlighted to those individuals are targeted in a focused and relevant manner, or to monitor the effectiveness of those digital marketing campaigns. We also monitor whether the adverts displayed on our website are of interest to users and retain this information to ensure that adverts seen by users of our website over a period of time are appropriate.
We may disclose details about the general use of our website to third parties. Information we pass on for this purpose will not include any personal data by which you may be identified.
You can configure your browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our website.
Process for complaining about a breach of privacy
If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.
We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.
After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
If you have any queries or concerns about the privacy of your information, please contact our Privacy Officer via the following:
Mail: Brightlight, Level 3, 31 Alfred Street, Sydney NSW 2000
Please address all written requests: ‘Attention: Privacy Officer’.
Changes to this policy
We will review this policy from time to time and may update it at our discretion. This policy was last updated in August 2019.