Privacy Policy

1.

Introduction

1.1

Investment Markets (Aust) Pty Ltd ABN 87 634 057 248 (referred to as IM, us, our or we) has implemented this Privacy Policy to provide users of our Website www.investmentmarkets.com.au (Website) and our other services with information about how we collect, hold and use Personal Information you provide to us. If you wish to make any inquiries regarding this Privacy Policy, you should contact our Privacy Officer in any of the ways specified in paragraph 10.

1.2

From time to time, IM may be related to other entities (Related Entities) and a reference in this Privacy Policy to us also refers to our Related Entities.

1.3

By using our Website, you consent to the collection and use of your Personal Information by IM as explained below. In addition to the Privacy Policy, our Terms and Conditions of Use shall apply to you and everyone else who uses this Website.

1.4

We may, from time to time, review and update this Privacy Policy, including taking into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our then most recent Privacy Policy as published on our Website.

2.

Expressions used in the Privacy Policy

2.1

Set out below is the meaning of some of the expressions and words used in this Privacy Policy:

APPs means the Australian Privacy Principles contained in the Privacy Act.

Content means any content, information, graphs, images, communications, advice, text or other material on the Website.

Listee means a person or entity who is looking to issue or sell Securities or other financial productsand advertises such investment opportunity on the Website for the purpose of being introduced to or connected to potential investors in those Securities or financial products.

Personal Information has the same meaning as in the Privacy Act.

Privacy Act means the Privacy Act 1988 (Cth).

Securities means securities and managed investment scheme interests relating to bodies, businesses or other entities and also includes those items included within the term Securities as defined in the Corporations Act 2001 (Cth).

Sensitive Information has the same meaning as in the Privacy Act.

User refers to a user (including you) of the Website (whether a Member or not).

2.2

In this Privacy Policy, the words include, includes and including are not words of limitation.

3.

Personal Information we collect and hold from information you provide

3.1

In the course of providing our services and functions, we collect Personal Information directly from you, or from a person acting on your behalf. This Personal Information may include:

(a)

registration data (such as your corporate name, personal name, business and postal address);

(b)

information request data and response data;

(c)

Australian Business Number and/or ACN;

(d)

contact details including email address and telephone numbers (landline and mobile);

(e)

your age group, gender, country, and postcode;

(f)

your physical address;

(g)

your password for Website access;

(h)

your typical investment amount;

(i)

your investor type (whether you are a wholesale investor or a retail investor);

(j)

your areas of investment interest;

(k)

your areas of interest by industry and your areas of news interests;

(l)

for industry participants, their profession/job title and employer / company details;

(m)

language preferences and settings;

(n)

identification information which would identify a mobile device (such as a MAC address), including but not limited to: device specific settings and characteristics, latitude and longitude details (location data), and data related to the types of apps stored on a mobile device;

(o)

limited information provided to us by any social network site, such as your username, site ID and email address;

(p)

investments made by you through your use of this Website, including by your direct enquiry to a Listee via this Website, or via any links to the Listee on this Website which were visited by you;

(q)

the kinds of alerts you would like to receive and method of delivery.

3.2

If you access any of our services through a social networking site or application including Facebook, Instagram, Twitter and LinkedIn, we will collect limited information provided to us by that social networking site, such as user name, site ID and email address.

3.3

If you do not provide some or all of the Personal Information we request, we may be unable to effectively provide our services to you.

3.4

We do not collect and hold Personal Information about you from third parties unless a third party has provided us with your information on your behalf or under the premise that the third party was you, or was authorised by you.

4.

Other information we collect and hold

4.1

We use third-party analytics tools to help us measure traffic and usage trends for the Website and other sites. These tools collect information sent by your device or our Website, including the web pages you visit, add-ons, and other information that assists us in improving the Website. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual user.

4.2

When browsing or searching our Website, our server automatically collects navigational data to help us improve our Website content and navigation. One way which navigational data is collected is by placing ‘cookies’ in your browser file on your hard drive. A ‘cookie’ is a small amount of information that is transferred to your browser by our web server. The web server that gives you the cookie is the only web server that can read the cookie again. The cookie therefore serves as a memory for you and can remember such details as your favourite search criteria so you do not have to enter the same information every time you come to our Website. Cookies do not capture or track any Personal Information and by themselves cannot identify you as an individual. If you wish, you may elect not to accept cookies on your browser. This may adversely affect your experience when visiting our Website.

4.3

Our Website may from time to time involve use of Google Analytics, which is a web analytics service provided by Google, Inc and which may use cookies to assist in the analysis of usage of our Website. Google’s cookies may generate information about your use of our Website including your IP address and may store that information. Google’s privacy policy can be found at this link: www.google.com/policies/privacy/.

