Privacy policy

INVESTIBLE PTY LTD Privacy and Spam Policy

Note that INVESTIBLE operates under a CAR (Corporate Authorised Representative) arrangement and in all instances the reporting should be to the ASIC Licensee (the Licensee) who will determine how any reporting will be submitted to ASIC or other regulatory agencies.

This privacy policy explains how INVESTIBLE Pty Ltd (ACN 54 603 802 795) and its related entities  (“INVESTIBLE”) meets its obligations to protect your personal information, including:

• Our commitment
• Why do we collect personal information
• What personal information do we collect
• How do we collect personal information
• How we store and secure your personal information
• When do we disclose your personal information to others
• How we ensure your personal information Is correct
• How you can access your personal information
• Using government identifiers
• Dealing with us anonymously
• Your sensitive information
• Complaints Resolutions
• Our Website

In short, we collect personal information from you if you interact with INVESTIBLE, whether you’re a founder, investor or supplier.

We only collect, use or disclose personal information where we think it’s necessary to run our business, or in circumstances that you would reasonably expect. For investors, we’ll collect more identification and financial information, so we can comply with the Australian Privacy principles and in particular our AML/CTF obligations .For founders, this includes information like your background and details of your business, so we can evaluate whether to invest in you.

Our commitment

INVESTIBLE is committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you.                          

The Privacy Act 1988 (Cwth) requires entities bound by the Australian Privacy Principles to have a privacy policy. The Privacy Act sets out the Australian Privacy Principles, which can be found at: https://www.oaic.gov.au/privacy/australian-privacy-principles/australian-privacy-principles-quick-reference/.

Our aim is to both support and ensure that we comply with these principles. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Federal Privacy Commissioner at http://www.privacy.gov.au.

INVESTIBLE believes that this Privacy Policy discloses the purpose, and how the personal information you provide to us and our representatives, is collected, used, held, disclosed and disseminated.

We encourage you to check our website regularly for any updates to our Privacy Policy.

Why do we collect personal information

The purposes for which we collect, hold and use your Personal Information include:

• provide you with information about INVESTIBLE’s products and services
• providing you with one of more of our financial products or services or products including to assess your application for a financial product or service and confirming your identity in compliance with AML/CTF Laws;
• managing and administering the INVESTIBLE funds and other investment products and services offered by INVESTIBLE;
• to provide you with information about our products, services, functions, events or activities;
• administer products and services which includes answering your requests and complaints, varying products and services, taking any required legal action in relation to our accounts and managing our relevant products portfolios
• to enable to subscribe to mailing lists or newsletters and interact or follow our social media pages, including but not limited to, Twitter, Facebook and LinkedIn

We will also use or disclose your personal information if you consent, if it is for something that you would reasonably expect us to use your personal information for, or if we are required or authorised to do so by law.

If you do not disclose information to us as and when requested, we may not be able to provide our services to you, or we may otherwise not be able to respond to your request or do business with you.

From time to time, we may provide you with direct marketing material. If, at any time, you do not wish to receive this information any further, you may contact us with this request. We will endeavour to meet your request within 2 weeks. We maintain a Register for those individuals not wanting direct marketing material.

What personal information do we collect

So that we can provide our products and services, we collect information that is reasonably necessary for us to carry out our business activities. Also as an organisation we are subject to certain legislative and regulatory requirements which necessitate us to obtain personal information about you.  For almost everyone we interact with this will include:

• your name, address (postal and residential), email address, telephone number, date of birth and gender;
• information from third party sources such as regulators, fund administrators, data providers and credit organisations, where permitted by law; and
• other contact details such as social media handles;

In addition to the above, we will collect additional personal information from you depending on your relationship with INVESTIBLE, which generally includes one or more of the following:

Investors

If you are or may become an investor in INVESTIBLE, or you represent a person who is or may become investor in INVESTIBLE, we (either directly or through a third party fund administrator) may collect and hold personal information including;

• financial information, including bank account details
• information about the funds in which the investor invests and the investment products and financial services supplied to the investor;
• data required for INVESTIBLE to comply with AML/CTF Laws, including any information required to verify your identity;
• your nationality and country of birth; and
• government identifiers, including your tax file number (TFN).

This type of information is generally collected and maintained by INVESTIBLE's external fund administrator.

Founders

If you are a founder seeking investment or an existing member of our portfolio, we may collect and hold personal information including:

• your employment history, professional and personal references, resume and qualifications; and
• details of your business or prospective business, including registration details, financial information and pitch decks.

How do we collect personal information

INVESTIBLE collects personal information directly from you or from third parties once authorisation has been provided by you. You have a right to refuse us authorisation to collect information from a third party.

Information may be collected in the following ways:

• through application or subscription forms for investment;
• by email or other written mechanisms;
• over a telephone call;
• in person;
• through transactions;
• through your use of our Website;
• by technology that is used to support communications between us;
• through publicly available information sources (which may include telephone directories, the internet and social media sites); and
• direct marketing database providers.

How we store and secure Your personal information

We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:

• confidentiality requirements of our employees;
• document storage security policies;
• security measures for access to our systems;
• only giving access to personal information to a person who is verified to be able to receive that information;
• control of access to our buildings; and
• electronic security systems, such as firewalls and data encryption on our websites.

We can store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information. We only hold your personal information for as long as is reasonably necessary for the purpose for which it was collected, or to comply with our regulatory obligations.

Even though we will take all reasonable steps to keep your personal information safe, data transmission over the internet is never guaranteed to be completely secure. We do not warrant the security of any information you transmit to us or from any online services.

