We are committed to protecting your privacy and the security of your personal information.
1 What does “personal information” mean?
“Personal information” is any information that can identify you or that can reasonably enable your identification to be determined. This information could include your name, postal or email address, date of birth or financial details.
Personal information includes “sensitive information”. Sensitive information is any personal information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, health or genetic information.
2 What personal information do we collect?
The type of personal information we collect and hold about you will depend on the dealings you have with us. When you deal with us (including for the purposes described in section 3 of this policy) the types of personal information you may be required to provide to us include:
- your contact details (for example, name, address, telephone number and email address), date of birth, gender and occupation;
- financial information;
- your Tax File Number;
- your Australian Business Number (if applicable);
- your bank account or other financial institution details; and
- identification documents (for example, drivers licence).
When you use our website, we may also indirectly collect your internet protocol (IP) address, device identifiers, browser type, operating system, internet service provider, location, mobile network information, pages accessed, time stamps and your online transaction history.
3 For what purposes will we use your personal information?
We collect, use and disclose your personal information in order to provide our services to you, including for the following purposes:
- Your identification details are used to enable us to provide our services to you, including to:
- process your application to register with us;
- verify your identity and contact information,
- set up an account in your name;
- provide you with secure access to our website;
- contact you to inform you about potential investments that we can arrange for you to make;
- receive and act upon your instructions to arrange for investments to be made on your behalf;
- process payments you make to us in connection with making investments and for our services;
- arrange for investments to be made on your behalf in accordance with your instructions;
- provide you with information about any important changes relating to investments you have made using our services, and related services, as well as any changes to our business generally;
- improve the services we provide to you; and
- ensure that we comply with our legal and regulatory obligations.
- If you have instructed us to arrange for an investment to be made on your behalf, we will hold information about that investment, which you will be able to view when you log in securely to our website.
- Your Tax File Number and Australian Business Number (where relevant) will be collected in order to ensure that any investment which is made on your behalf can be taxed correctly.
- We may also use your personal information for any purpose:
- for which your personal information was originally collected or you have consented;
- for enforcement related activities conducted by, or on behalf of, an enforcement body; or
- which is authorised or required by a court/tribunal order or an Australian law.
We may collect, use and disclose your personal information to provide you with information about our products and services and products offered by other parties that we believe may be of interest to you (including by way of direct mail, telephone, email, SMS and MMS, secure portals, and online advertising and marketing) or to request your feedback for research purposes. You always have the right to opt out of receiving such information. You may exercise that right by contacting us as set out below in section 13.
If you cease your relationship with us and close down your account, we will only retain your personal information on file to the extent necessary to meet our legal obligations and we will only contact you with your consent.
4 Do you have to provide your personal information to us?
If lawful and practicable, we offer you the opportunity to deal with us anonymously or by using a pseudonym. For example, we can provide general information to you about our products or services, or general guidance on how to fill out our forms, without collecting any of your personal information.
However, if we are unable to collect and/or verify some or all of your personal information, we may not be able to enter into a business relationship with you or provide certain services to you. In order for us to provide our services to you, it is normally impracticable for us to deal with you anonymously or by using a pseudonym. For example if you do not provide your personal information to us, we will be unable to provide our services to you, as it will not be possible for us to arrange for investments to be made on your behalf.
5 How do we collect your personal information?
We will generally collect your personal information as much as possible directly from you. For example, we collect information about you when you apply to register with us and through other forms that you may complete in order to allow us to arrange for investments to be made on your behalf.
We may on occasion collect your personal information from publicly available sources of information and from third parties, including for example, from:
- your financial adviser or another person whom you have authorised us to contact;
- Australia Post and/or the Australian Taxation Office (if we cannot contact you);
- identity verification service providers; or
- direct marketing organisations and data providers.
We will only collect “sensitive information” if you have consented to the collection of the information and the information is reasonably necessary for one or more of our functions or activities or if the collection of sensitive information is authorised or required by a court/tribunal order or an Australian law, including the following Australian laws:
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
- Corporations Act 2001 (Cth);
- Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth);
- Privacy Act.
6 Who do we disclose your personal information to?
As set out in sections 2 and 3 above, there are a range of people and organisations we may disclose your personal information to and collect your personal information from. The particular party we may disclose your personal information to will depend on the dealings you have with us. Some examples of persons to whom we may disclose your personal information include:
- we will use a third-party nominee selected at our discretion, whom you will authorises us to appoint to hold an investment on your behalf when you ask us to arrange for you to make an investment;
- issuers of financial products that we may promote through our website and arrange for the nominee to apply to invest in on your behalf;
- Automic Group Pty Ltd (ACN 152 260 814), whom we have appointed to provide our registry services to keep records of your account and any investments the nominee holds on your behalf;
- Lanterne Fund Services Pty Ltd (ABN 49 098 472 587, AFSL 238198), a financial services licensee that has appointed us as its authorised representative and is responsible for ensuring that we comply with the financial services laws;
- mail and electronic mail service providers for the communication of investor statements and other information;
- legal advisers and other experts;
- regulatory authorities and legal bodies as required by law (e.g. Australian Taxation Office, the Australian Transaction Reports and Analysis Centre, Australian Prudential Regulation Authority, the Australian Securities and Investments Commission or a court or tribunal);
- auditors (in order to assist them in conducting their independent audit and review activities of our financial statements and operations);
- other third party service providers who may provide contracted services to us to assist us to provide our services to you, such as information technology support, hosting services, telephone services, mailing or sending other documentation, identity verification, fraud prevention, marketing or market research.