4.4

Our Website may also from time to involve use of Google Analytics/AdWords and third-party remarketing cookies to serve advertisements to visitors to our Website.

4.5

Log file information is automatically reported by your browser each time you make a request to access (i.e. visit) a web page or app. It can also be provided when the content of the web page or app is downloaded to your browser or device. When you use our Website or other sites, our servers automatically record certain log file information, including your web request, IP address, browser type, referring / exit pages and URLs, numbers of clicks and how you interact with links, domain names, landing pages, pages viewed and other such information. We may also collect similar information from emails sent to our users which then help us track which emails are opened and which links are clicked by recipients. That information permits more accurate reporting and improvement of our services.

4.6

When you use a mobile device to access our service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by IM. A device identifier may deliver information to us or to a third party partner about how you browse and use our service and may help us or others provide reports or personalized content. Some features of our Website may not function properly if use or availability of device identifiers is impaired or disabled.

4.7

We at times may use session recording software to capture information regarding how visitors to our Website are interacting with our webpages. This allows us to evaluate and, if necessary or beneficial, modify our Website to improve its functions and make it easier to use. The information collected may include visitor and user activities on the Website and how they navigate around a webpage. We may deploy other web analytics and tracking services on the Website not specifically mentioned in this Privacy Policy.

4.8

We may collect and hold your Personal Information for other purposes or in other ways not listed above. If we do so, we will make it known to you at the time we collect your Personal Information.

4.9

We do not otherwise collect, use or disclose your Personal Information without your permission, unless the collection, use or disclosure is:

(a)

in accordance with this Privacy Policy or any agreement you enter into with us; or

(b)

required or authorised by law, including under the APPs and the Privacy Act.

4.10

We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, and we may (but we have no obligation to) monitor the use of the Website or to retain the content of any user session.

5.

Use and disclosure of your Personal Information

5.1

We will only use or disclose your Sensitive Information where you have actually or impliedly given us your consent to do so. For example, if you share with us via our Website your investment details or any other Sensitive Information in the process of using our services, we will treat that as your consent to use that information to provide or procure an answer to your query.

5.2

We may disclose your Personal Information to:

(a)

our parent company and other companies within the Group;

(b)

financial institutions;

(c)

relevant government departments;

(d)

external service providers and other compliance inspectors for audit purposes;

(e)

external parties for business acquisitions or in the event of the sale of the business;

(f)

social media service providers and other social networking providers authorised by you; and

(g)

any other external parties authorised by you from time to time.

5.3

We use the Personal Information we hold about you to do the following things:

(a)

administer this Website;

(b)

administer our relationship with you including responding to your queries;

(c)

confirm your identity in order to create your member account and ensure that you are eligible to use the services provided on the Website;

(d)

review any marketing or other information that you may make via the Website;

(e)

confirm that you are eligible to register an account through the Website including in accordance with relevant legislation;

(f)

provide services through the Website including allowing you to contact other members and account holders using the information on the Website and be contacted by them;

(g)

market services, which may be supplied by IM, of third-party suppliers that may be of interest to you;

(h)

provide you with agreed services, and to assist in meeting your requirements, needs, goals and objectives;

(i)

train our staff and provide quality assurance;

(j)

provide a better Website experience with Content and advertising more relevant to your interests;

(k)

provide you with information on selected products and services that we think may be of interest to you (unless you have asked us not to do so);

(l)

enable us to comply with all our legal and regulatory obligations;

(m)

share your Personal Information with our Related Entities, business partners and our selected third parties;

(n)

contact you to ensure customer satisfaction in respect of our role as a Website provider and assist you in getting the best value from our service;

(o)

(if you are an employee or other representative of a client to which we provide our services or a supplier or service provider to us) communicate with you about your or your employer's engagement with us and otherwise as specified in this Privacy Policy;

(p)

personalise the Website for you and provide you with a better Website experience, including by providing you with content and advertising more relevant to their interests;

(q)

enable your access to and use of the Website services;

(r)

send you marketing communications;

(s)

communicate with you concerning our services;

(t)

respond to feedback from you;

(u)

develop and/or test our systems and services; and

(v)

attend to our own internal administrative purposes.

5.4

We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, and we may (but we have no obligation to) monitor the use of the Website or to retain the content of any user session.

5.5

Where we disclose your Personal Information to our agents or sub-contractors for these purposes, the agent or subcontractor in question will be obligated to use that Personal Information in accordance with the terms of this Privacy Policy.

5.6

In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, we may disclose your Personal Information to the extent that we are required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend our legal rights.