When we disclose your personal information to others

We do not routinely disclose personal information to third parties unless:

• you have consented; or
• you would reasonably expect us to use or disclose your personal information in this way (for example, if the disclosure is incidental to services being provided to our business or for the resolution of any dispute that arises between you and us); or
• we are authorised or required to do so by law;
• for the purpose of reporting to the Licensee AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. or
• we may also share non-personal, de-identified and aggregated information for research or promotional purposes.

For clarity, we do not sell, trade or rent your personal information to third parties without your consent.

This may include disclosing personal information to our employees, contractors and related entities, as well as third parties who supply services to us to assist us in performing our administration functions and in fulfilling our legal and regulatory obligations (e.g. legal and accounting firms, data storage systems and certain SaaS providers). We will take reasonable steps to ensure that they handle your personal information in the same way that we do and in accordance with the Privacy Act and the APPs.

Our employees and the outsourcing companies/service providers/contractors who have entered into contracts with us, are obliged to respect the confidentiality of any personal information held by INVESTIBLE.

INVESTIBLE takes its obligations to protect your personal information seriously. This includes when we operate throughout Australia and overseas. As part of our operations, some uses and disclosures of your personal information may occur outside your State or Territory and/or outside of Australia. In some circumstances, we may need to obtain your consent before this occurs, and in such circumstances, we will seek your consent.

How we ensure Your personal information Is correct

INVESTIBLE takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. To ensure we can maintain this level of accuracy and completeness, we recommend that you:

• inform us of any errors in your personal information; and
• update us with any changes to your personal information as soon as possible.

If you provide inaccurate or incomplete information we may not be able to provide you with the products or services you are seeking.

How you can access your personal information

You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing (for security reasons) and we will provide you with access to that personal information. Access to the requested personal information may include:

• providing you with copies;
• providing you with the opportunity for inspection; or
• providing you with a summary.

If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.

Some exceptions exist where we will not provide you with access to your personal information if:

• providing access would have an unreasonable impact on the privacy of others;
• providing access would pose a serious threat to the life or health of a person;
• the request for access is frivolous or vexatious;
• the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
• providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
• providing access would be unlawful;
• denying access is required or authorised by or under law; or
• providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.

Using Government Identifiers

Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use this information other than for the purposes described in this Privacy Policy, nor disclose this information other than when required, or authorised by law or unless you have voluntarily consented to disclose this information to a third party.

Dealing with us anonymously

You can deal with us anonymously where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.

Your sensitive information

We will not without your prior consent collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record.

This is subject to some exceptions including:

• where the collection is required by law; and
• when the information is necessary for the establishment, exercise or defence of a legal claim.

Complaints Resolutions

Please contact our Privacy Officer / Compliance Manager at clientservice@investible.com if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 7 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.

Our Website

INVESTIBLE’s website may provide links to third party websites. The use of your information by these third party sites is not within the control of INVESTIBLE and we cannot accept responsibility for the conduct of these organisations. Other websites are not subject to our privacy standards. You will need to contact or review those websites directly to ascertain their privacy policies.

You may register with us to receive newsletters and other information. By doing so, your name and email address will be collected and stored on our database. We take care to ensure that the personal information you give us on our website is protected. For example, our website has electronic security systems in place, including the use of firewalls and data encryption.

If you do not wish to receive any further information from us, or you wish to update your registration details, please email your request to us. We will endeavour to meet your request within 5 working days.

Our Website may utilise cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using our site – they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.

Changes to our privacy and information handling practices

This Privacy Policy is subject to change at any time at our discretion. The amended policy will apply between us whether or not we have given you specific notice of any change. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

SPAM Policy

Spam is a generic term used to describe electronic ‘junk mail’- unwanted messages sent to a person’s email account or mobile phone. In Australia, spam is defined as ‘unsolicited commercial electronic messages’.

‘Electronic messaging’ covers emails, instant messaging, SMS and other mobile phone messaging, but not cover normal voice-to-voice communication by telephone.

INVESTIBLE Pty Ltd (ACN 54 603 802 795) ( “INVESTIBLE” ) complies with the provisions of the Spam Act 2003 (Cwth), when sending commercial electronic messages.

Equally importantly, INVESTIBLE ensures that our practices are in accordance with the Australian Privacy Principles in all activities where they deal with personal information. Personal information includes our clients contact details.

The three key steps INVESTIBLE follows:

• Consent – Only commercial electronic messages are sent with the addressee’s consent – either express or inferred consent;
• Identify – Electronic messages will include clear and accurate information about the person and that INVESTIBLE is responsible for sending the commercial electronic message; and
• Unsubscribe – We ensure that a functional unsubscribe facility is included in all our commercial electronic messages and deal with unsubscribe requests promptly.

Comply with the law regarding viral messages

INVESTIBLE ensures that commercial communications that include a Forwarding Facility contain a clear recommendation that the recipient should only forward the commercial communication to persons with whom they have a relationship, where that relationship means that person could be said to have Consented to receiving commercial communications.

Comply with the age sensitive content of commercial communication

Where the content of a commercial communication seeks to promote or inspire interaction with a product, service or event that is age sensitive, INVESTIBLE takes reasonable steps to ensure that such content is sent to Recipients who are legally entitled to use or participate in the product service or event

Note: Club INVESTIBLE Pty Ltd (ABN 38 608 913 408) is a Corporate Authorised Representative number 001 269 262 of Vestyn Capital Pty Ltd (ABN 11 155 738 542, AFS Licence No 421 584).

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