This Privacy Policy explains how Equitise Pty Limited (we, us, our) uses, collects, stores, and discloses personal information. It also explains how an individual may seek to access or correct their personal information or make a privacy complaint. It should be read in conjunction with the Terms of Use that apply to the use of our website (Website). By accessing and using this Website, and/or using our services, you consent to the use, collection, disclosure and storage of your personal information in accordance with this Privacy Policy. If you choose not to provide the personal information when we ask for it, you may not be able to fully utilise the Website or our services.

1. Individuals in Europe

If you are in the European Union (EU) (including the European Economic Area (EEA)), the collection and processing of your personal information will be subject to the General Data Protection Regulation (2016/679) (GDPR) from 25 May 2018. In providing our services to you, we may collect and process personal information as outlined below. Otherwise, including for individual users of our services, we will be a data controller for the purposes of the GDPR and this policy includes information that must be provided to you when we collect your personal information.

2. What personal information do we collect?

We may, in addition to other information, we collect the following personal information about you:

• Information you provide to us when you register to use the Website and our services and when you maintain your account;
• Your name, email address, residential address, contact telephone numbers, date of birth and password;
• Financial information, such as your bank account number;
• Specific documents to verify your identity and other personal details;
• Details of transactions you carry out through our Website; and
• Information obtained from third parties in accordance with this Privacy Policy (such as Facebook or Linkedin).

We have statutory responsibilities to collect and disclose certain information to comply with regulatory requirements and contractual obligations. For example, under the Anti-Money Laundering and Countering Financing Terrorism Act 2009 (New Zealand) and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (Australia) we are obliged to verify the identity of, and run anti-money laundering checks on, persons who use our Website and services. To comply with those responsibilities, we may use third parties to verify your personal information. If those services are not able to verify your identity to our satisfaction, we may request that you send us further identification information. While you hold an account with us, we may also need to run additional identity checks on you. By using this Website, you agree that we may run these identity checks on you, and that you will not be able to use the Website or our services unless we are able to complete those checks to our satisfaction.

3. Cookies

We may also collect technical information whenever you use our Website. This may include information about the way users arrive at, browse through and interact with our Website. We may collect this type of technical information through the use of cookies and other means. Cookies are small text files stored on your device, to help operate the Website and collect information about online activity. For example, we use cookies to store your preferences and settings, help with sign in, combat fraud and analyse site operations. Where we use cookies that identify EU individuals or monitor their behaviour in an ongoing manner or together with other identifiers or information, we will inform you and obtain op-in consent for the use of each of the cookies, and provide you with the option to withdraw your consent to any cookies you have agreed to at any point.

4. How do we use personal information?

We may use personal information for any of the following purposes:

• Verifying any information that you give to us, or information that we collect from third parties and any third party databases;
• Carrying out credit and identity checks;
• Assessing your suitability to register with us and use our services;
• Providing our services to you;
• Satisfying any obligation arising from any agreement between you and us;
• Complying with our legal and regulatory obligations or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;
• Storing, accessing and making information available through the Website;
• Contacting you with information about us, our services and new investment opportunities that we think may be of interest to you;
• Monitoring, operating, maintaining and improving the Website; and
• any other purpose permitted under the Privacy Act 1993 (New Zealand) and the Privacy Act 1988 (Cth) (Australia) or that we notify you of at the time personal information is collected. By using this Website, you are agreeing to authorise any third party to provide your personal information to us for any of the above purposes.

If we disclose your personal information to a credit reporting agency, that agency may hold your information on their credit reporting database and use it for providing credit reporting services and for any other lawful purpose and the agency may disclose your information to their subscribers for the purpose of credit checking or debt collection or for any other lawful purpose.

5. When do we disclose personal information?

We may disclose personal information to service providers and others working with us to help us provide, improve and promote our Website and our services.

We may also disclose any of the personal information we hold:

• For the purposes for which the information was collected;
• With your express consent;
• For any purpose which is permitted under the Privacy Act 1993 (New Zealand) and the Privacy Act 1988 (Cth) (Australia);
• In relation to any proposed purchase or acquisition of our business or assets; or
• Where required by applicable law or any court, or in response to a request by a law enforcement agency.

We may share non-personal and aggregated information for research or promotional purposes. Except as set out in this Privacy Policy, we do not sell or trade personal information to third parties, or allow such third parties to use that personal information.

6. When do we disclose personal information?

We store your personal information in our electronic database and in print form. The information that we collect may be transferred to, and stored in New Zealand, Australia and overseas. If any information is stored overseas, it may also be processed by staff operating outside New Zealand or Australia who work for us or for one of our suppliers.

Any third parties to whom we disclose or permit access to your personal information in the course of providing services on our behalf will be subject to strict contractual restrictions to ensure that they protect personal information and keep it confidential, consistent with relevant privacy and data protection laws.

We will keep your personal information for as long as necessary to achieve the purposes for which we collected it, and in all cases for such periods as we are required to in order to comply with any relevant legislation and regulations. Where we no longer need to keep your personal information, we will take reasonable steps to destroy or de-identify your personal information.

We will take steps to ensure that your personal information will be afforded the level of protection required of us under and in accordance with this Privacy Policy and applicable data protection laws, and in accordance with current legally recognised data transfer mechanisms, such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient - https://www.privacyshield.gov/welcome) or appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm)

7. Access and complaints if you are in the EU

You also have in certain circumstances the right to request that the personal information that is collected from you is erased, its further processing is restricted, or to object to its further processing and the right to data portability. You can also ask that personal information provided by you to us is transmitted to another party. You may also withdraw your consent where it has been provided as a condition of our processing your information or object to the further processing of your personal information in certain circumstances.

If we refuse any request you make in relation to these rights, we will write to you to explain why and how you can make a complaint about our decision.

To make a request in respect of these rights or to make a complaint contact the Equitise Managing Director, the details of which are set out below.

You also have the right to lodge a complaint with a relevant data protection supervisory authority (for example in the place you reside or where you believe we breached your rights).

8. Data controller

For the purposes of the GDPR, Equitise with the address outlined below is a data controller for our website and the services provided through our website.

9. Your rights

If you have registered with us, you may access some of the personal information that we hold about you in the My Profile dropdown menu of the Website and this is editable in the Settings page. You have the right to request access to, correct or make a complaint about any of the personal information we hold about you. You also have the right to request confirmation of what personal information we hold about you. If you would like to exercise any of these rights, please contact us at:

Chris Gilbert (Managing Director)
(02) 9119 0585
[email protected]
Level 4, 17 - 19 Bridge Street
Sydney, NSW 2000

10. Amendments

We may add to, remove or change the provisions of this Privacy Policy from time to time. All additions and changes will be notified to you by being posted on this page. It is your responsibility to refer to these additions and changes. This privacy policy was last updated in June 2018.