Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
What personal information do we collect?
We may collect the following types of personal information:
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
Why do we collect, use and disclose personal information?
The information that we collect is intended to identify you as the owner of assets received or held by the site, to correctly identify the recipient of assets transferred from the site, in order to transact on the exchange and other material service obligations that we have to clients. We may collect, hold, use and disclose your personal information for the following purposes:
We also use and disclose your personal information as required by laws that apply to us, including our obligations under the AML/CTF Act and our reporting obligations to AUSTRAC. For more information on our AML/CTF obligations, please see our AML/CTF Policy at [insert url link]. We work with government agencies and law enforcement bodies in Australia and, if required, internationally, to aid in the mitigation and enforcement against fraud, money-laundering, terrorist-funding and economic or political sanctions. We are required by law (including under the AML/CTF Act) to verify your identity and conduct ‘Politically Exposed Persons’ and sanctions checks on you. If we are required by law to disclose your personal information to a government agency, regulatory body or law enforcement body, we will do so.
Do we use your personal information for direct marketing?
We may send you direct marketing communications and information about our services, products and market research. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link). Please note that we do not sell your personal information to third parties for marketing purposes.
We may send marketing and/or promotional messages to any electronic address that you provide or for which you are responsible. You warrant that you have authority, either as or on behalf of the electronic account holder, to provide this consent and agree that until you withdraw your consent by providing written notice to us or using an unsubscribe facility in the message, we may continue to send commercial electronic messages to those addresses. It is in our legitimate intent to provide you with the best products and services we can by keeping you informed and hearing your feedback.
To whom do we disclose your personal information?
Disclosure of personal information outside Australia
We may disclose personal information outside of Australia to organizations who provide services in relation to ID verification, AML/CTF screening, data security and storage located in Singapore, Hong Kong and the United Kingdom. When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
Using our website and cookies
We may collect personal information about you when you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit, your operating system, browser type and the internet protocol (IP) address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
We take reasonable steps to ensure that your personal information is protected appropriately. Although we periodically review our systems for effectiveness, we can give no guarantee that your personal information will not suffer misuse, loss, unauthorised access, modification or disclosure. We ensure that we meets OAIC guidelines regarding the appropriate levels of information and software security, governance and associated procedures.
Retention of Personal Information
Personal and transactional information relating to your account is generally held for at least 7 years after the account has been closed. This is in order to fulfill our obligations to our legal, compliance and regulatory obligations. If we determine that there is no reasonable requirement as to why personal information held in respect of an individual is no longer needed for our functions or the services we provide, we will permanently destroy or de-identify that information.
Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the contact information set out below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected. Depending on the type of request, requests may attract a minimal charge.
If you consider that any action of ours breaches this privacy notice or the Australian Privacy Principles or otherwise doesn’t respect your privacy, you can make a complaint. This will be acted upon promptly. To make a complaint, write to us at Level 36, 1 Macquarie Place, Sydney NSW 2000, or email: firstname.lastname@example.org
If you are not satisfied with our response to your complaint, you can contact the Office of the Australian Information Commissioner
Phone Number 1300 363 992