CROWDPROPERTY PTY LTD
WHO ARE WE?
In this policy, ‘we’, ‘us’ and ‘our’ refer to CrowdProperty Pty Ltd ACN 633 516 195 (CrowdProperty), and the CrowdProperty Investment Trust (the Trust) and our related businesses including:
Quay Fund Services Limited (Quay) as the trustee for the Trust
CrowdProperty holds a Corporate Authorised Representative authorisation (No. 001285637) from Quay (AFSL No.494886)
CrowdProperty Limited (UK) as a technology platform partner
We collect, use and handle your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), and specifically the Australian Privacy Principles. and the extent applicable data protection or privacy laws of any other country.
OUR COMMITMENT TO PROTECT YOUR PRIVACY
At CrowdProperty, we understand that the details you provide us are private and personal. It’s important that you feel secure whenever you deal with us. It’s also important that you understand how we protect your privacy and the manner in which we may use your details. As such our policies relating to personal information are designed to ensure that you are fully protected under Australian Privacy Laws.
Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.
When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you.
The types of personal information we may collect about you include your name, date of birth, address, account details, occupation, employment details & history, financial needs & objectives, investment preferences & aversion or tolerance to risk, current financial circumstances, including assets & liabilities,, income expenditure, family structure, including dependents, socialsecurity eligibility, medical history & reports, etc and any other information we made need to identify you.
WHY WE COLLECT YOUR PERSONAL INFORMATION
We collect personal information when you apply for financial products or services, insurance policies or related services, and to update our records.
We may also collect your personal information for the purposes of direct marketing, such as articles that may be of interest to you, as well as managing our relationship with you. From time to time we may offer you other products and services.
To enable us to maintain a successful business relationship with you, we may disclose your personal information for the purposes for which it was provided or secondary purposes in circumstances where you would reasonably expect such use or disclosure. Our responsibilities extend, among other things, to fraud, money laundering and other crime prevention, careful credit assessment and validation of the identity of all Users of the in accordance with Australian laws.
The information we collect from you may also be disclosed to third parties if the disclosure is required by or permitted by law.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Where reasonable and practical we will collect your personal information directly from you. We may also collect your personal information from product providers and other people such as accountants and lawyers.
HOW DO WE COLLECT YOUR SITE DATA ACTIVITY USING COOKIES AND METADATA?
A Cookie is a small piece of computer code which remains on your computer and contains information which helps Us identify your browser.
When you visit Our website and applications and tools on it, the cookie records the authentication to allow your user id to login. We use the information gathered by cookies to identify your web browser so that when you log in on the next occasion your use of the website and other applications and tools on it is easier and faster because the website has remembered your details.
Sometimes information that you upload is provided with associated metadata. If you do not want us to use the metadata you must remove it by erasure from the underlying document/materials properties before uploading it onto the website and other applications and tools.
DO WE DISCLOSE YOUR PERSONAL INFORMATION?
We may disclose your personal information:
to other organisations that are involved in managing or administering your investments, such as third party suppliers, printing and postal services, call centres;
to associated businesses that may want to market products to you;
to companies that provide information and infrastructure systems to us;
to anybody who represents you, such as finance brokers, lawyers and accountants, insurers investment/super providers;
to anyone, where you have provided us consent;
where we are required to do so by law, such as under the Anti-Money or Laundering and Counter Terrorism Financing Act 2006 (Cth);
to investors, agents or advisers, or any entity that has an interest in our business; or
to your employer, referees or identity verification services.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfyourselves that:
(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
(b) you have consented to us making the disclosure.
We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia and administered by our partner CrowdProperty Ltd, who are based in the UK.
We may disclose your personal information to overseas entities that provide support functions to us.
You may obtain more information about these entities by contacting us.
From time to time we may use your personal information to provide you with current information about investments, superannuation, insurance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.
If the direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
UPDATING YOUR PERSONAL INFORMATION
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.
ACCESS AND CORRECTION TO YOUR PERSONAL INFORMATION
We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time.
We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.
An explanation will be provided to you if we deny you access to the personal information we hold about you.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.
We may need to consult with other entities as part of our investigation.
If we refuse to correct personal information we will provide you with our reasons for not correcting the information.
USING GOVERNMENT IDENTIFIERS
If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.
BUSINESS WITHOUT IDENTIFYING YOU
In most circumstances, it will be necessary for us to identify you in order to successfully do business with you. However, you may deal with us anonymously where it is lawful, practicable and reasonable to do so.
We will only collect sensitive information about you with your consent. Sensitive information is personal information that includesinformation relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.
HOW SAFE AND SECURE IS YOUR PERSONAL INFORMATION THAT WE HOLD?
We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact our Complaints Officer on:
Phone: 02 7227 7377
Mail: PO Box 1928, Neutral Bay Junction, NSW 2089
The Compliance Manager will deal with your complaint confidentially and endeavour to acknowledge receipt in writing within two business days of receiving the complaint. We will try to resolve all issues within a maximum of 45 days of receipt, but in a shorter period if possible. If it is impossible to substantially respond to your complaint within 45 calendar days, you will, before the end of that period, be:
informed of the reasons for the delay;
advised of your right to complain to the Australian Financial Complaints Authority (AFCA);and;
be provided with the contact details of the AFCA.
In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Australian Financial Complaints Authority: https://www.afca.org.au/make-a-complaint/
You may request further information about the way we manage your personal information by contacting us.
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.