Privacy policy - InvestorHub

1. Overview.

In this Privacy Policy (Policy), 'us', 'we' or 'our' means FRESH EQUITIES PTY LTD (ACN 619 657 028).

Your privacy is important to us and we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act), which includes the Australian Privacy Principles (APPs).

This Policy outlines how we collect, use, disclose and store your personal information. This Policy will also let you know how you can access that information. It applies to all personal information collected via our website www.freshequities.com (Site) and social media accounts, including Facebook, Instagram, LinkedIn and Twitter (together, Online Services).

This Policy is available free of charge and can be viewed from our Site or upon request from compliance@freshequities.com.

In this Policy:

• 'Personal information' means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
• 'Sensitive information' means information or an opinion about an individual's criminal record.
• 'Disclosing' means providing information to persons outside of Fresh Equities.
• 'Individual' means a natural person whose personal information we collect, use, or disclose.

2. Consent.

By providing personal information, you consent to us collecting, using, storing and disclosing your personal information in accordance with this policy or as required or permitted by law.

You may refuse to give us your consent, and you may withdraw your consent, to some or all of the purposes in this Policy.

If you do not give us your consent, or withdraw your consent, in whole or part:

1. we may not be able to provide our Online Services to you; and
2. you may need to stop using our Online Services.

If you continue using our Online Services, then we will treat your use as your consent to us handling your personal information in accordance with this policy.

3. The types of information we collect.

3.1. Personal information

Personal information is information or an opinion about you which identifies you, or from which you can be reasonably identified.

We collect the following types of personal information about you:

1. your name, gender, email address, age, date of birth and mobile number;
2. your occupation;
3. your payment and transactional information;
4. your residential address or business address;
5. your device ID, device type and information, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, Internet Protocol (IP) address and standard web log information;
6. details of products or services which we have provided to you or about which you have enquired;
7. information contained in any communications between you and us;
8. information you provide if you participate in a survey, promotion or competition;
9. information about your investment habits, investment ranges and industries or sectors in which you are interested in investing; and
10. any other personal information you provide us when you access our Online Services.

3.2. Sensitive information

We may collect information about any criminal record you may have from third parties only if you consent to us collecting this information about you and the collection is reasonably necessary for one or more of our functions or activities.

3.3. Other personal information

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout

4. Why we collect and use your personal information.

We collect and use your personal information through lawful and fair means, so we can perform our business activities and functions.

Your personal information is collected and used for the following purposes:

1. to verify your identity under the Anti-Money Laundering and Counter-Terrorism Act 2006 (Cth) and the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1);
2. to provide you with our products and services, including accepting and processing your orders, delivering orders and providing refunds or discounts;
3. to give you information about our products and services;
4. to interact with you;
5. to administer surveys;
6. to send you promotional and marketing information about our products and services;
7. to administer rewards or other promotional activities sponsored or managed by us;
8. to develop, improve and market our products and services;
9. to conduct product and market research;
10. to develop consumer insights so we can better understand your preferences and interests, personalise your experience and enhance the products and services you receive;
11. to send you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you;
12. to perform administrative and operational functions;
13. to comply with any legal requirements;
14. for any related purpose for which we are entitled to use your personal information; and
15. for any other purpose for which you give your consent.

5. How we collect your personal information.

5.1. You give it to us

We collect personal information directly from you when you:

1. use our Online Services;
2. set up an account with us;
3. communicate with us;
4. share personal information with us from other applications, social media, websites or services;
5. participate in one of our surveys, promotions or competitions; or
6. purchase one of our products or services.

5.2. We collect it from third parties

We may collect personal information about you from third parties such as law enforcement agencies, government authorities and credit reporting agencies for the purposes of verifying your identity.

We also collect personal information about you from other sources, including from our partners who use the Site or Online Services. We may collect this information when one of our partners refers you to us, or for one of the reasons provided in paragraph 4 above.

5.3. We collect it through cookies

We also use cookies to collect personal information when you use our Site. Cookies are small data files transferred onto computers or devices by websites. When you use or access our Site, we may collect information by sending and storing cookies from our Site to your device.

Cookies tell us when you visit our Site, which pages you visit and the information you download. They also remember your details and preferences so you can easily continue your browsing session when you return to our Site.

If you do not want to activate cookies, you can opt-out of receiving them by amending the settings of your internet browser, however, you may find that some parts of our Site will have limited functionality and personalisation if you do so.

6. Dealing with us anonymously.

You may choose to deal with us anonymously or by using a pseudonym in certain circumstances, such as when you contact us to make a general enquiry. In most circumstances, however, at a minimum we need your name and contact details to allow us to handle your enquiry or request.