We may also share your personal information with a third party where we have obtained your consent.
Where practicable, we will use our best endeavours to seek your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected.
If you do not consent to us collecting, using and/or disclosing your personal information for such other purposes, this may affect our ability to deliver and improve our services, or to engage or do business with you.
7 Do we disclose your personal information overseas?
We will only disclose your personal information to a recipient overseas in accordance with the Privacy Act. Circumstances in which we will do this include where:
- you have asked us to, or we have your consent to do so;
- we have outsourced a business activity or function to a service provider located outside Australia;
- we reasonably believe that the overseas recipient is subject to a law or binding scheme that protects the information in a way that is substantially similar to the way the information is protected under the Privacy Act and the Australian Privacy Principles, and there are mechanisms you can access to take action to enforce that protection; or
- the disclosure is required or authorised by or under an Australian law or a court/tribunal order.
Please note that the laws on processing personal information in other countries may be less stringent than in Australia. When we disclose your personal information overseas, we will take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia, including the Australian Privacy Principles.
8 How do we protect your personal information?
We have security policies and systems in place to protect your personal information. We take reasonable steps to protect the personal information we hold from loss, interference, destruction, unauthorised access, modification or disclosure using both physical and electronic security measures. We implement multiple layers of security controls throughout our systems so that in the event that one control fails, or a vulnerability is exploited, there are other measures still in place to protect your personal information. Relevant measures include firewalls, data encryption, limiting physical access to data centres and controls over access to information.
Only the people within our organisation who have the need to access your personal information will be dealing with it. We have put in place arrangements to ensure that they have the training and skills to protect your personal information from unauthorised access or misuse.
Our website uses industry standard security protocols to protect the personal information you disclose in using our online facilities. We use encryption to provide more secure communications when using our online facilities. In addition, when you use our website you must read and accept the Terms and Conditions relating to privacy and security. You can review the Terms and Conditions by clicking on the following link: https://www.stropro.com/terms-and-conditions/
If you provide us with your personal information over the internet, you accept that such information will be transmitted at your own risk as the security of such information cannot be guaranteed.
You are responsible for keeping your account details, including your user name and password, confidential and secure.
9 Can you access the personal information we hold about you?
You may request access to any of the personal information we hold about you by contacting us as set out below in section 12. A summary of personal information such as your name and contact details and the investments we have arranged for you to make is available to you upon request. We will provide you with access to your personal information in accordance with the Privacy Act.
Under the Privacy Act, we can deny access to some or all of your personal information in specified circumstances, and will provide reasons for any refusal in writing. If you are not satisfied with any refusal to grant you access to your personal information, you may make a complaint (see section 13).
10 Can you correct any personal information held by us that is incorrect?
We endeavour to ensure that the personal information we hold about you is accurate, up-to-date, complete, relevant and not misleading. Please let us know if you believe any of your personal information that we hold is incorrect by contacting us as set out below in section 12.
To ensure that the information we hold about you remains accurate, complete and up-to-date, we may ask you to check and correct your personal details from time to time. We may do this as part of our regular communications with you, when you make a telephone enquiry or through other means.
Some of the pages on our website use “cookies”, which are small files that may be placed on your hard disk for record-keeping purposes. Cookies helps us remember who you are and may collect and store your server address, top level domain name (e.g. .com, .gov, .net etc), the date and time of your visit, country your service address is located in, the type of browser you used, the pages viewed and any downloads made, the previous site you visited and the site you visited next. Cookies can make your subsequent visits to our website simpler and more efficient (for example, your password may be saved so you do not need to re-enter it). We may also use the information to assist in improving the website, marketing and product development.
You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. (However, by not accepting cookies, some pages on the website may not display properly or you may not be permitted to access certain information.) A server cannot find out a name or email address, or anything about you by using cookies.
We do not store or collect cookie information. Once we receive information from you, via email or any other means, the information is stored in a secure environment.
If you have any queries you can contact us by the following means:
Call: Robert Nicholls, Director on +61 0403 806 779
Mail: Level 3, 36 York Street, Sydney NSW 2000
13 Can you complain about a breach of your privacy?
Call: Robert Nicholls, Director on +61 0403 806 779
Email: email@example.com or firstname.lastname@example.org
Mail: Level 3, 36 York Street, Sydney NSW 2000
Please mark the envelope or the email message “Notice of Privacy Complaint”. We will try to resolve your complaint quickly and fairly.
If you are not satisfied with the manner in which we deal with your complaint you may refer it to the Office of the Australian Information Commissioner (OAIC). You can contact the OAIC:
Online: by visiting www.oaic.gov.au
Phone: 1300 363 992
Mail: GPO Box 5218
Sydney NSW 2001