1.1 The types of personal and sensitive information we will collect from you will depend on the circumstances in which it is collected. It may include:
(a) contact details for example your name, address, email, phone number, and date of birth;
(b) information required to open an account with us, receive services or products from us, or do business with us, such as billing address, bank account details, credit or debit card numbers, tax file number, other financial information, your activities and financial history with us;
(c) information that allows us to tailor the services and products for your needs;
(d) information required in a recruitment process;
(e) statistical information regarding the use of our websites or apps, including website users’ IP addresses and the dates and times of visits;
(f) audit records about when a record is changed, by whom and what the previous values were;
(g) payments made to us by cards linked to your account;
(h) sensitive information, only with your consent, for example where you register for an event, we may ask you for information about your health and dietary needs; and
(i) information (including sensitive information, with your consent) that may be relevant to legal or other professional advice you have asked us to provide to you.
1.2 We usually collect personal and sensitive Information when you:
(a) submit information to us or use our websites or apps, including as an investor, shareholder, officer, employee or service provider of a listed or unlisted entity (Related Parties). For instance, when you register a user account, retrieve log-in information, or request a new password;
(b) register for or attend one of our events, or subscribe to our online services, newsletters, mailing lists or our website or apps;
(c) request or receive services or products from us. This may include us accessing information held by third parties that we have relationships with or from related parties, or receiving information for regulatory and compliance purposes;
(d) contact us through the website, apps, by email, chat or phone, or request that we contact you;
(e) order services or products, using cards or accounts linked to your account with us or other communication means; or
(f) apply for a job opportunity with us.
1.4 If you do not provide us with the information we request, our ability to supply you with products or services, or to otherwise fulfil the purpose for which you have provided your information may be limited.
1.5 We will collect personal information directly from you, but may also collect it from third parties.
1.6 We may collect and disclose your personal information within our group of companies.
1.7 We also collect information about companies and entities that we engage with.
2.2 We may share your personal information with:
(a) the suppliers and service providers who help with our business support, development and operations including in relation to fraud prevention, identity verification, marketing, technology services, compliance, or during peak times of our services;
(b) your professional advisers;
(c) a potential purchaser/organisation involved in the proposed sale of all or part of our business for the purpose of due diligence, corporate re-organisation, investment, and transfer of all or part of the assets of our business. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them;
(d) a new owner of our business that will require the transfer of your personal information;
(e) law enforcement, regulatory authorities, government agencies or officials, or other third parties pursuant to a subpoena, court order, or other legal process or, law, regulation, rule, and our other regulatory, accounting, reporting or professional obligations and requirement applicable to us; when we need to do so to comply with law or credit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent breach of the laws, regulations and rules applicable to us and our services, to report suspected illegal activity or to investigate suspected violations of our agreements with you and enforce them.
2.3 Our main purposes for collecting, holding, using and disclosing personal information (and sensitive information, where relevant and permitted by the Privacy Laws) are the following:
(a) to carry out our business including suppling products or services to our customers, clients and, where relevant, Related Parties or another person, obtaining products and services from our suppliers and service providers, and carrying out processes associated with the services and products we provide, including fraud and identity verification checks, receipt of funds and account monitoring;
(b) to improve the products and services that we supply to you;
(c) to process and assess employment applications;
(d) to protect, exercise or defend our legal rights and to enforce agreements between you and us;
(e) to comply with legislative, regulatory, accounting, reporting or professional obligations, and our Policy requirements, including if the Australian Securities and Investments Commission requests to inspect your information under the Corporations Act 2001 (Cth) or in accordance with the reporting obligations to AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
(f) for the purposes of conducting analysis about the deployment and use of our products and services, our business, operations, events and the technology that supports our products and services, in Australia or elsewhere;
(g) to provide information to, and respond to queries, requests or complaints from our shareholders, suppliers, service providers, existing or prospective clients or customers, Related Parties and other persons.
2.4 We generally explain, at the time we collect personal or sensitive information, how we will use or disclose that information. We will only use or disclose this information for a purpose other than for which it was collected if you have consented to such different use or disclosure or such use or disclosure is otherwise allowed by the Privacy Laws.
3.1 We may disclose personal information outside Australia but only to the extent it is necessary to perform our business functions or activities. In the conduct of our business we may transfer and disclose personal information to contracted service providers and organisations with whom we partner to provide services and whose data warehouses may be located outside Australia including in the United States. The privacy laws of those countries may not provide the same level of protection as the laws of Australia, but we will comply with all applicable laws relating to the cross-border data disclosure and we will take reasonable steps to ensure that this organisation does not breach the Australian Privacy Principals 2 to 13 in the Privacy Act 1988 (Cth).
4.1 We may use your personal information to send you information about your account, our services, products, events, or other items or material that you may be interested in. We will only contact you if you have consented to receive such messages.