5.7

We may use or disclose the Personal Information we collect from you for direct marketing. You may request at any time not to receive direct marketing material when you use our services. Simply contact us via our contact details below and we will make sure you no longer receive direct marketing communications from us.

5.8

We may use or disclose the Personal Information we collect from you to improve your IM experience. This may include use or disclosure of your Personal Information to personalise, develop and improve the services we provide you, verify your identification and improve your account security.

5.9

In the event that we intend to enter into a major corporate transaction, such as a sale of control of our or another business, we may disclose certain parts of your Personal Information to potential buyers, underwriters or advisors. If we do this, we will take reasonable precautions to ensure that the recipients of your Personal Information are obligated to keep it confidential.

5.10

We may, from time to time, expand, reduce or sell our business and this may involve the transfer of certain sections or the whole business to other parties. Your Personal Information will, where it is relevant to any such transaction, be transferred to the new owner or newly controlling party who will, under the terms of this Privacy Policy, be permitted to use your Personal Information for the purposes for which it was supplied by you.

5.11

By providing us with your Personal Information, you consent to us using your Personal Information in the above ways.

5.12

If you do not consent to us using your Personal Information in the above ways you must not provide your Personal Information to us. You should also not provide your Personal Information to us if you are under 18 years of age. If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, we may not be able to provide you with requested products or services and access to some of the functionality of the Website.

5.13

We may use your Personal Information for other purposes not listed above. If we do so, we will make it known to you at the time we collect or use your Personal Information.

6.

Cross-border disclosure of Personal Information

6.1

We may disclose your Personal Information to overseas recipients for any of the reasons outlined above. Your personal information may in some circumstances be communicated to third parties in New Zealand, Hong Kong, Singapore, USA or the UK, but only upon express terms that they must comply with privacy obligations no less stringent than those contained in the Privacy Act 1988 (Cth).

6.2

While we cannot guarantee overseas recipients will comply with Australian laws, we will use all reasonable endeavours to ensure that those overseas recipients do not breach the APPs.

7.

Storage of your Personal Information

7.1

All information will be stored either on our servers or using the services of third parties such as Amazon Web Services (AWS). Please visit the AWS site at https://aws.amazon.com/privacy/ to learn more about how they collect and use this information.

7.2

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we will take all reasonable steps to protect your Personal Information, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit via the internet.

7.3

We have implemented steps to protect the Personal Information we hold from misuse, loss, unauthorised access, modification or disclosure by using a variety of secure techniques to protect your information, including secure servers, firewalls, password protected access rights to computerised records, database encryption and SSL.

8.

Currency, access and correction of Personal Information

8.1

You have certain rights to obtain access to your Personal Information which IM holds about you and to advise IM of any perceived inaccuracy. We also seek to ensure that the Personal Information we hold is accurate, complete and up-to-date.

8.2

For Personal Information of yours, we request that you help us by keeping your information up-to-date in your account settings.

8.3

To make a request to access, to update or to request the correction of any Personal Information we hold about you, please contact our Privacy Officer (contact details set out in paragraph 10).

8.4

If we find that we have no further need for your Personal Information we may (but are not obliged to) remove it from our systems and destroy all record of it.

9.

Complaints

9.1

Any complaints regarding an alleged breach of your privacy rights may be made directly to us in writing to our Privacy Officer (contact details set out in paragraph 10).

9.2

After receiving a complaint, we will follow the following procedure:

(a)

Our Privacy Officer will investigate the complaint and report to our Chief Executive Officer;

(b)

A decision will be made and you will be advised in writing of our determination within 30 days of the complaint;

(c)

If you are not satisfied with our response or do not receive a response within 30 days of having made the complaint, you may make a complaint to the Office of the Australian Information Commissioner.

10.

Contacting us

If you have questions or would like to make a complaint about privacy, please contact us at:

Privacy Officer

Email:

info@investmentmarkets.com.au

Phone:

+61 (0) 7 3220 3428

Address:

Investment Markets (Aust) Pty Ltd
GPO Box 2227, Brisbane Qld 4000

11.

Changes to this Privacy Policy

11.1

We may, from time to time, update this Privacy Policy. We reserve the right to change our Privacy Policy at any time. You can find the date of the most recent review of this policy at the end of the document. When we make material changes to this Privacy Policy we will highlight these in a banner on the Website and notify you by email or by way of a popup when you next login to the Website.

11.2

Your continued use of the Website, requesting our services or the provision by you of further Personal Information to us after this Privacy Policy has been revised will be deemed to be your acceptance of and consent to the revised Privacy Policy.

This Privacy Policy was last revised on 1 October, 2021.

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