7. Disclosing your personal information and who might have access.

7.1. Within Australia

We may disclose your personal information to the following third parties for the purposes described in this Policy:
1. other users of the Site for the purposes of enabling connections between you and them;
2. our clients for the purposes of enabling connections between you and them;
3. our employees, related entities and employees of those related entities;
4. our professional advisers;
5. third parties and contractors who provide services to us, including information technology service providers;
6. any third parties authorised by you to receive information held by us; and
7. government, regulatory and law enforcement agencies as required, authorised or permitted by law.

7.2. Outside Australia

We may disclose your personal information to corporate advisors who have registered to use the capital raising platform we offer through the Site (Advisors). Some Advisors are based in and operate out of the United States of America, Singapore and Hong Kong.

By providing us with your personal information, you consent to us disclosing your personal information to overseas Advisors and acknowledge we will take reasonable steps to ensure they deal with your personal information in a way that complies with the Privacy Act and the APPs.

8. Using your personal information for direct marketing.

We do not use personal information for the purposes of direct marketing, unless:

1. the personal information does not include sensitive information;
2. you would reasonably expect us to use or disclose the information for the purposes of direct marketing;
3. a simple way of opting out of direct marketing is provided; and
4. the individual has not requested to opt out of receiving direct marketing from us.

In relation to sensitive information, we may only use or disclose sensitive information about you for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.

We may use your personal information to contact you via phone, SMS, email or mail to promote and market our products and services. By providing us with your personal information, you consent to us contacting you for direct marketing purposes. You can opt-out from being contacted by us for direct marketing by emailing 'unsubscribe' to contact@dealpad.com.au.

9. Security.

9.1. How we store and protect your personal informationWe recognise how important the security of personal information is. While we take reasonable steps to ensure your personal information is protected from loss, misuse, unauthorised access, modification or disclosure, security measures over the internet cannot be guaranteed. This means we cannot guarantee the security of your personal information. In the event of an eligible data breach, we will comply with the required data breach reporting laws under the Privacy Act.

We hold your personal information in hard copy or electronic form, in facilities or secure databases that we own and operate, or that are owned and operated by our third party service providers. We manage the security of your personal information by login password controls, monitoring staff emails and conducting periodic information security audits.

Where we no longer require the personal information for a permitted purpose under the APPs, we will take reasonable steps to destroy it.

10. Links to third party websites/platforms.

Our Online Services may contain links to websites, other applications and social media platforms operated by third parties.

Those links are provided for convenience and may not remain current or be maintained. Unless stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites.

The privacy policies that apply to third parties’ websites may differ substantially from this Policy, so we encourage you to read those privacy policies before using those websites.

11. Accessing or correcting your personal information.

11.1. Accessing your personal information

If you would like to access your personal information, please contact us using the details below.

While we try to give you access to your personal information free of charge, we may charge you a reasonable fee to cover costs associated with:

1. searching for, locating and retrieving your personal information; and
2. reproducing and sending you your personal information.

In certain circumstances, we may not be able to give you access to your personal information. In these circumstances, we will write to you to explain why we cannot comply with your request.

We aim to respond to requests for access within 14 days of receiving a written request.

11.2. Correcting your personal information

We try to ensure any personal information we hold about you is accurate, up-to-date, complete and relevant.

If you believe the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or incorrect, please contact us using the details below and we will take reasonable steps to ensure it is corrected.

We aim to respond to requests for correction within 14 days of receiving a written request.

12. Destroying or de-identifying personal information.

We destroy personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information.

13. Making a complaint.

If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details below.

We take privacy complaints seriously. If you make a complaint, we will respond within 7 days to advise you of the person responsible for managing your complaint. We will try to resolve your complaint within 30 days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint.

We will investigate your complaint and, where necessary, consult with third parties about your complaint. We will decide how to address your complaint and write to you to explain our decision.

If you are not satisfied with our decision, you can refer your complaint to the Office of the Australian Privacy Commissioner. Details about how to file a complaint can be found at www.oaic.gov.au.

14. Changes.

We may, from time to time, amend this Policy, in whole or part, in our sole discretion. Any changes to this Policy will be effective immediately upon the posting of the revised Policy on our Site.

Depending on the nature of the change, we may announce the change on our Site home page or by email (if we have your email address). However, in any event, by continuing to use the Online Services following any changes, you will be deemed to have agreed to such changes.

15. Contact us.

All questions or queries about this Policy and complaints should be directed to:

Privacy Officer
compliance@freshequities.com

This Policy was last updated on 4 May 2022.

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