MICROSITE PRIVACY POLICY

1. General

   1. The following Privacy Policy applies to the products and services provided by Fresh Equities Pty. Ltd. ACN 619 657 028 trading as “InvestorHub”.

   2. In this policy,

      • 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
      • the words “you” and “your” mean both you and any entity or firm you’re authorised to represent;
      • the word “customer” means a third party customer of InvestorHub.
   3. 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

   • We provide public facing websites and online communications platforms on behalf of our Customers for you to use.
   • 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.
   • 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.
   • This Privacy Policy applies to all protected personal information collected, maintained or used by us.

3. Services

   • We only collect information on behalf of our customers or to improve our products.

   • We collect information in the following ways:

     • Information you give to us directly. This includes

       • 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;
       • 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;
       • 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.

     • Information we collect through your use of our services. This includes:

       • 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;
       • cookies and other similar identifiers, which we send to your computer’s browser for session identification purposes.

     • Information from our customers. We receive information provided to us by our customers, including:

       • 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;
       • 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.

     • 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

   • 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:

     • deliver services on behalf our customers;
     • 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;
     • keep a record of your communications with us to help solve any issues or disputes that might arise;
     • 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;
     • 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.

   • We may use the information we collect through your use of our services to:

     • 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.
     • 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.

   • 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.

   • 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

   • We use a number of security measures to protect the information you provide to us.

   • We protect your personal information by:

     • restricting internal and external access to your personal information; and
     • maintaining our technology systems to prevent unauthorised computer access; andsecurely destroying your personal information when your personal information is no longer needed.
   • We use industry standard encryption technology to transmit all user information.

6. Accuracy And Retention

   • 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

   • 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.