1. General
a. The
following Privacy Policy applies to the products and services provided by Fresh
Equities Pty. Ltd. ACN 619 657 028 trading as InvestorHub .
b. In this
policy,
i.
the words we , our ,
us , InvestorHub and Site refers any InvestorHub website, software or web based application and
Fresh Equities Pty. Ltd. ACN 619 657 028 and all of their related entities.
This Privacy Policy applies to and should be read in conjunction with the
Microsite Terms of Use & Service (collectively, the Agreement )
available at https://www.investorhub.com/microsite-terms-and-conditions
ii.
the words you and your mean both you and any
entity or firm you re authorised to represent;
iii.
the word customer means a third
party customer of InvestorHub.
c. We may, at
our sole discretion, amend, add or remove any part of
this Privacy Policy with reasonable notice to you.
2. Collection
of Personal Information
a. We provide
public facing websites and online communications platforms on behalf of our Customers for you to use.
b. We
recognise the importance of protecting the privacy of personal information. We
employ strict policies and security measures to protect the information you
provide us.
c. When you
register with us, use InvestorHub, or provide us with
your personal information, you give us consent to process and use such
submitted personal data in accordance with this Privacy Policy.
d. This
Privacy Policy applies to all protected personal information collected, maintained or used by us.
3. Services
a. We only
collect information on behalf of our customers or to improve our products.
b. We collect
information in the following ways:
i.
Information you give to us directly. This includes
1. Information
about you. This might include your name, email, holder identification number,
any representative participant identification number, contact information,
address, telephone number, images, photographs, social media profile links, and
profile information such as age, gender, location, physical features or any
other information you intentionally provide on the InvestorHub
platform;
2. Financial
information. This includes information required to facilitate the purchase of
securities offer by our Customer, including your
financial and investment decisions, your investor or member status, your
investment qualifications and any special regulatory or legal exemptions to
which you are entitled or subject;
3. Platforms
interactions. This includes structured and unstructured interactions you submit
to us, including any answers to questions or surveys that we send to you, any
public or private messages that you send to our Customers
or other users, any likes or other sentiment indicator actions you interact
with, or any other information which you submit to us on our platform.
ii.
Information we collect through your use of our
services. This includes:
1. information
collected by our server, from or about the computers, phones, or other devices
where you access our services, including the internet protocol (IP) address
used to connect your computer to the Internet, operating system, browser and
platform, the average time you spend on InvestorHub,
the pages of InvestorHub you have visited, your use
of InvestorHub, your language settings and time zone
and your device fingerprint;
2. cookies and
other similar identifiers, which we send to your computer s browser for session
identification purposes.
iii.
Information from our customers. We receive
information provided to us by our customers, including:
1. Information
about your interactions with our customers, including user identifiers, your
status as a member of our customer, the number of securities you hold with
respect to our customer, any information about your past, present or future
interest in our customer s securities, and other descriptions about you that
they provide to us;
2. Information
about you, including, your full name, your address, your email address, your
telephone number, your email, your holder identification number, any
representative participant identification number, and other contact
information.
iv.
Information from third parties at your request. If
you choose to authenticate with InvestorHub using a
social media account, we may receive your email address, your full name and
your social media profile picture, unique user identifiers, social media
profile links, and personal profile information such as age, gender, location, interests and physical features.
4. How We Use
Your Information
a. We may use,
or disclose to third parties, the information you give to us directly and the
information we receive from third parties in order to:
i.
deliver services on behalf our customers;
ii.
provide, maintain, protect and improve our services
for the benefit of our customers, to develop new services, and to protect our
services and our customers;
iii.
keep a record of your communications with us to
help solve any issues or disputes that might arise;
iv.
help verify accounts and activity, and to promote
safety and security on and off of our services, such as by investigating
suspicious activity or violations of our terms or policies;
v.
comply with the law, legal process, litigation,
and/or requests from public and governmental authorities within or outside your
country of residence. We may also disclose information about you if we
determine that for purposes of national security, law enforcement, or other
issues of public importance, disclosure is necessary or appropriate.
b. We may use
the information we collect through your use of our services to:
i.
measure the use of InvestorHub
and to administer and improve InvestorHub. We
interpret this statistical data in our continuing effort to improve InvestorHub and your user experience.
ii.
gather information on which web pages are visited
and how often, to make InvestorHub more user
friendly, and to give you a better experience when you return to InvestorHub.
c. We may
combine the information you give to us directly with the information we collect
through your use of our service, our customers or from third parties.
d. In
delivering our products or collecting and using your personal information, we
may be required to disclose some of your personal information to third party
organisations, including external service providers; our legal, accounting,
financial or other professional advisors; and regulatory or government
authorities as required by law.
5. Security
a. We use a number of security measures to protect the information you
provide to us.
b. We protect
your personal information by:
i.
restricting internal and external access to your
personal information; and
ii.
maintaining our technology systems to prevent
unauthorised computer access; andsecurely destroying
your personal information when your personal information is no longer needed.
c. We use
industry standard encryption technology to transmit all user information.
6. Accuracy
And Retention
a. You are
entitled to request access to and correction of all personal data you provide
us, or to remove your name from our records at any time by contacting us at
privacy@investorhub.com.
7. Cross
Border Data Flows
a. We may
disclose your information to third parties who are not in your country of
residence, in accordance with this Privacy Policy and if applicable, the InvestorHub Data Processing Addendum.