Privacy Policy—Sharesies Australia

Privacy Policy

Introduction

This Privacy Policy governs the collection and handling of your personal information by Sharesies AU Pty Limited ACN 646 197 122, a Corporate Authorised Representative (CAR No: 1284794) of Sanlam Private Wealth Pty Ltd (Australian Financial Services Licence No. 337927) (Sharesies).

Acting as a Corporate Authorised Representative for Sanlam Private Wealth Pty Ltd (Sanlam), Sharesies provides general financial product advice and deal in certain financial products to retail and wholesale clients in Australia (the Services).

This Privacy Policy sets out how Sharesies will collect, use, store and disclose your personal information (being any information or opinions about you which are reasonably identifiable) in accordance with the Privacy Act 1988 (Cth) (Privacy Act).

In this Privacy Policy, references to “we”, “us”, or “our” are references to Sharesies. References to “you” or “your” are references to Sharesies’ customers, contractors, suppliers (or potential customers, contractors, suppliers or employees), users of our website, and any other individuals we deal with in the course of running our business.

Acceptance of this Privacy Policy

You accept this Privacy Policy, and authorise the collection, use, disclosure, storage and retention of your information by Sharesies as described in this Privacy Policy when you access or use our Services or otherwise provide us with any of your personal information.

We may update this policy from time to time and without notice—you should review it periodically for any changes.

Types of personal information we may collect

The type of personal information we might collect about you will ultimately depend on how you access our Services or otherwise engage with us, but may include:

  • your full name and contact details (such as email, postal addresses and telephone numbers);

  • your age or date of birth;

  • your credit card information, for the purposes of enabling our third party payment gateway provider to process any transactions (please note that Sharesies will not itself collect or store this information);

  • your bank or other financial deposit account details, if relevant to your use of the Services; 

  • details or copies of your government issued identification (such as your passport, drivers licence or Medicare card), or other forms of identification or unique identifiers;

  • depending on your browser settings, your device type, ID, geo-location, computer and connection information, and other data or information about your access to our website;

  • details of the products or services you have enquired about or we have provided to you (including the Services), and any related information. If you use our Services, this can include information about your financial and investment holdings (such as details of the funds you have invested via Sharesies, trade histories) and any relevant taxation information (including your tax file number);

  • records of your enquiries or communications with us (including recordings of any phone calls); 

  • any other information you provide to us through our website or otherwise (such as customer surveys, mailing lists etc); and

  • if you are a contractor, supplier, or potential employee, any personal information that is relevant to your potential or actual engagement by us.

We don’t expect that we will collect your sensitive or health information as a matter of course, however if this occurs (for example, sensitive information may be evident from other materials we collect), we will ensure that such collection, and our use and disclosure, will comply with relevant laws.

We will generally collect the above types of personal information from you directly, when you engage with us or use our website. However, there are some circumstances in which we might collect personal information about you from third parties, such as Sanlam, our related bodies corporate, or service providers that help us to verify your identity, process transactions or provide marketing services. From time to time we may also collect information about you from publicly available sources.

You are not required to provide us with your personal information. However, if you don't, or we can't otherwise collect your information, it may affect our ability to engage you or provide you with our Services.

Using and disclosing your personal information 

How we use and disclose your personal information will ultimately depend upon the purpose for which we collected it, but may include: 

  • responding to your enquiries or sending you any requested information;

  • providing our Services to you;

  • assisting you to enquire about, or purchase, relevant third-party financial products and services;

  • enabling you to access our website; 

  • operating, protecting, improving and optimising our website, Services, users’ experience and business;

  • sending you marketing or promotional messages about our products and Services, or other third-party financial products and services that we think might be of interest to you— such messages may take the form of emails, SMS, mail or other forms of communications. You can opt out from these communications at any time by contacting us or using the unsubscribe functionality;

  • creating our own market data and providing information about the market (we note that we may use your personal information to obtain your feedback through a third party); 

  • if you are a contractor or supplier or potential employee, considering and facilitating your engagement;

  • detecting, preventing and protecting against fraud and crime; or

  • any other purpose which you have consented to or that is required or permitted by relevant laws or court orders.