4.2 We may provide your personal information to third parties who offer services that you may be interested in. These third parties may contact you directly in relation to those services.
4.3 If you receive promotional information from us and do not wish to receive this information any longer, please contact us directly at firstname.lastname@example.org.
If you have an account with us, we will send you messages containing important information about your account. These messages are an important part of the services and products that we provide to you and will be sent to you as long as you hold an account with us. Customers, clients, and Related Parties with an account cannot opt-out of receiving these messages.
6.1 We may use digital technologies including technologies like cookies, location services, web server logs and web beacons in connection with our website and apps, social media pages and other digital portals. Some of these technologies may operate without collecting or using any personal information.
6.2 We sometimes use cookie technology on our websites to provide information and services to web site visitors. Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes and are a necessary part of facilitating online transactions. Most web browsers are set to accept cookies. Cookies are useful to estimate the number of visitors of our website and determine overall traffic patterns through our websites.
9.1 If you send us an application for a position, this information will be used to assess your application. This information may be disclosed for purposes such as:
(a) aptitude, psychological and medical testing;
(b) obtaining (with your prior consent) a police or criminal record check; and
(c) other human resources management activities.
9.2 As part of the application process, you may be asked for your specific consent to the use and disclosure of certain personal information about any pre-employment medical examination or any aptitude or psychological testing. We may also ask you to consent to the disclosure of your personal information to those people who you nominated to provide references.
9.3 A refusal to provide any of this information, or to consent to its proposed disclosure may affect the success of the application.
10.1 If, at any time, you want to access your personal information record with us, please contact us at email@example.com. Our file of your information will usually be made available to you within 21 days. We may charge you with a reasonable fee for giving you access to your personal information.
10.2 We will take steps to keep this information accurate, up to date, complete, relevant and not misleading, as we deem reasonable in our sole discretion. However, if, at any time, you wish to change your personal information because it is no longer inaccurate, it is incomplete, out of date, irrelevant or misleading, please either update your account information directly or contact us at firstname.lastname@example.org and we will amend this record.
10.3 If you wish to have your personal information deleted, please let us know in the same manner as referred to above and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.
10.4 We will endeavour to meet your request to correct or delete your personal information within 5 working days.
10.5 If you request access to your personal information or ask us to correct or update it, we may need to verify your identity. In some circumstances, there may be a valid reason for us to deny your request to access or correct your personal information. If we do this, we will tell you why and you may contact the Office of the Australian Information Commissioner.
10.6 If we refuse to correct or update your personal information, you may ask us to associate a statement to it that this information is inaccurate, out of date, incomplete, irrelevant or misleading and we will take reasonable steps to do so.
11.1 We may hold your personal information in either electronic or hard copy form. We take reasonable steps (in our sole discretion) to keep it secure from misuse, interference, loss, unauthorised use, modification or disclosure. For example, our website has electronic security systems in place, including firewalls and data encryption. Your information is stored on secure servers that are protected in controlled facilities. We restrict physical access to our offices, employ secure databases, password protect our IT systems, frequently update our anti-virus software and conduct regular audit and data integrity checks. We require our employees and contractors to respect the confidentiality of any personal information held by us.
11.2 However, we cannot guarantee the security of your personal information. The internet is not a secure environment. If you do use the internet or other electronic means to send us any information, including your email address, please be aware that it will be sent at your own risk.
11.3 If we become aware of unauthorised access to or disclosure of your personal information, we will take appropriate steps to rectify the data breach and will notify you in accordance with the requirements of the Privacy Laws.
When we no longer need to use your information, or we are no longer required to retain it by law, regulation, court or tribunal order, or policies, we will take steps to properly de-identify or destroy it.
13.1 If you have any concerns or complaints about how we handle your personal information, or if you have any questions about this Policy, or wish to receive this Policy in a different form, please contact us:
Automic Pty Limited
Alistair McKeough, Principal of Corporate Governance
Level 5, 126 Phillip Street, Sydney, NSW, 2000
Tel: +61 2 8072 1428
Please include your name, email address and/or telephone number and clearly describe the issue.
13.2 In most cases, we will ask that you put your request in writing to us. If you submit a complaint, our Principal of Corporate Governance will investigate it and will use reasonable endeavours to respond to you in writing within 30 days of receiving the written complaint. If we fail to respond to your complaint within 30 days of receiving it in writing or if you are dissatisfied with the response that you receive from us, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at email@example.com or on 1300 363 992. More information is available on the OAIC’s website at https://www.oaic.gov.au/.
14.2 We will conduct a Privacy Impact Assessment, at our sole discretion, for new projects in which personal information will be handled, or when a change is proposed to information handling practices.
14.3 If at any point we decide to use personal information in a manner materially different from that stated at the time it was collected, we will notify users by email or via a prominent notice on our website, and where necessary we will seek the prior consent of our users.