Dated 09 July 2019
ABN: 29 612 870 649

This Privacy Policy explains how we collect, hold, use and disclose your personal information. Please read this Privacy Policy carefully. Please contact us if you have any questions.

If you do not wish to provide personal information to us, then you do not have to do so. However, if you do not provide personal information when requested, it may affect your use of this website ("Site") or any products and services offered on it.

1. Type of personal information collected

The type of personal information we collect is:
· 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 Twitter, Facebook or Linkedin).

2. Collection of personal information

We collect your personal information through this Site and directly from you (e.g. when you communicate with us).

We have statutory responsibilities to collect and disclose certain information. For example, under the Anti-Money Laundering and Countering Financing Terrorism Act 2009, 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. Please note that you will not be able to use the full functionality of our Website or our services unless we are able to complete those checks to our satisfaction.

3. Purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose the personal information we collect for the following purposes:

· to contact and communicate with you,
· to conduct identity checks on you (see section 2 above),
· to enable us to provide our products and services to you,
· to enable us to manage the provision of our products and services to you, such as ongoing monitoring and reporting obligations,
· for internal record-keeping and administration,
· where permitted by law, for marketing,
· as required or authorised by law or a court or tribunal order, and to protect our legal rights and to comply with our ongoing monitoring and reporting obligations, and
· for any other purpose communicated to you at or around the time we collect your personal information.

4. Disclosure of personal information

We may disclose personal information we collect for the following purposes:

· to third party service providers and business contacts, including to third parties who conduct identity checking services,
· to regulators, registries and other similar bodies as required for the maintenance, operation and administration of our financial services business,
· to our professional and legal advisers, and
· as required by law or authorised by law or a court or tribunal order.

We may disclose personal information to overseas third parties that we work with.

5. Access to and correction of personal information

Access: You may request details of personal information that we hold about you, in certain circumstances set out in the Privacy Act 1988 (Cth). An administrative fee may be payable for the provision of information, but not the making of your request. We may refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

Correction: If you believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us by email. We rely in part upon customers advising us when their personal information changes. We will respond to any request within a reasonable time. We will endeavor to promptly correct any information found to be inaccurate, incomplete or out of date.

6. Complaints about breach

If you believe that we have breached the Australian Privacy Principles and wish to make a complaint about that breach, please contact us on the email address below.

We will investigate complaints and use reasonable endeavours to respond to you in writing in a timely manner.  If we fail to respond to a complaint within a reasonable time or if you are dissatisfied with our response, you may take your complaint to the applicable regulator in your jurisdiction. If you are in Australia, the applicable regulator is the Office of the Australian Information Commissioner (OAIC). Details of how to contact the OAIC are located at

7. Unsubscribe

To unsubscribe from our e-mail database, or opt out of communications, please contact us at the details below.

8. Storage and Security

We may hold your personal information in hard copy or digital form.

We will take reasonable steps to protect personal information we hold about you from misuse, interference and loss and from unauthorised access, modification or disclosure.

9. How To Contact us

You can contact our Privacy Officer by emailing Please include your full name and contact details, and full details of your enquiry, request or complaint in all messages to us.

10. Updates To Our Privacy Policy

We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version on this Site. Please check this Site regularly for changes.