We may share your personal information with our service providers, related bodies corporate, and business partners, such as:

  • Sanlam or members of the Sharesies Group, but only in connection with the purposes set out in this Privacy Policy;

  • our service providers, contractors and suppliers that help us to operate our business and fulfil the above purposes (e.g. IT platforms, third parties that help us to enhance the safety and security of the Service, stock exchanges, investment providers, cloud storage providers payment gateways, data analytics or research partners, mail-out and marketing providers); and 

  • any other entities we are required or permitted by law to disclose your personal information to (including domestic and international regulatory authorities). 

Some of these service providers, members of the Sharesies Group and business partners are located outside of Australia and may not be subject to Australian privacy laws. While this may change from time to time, we expect such recipients of your personal information to be located primarily in New Zealand, with the exception of cloud-based IT providers for systems such as customer relationship management and email. We will take such steps as are reasonable in the circumstances to confirm that those organisations are required to provide reasonable security and other protective measures in relation to your personal information. By providing us with your personal information, you authorise such disclosure.

We may share your personal information if we sell to, or merge some or all of our business or assets with, another company.

We can use and share information that does not identify you for any purpose.

A note on cookies and similar tech

Cookies and other similar technology are used to remember your browser or device during and between website or app visits. We can use this technology to do things, such as remember your preferences and settings, improve security, analyse traffic and trends, and measure the effectiveness and popularity of features or marketing.

This technology is linked to your browser or device rather than you as an individual. The sort of information collected includes your device type, date and time of use, referring website, IP address, and advertising identifiers. However, from time to time we may link this information to other information we collect about you, which can result in it being identifiable and therefore your personal information.

We may allow others to provide analytics, send messages and ads for us, and to track and report on performance. These entities may use cookies and other similar tech to identify your browser or device when you access our websites, as well as when you visit other online sites and services.

Retaining and deleting your information

We may hold your personal information in either electronic or hard copy form. We take all reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. 

Once we no longer need it for any of the purposes described in this Privacy Policy (or otherwise communicated to you), we will permanently delete or destroy the personal information we hold about you, unless otherwise required by law.

We’re committed to keeping your information safe and secure

We continuously implement and update security measures to help protect your information. However, despite all of our measures, we can’t guarantee the security of the transmission or storage of your information.

Your rights regarding your information

You may request:

  • access to your information (we may charge a fee); or

  • that we correct information that is inaccurate, incomplete or out of date,

by contacting our Privacy Officer using the details at the bottom of this Privacy Policy. We will take reasonable steps, consistent with our obligations under the Privacy Act, to correct or update that information if you so request.

If at any time you no longer wish to receive any additional marketing emails from us or our business partners, or do not want your information disclosed for direct marketing purposes, please contact our Privacy Officer using the details at the bottom of this Privacy Policy. Alternatively, you can opt out using the function in any electronic marketing communications sent from us or our business partners.

Our website and communications may contain links to third-party websites. Our terms don't apply to any third-party websites. We take no responsibility for the content, operation, or privacy practices of other websites.

Changes to our Privacy Policy

This document sets out our current Privacy Policy, last updated [10 December 2020]. We may review this policy from time to time and will notify you of any changes by posting an updated version on our Website.

Contact us

If you have any questions regarding our Privacy Policy or wish to access or amend the information that we hold about you, please contact our Privacy Officer at:

Attention: The Privacy Officer

Email: help@sharesies.com.au 

If you have concerns that we have not met our obligations to you as required by the Privacy Act, you may contact us and make a complaint at the address and/or email listed above.

More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the Office of the Australian Information Commissioner at:

Website: www.oaic.gov.au

Phone: 1300 363 992