- Individuals in the EU
If you are in the European Union (EU) (including the European Economic Area (“EEA”)), the collection and processing of your personal information will be subject to the General Data Protection Regulation (2016/679) (“GDPR”). In providing our services to you, we may collect and process personal information as outlined below. We will be a data controller for the purposes of the GDPR and this policy includes information that must be provided to you when we collect your personal information.
- What personal information do we collect?
2.1 - We may, in addition to other information, collect the following personal information about you:
(a) Information you provide to us when you register an account to use the Vest Platform and our services and when you maintain your account;
(b) Information you provide to us when you contact us via the Vest Platform, email, telephone or otherwise;
(c) Your name, email address, residential address, contact telephone numbers, date of birth and password;
(d) Financial information, such as your bank account details;
(e) Specific documents to verify your identity and other personal details;
(f) Details of transactions you carry out through the Vest Platform;
(g) Details of your visits to the Vest Platform;
(h) Information obtained from Plugins; and
(i) Information obtained from third parties (such as Facebook or Linkedin).
- How do we use personal information?
(a) Verifying any information that you give to us, or information that we collect from third parties and any third party databases;
(b) Carrying out credit and identity checks;
(c) Assessing your suitability to register with us and use the Vest Platform and our services;
(d) Providing our services to you;
(e) Satisfying any obligation arising from any agreement between you and us;
(f) Complying with our legal and regulatory obligations or in connection with legal proceedings, including but not limited to money laundering, crime or fraud prevention, detection or prosecution;
(g) Storing data;
(h) Accessing and making information available through the Vest Platform;
(i) Contacting you with information about us, our services and new investment opportunities that we think may be of interest to you;
(j) Monitoring, operating, maintaining and improving the Vest Platform; and
(k) any other purpose permitted under the Privacy Act 1988 (Cth) or that we notify you of at the time personal information is collected. By using the Vest Platform, you are agreeing to authorise any third party to provide your personal information to us for any of the above purposes.
- When do we disclose personal information?
5.1 - We may disclose personal information to our related companies, service providers (including credit reporting agencies), Plugins, and others working with us to help us provide, improve and promote the Vest Platform and our services.
5.2 - We may also disclose any of the personal information we hold:
(a) For the purposes for which the information was collected;
(b) With your express consent;
(c) For any purpose which is permitted under the Privacy Act 1988 (Cth);
(d) In relation to any proposed purchase or acquisition of our business or assets; or
(e) Where required by applicable law or any court, or in response to a request by a law enforcement agency.
5.4 - If we disclose your personal information to a credit reporting agency, that agency may hold your information on their credit reporting database and use it for providing credit reporting services and for any other lawful purpose and the agency may disclose your information to their subscribers for the purpose of credit checking or debt collection or for any other lawful purpose.
- How do we store personal information?
6.1 - We store your personal information in our electronic database and in print form. The information that we collect may be transferred to, and stored in Australia and overseas with our group companies. We may also subcontract processing to, or share your personal information with, third parties located in countries other than Australia (such as companies that we engage in relation to technical or billing support). Your personal data, therefore, may be subject to privacy laws that are different from those in your country.
6.2 - Any third parties to whom we disclose or permit access to your personal information in the course of providing services on our behalf will be subject to strict contractual restrictions to ensure that they protect personal information and keep it confidential, consistent with relevant privacy and data protection laws.
6.3 - We will keep your personal information for as long as necessary to achieve the purposes for which we collected it, and in all cases for such periods as we are required to in order to comply with any relevant legislation and regulations. Where we no longer need to keep your personal information, we will take reasonable steps to destroy or de-identify your personal information.
- Protection of data
7.2 - Please note that the transmission of information via the internet is not completely secure. Although we will take steps to protect your personal data, we cannot guarantee the security of your data transmitted to the Vest Platform and any transmission is at your own risk.
- Access and complaints if you are in the EU
8.1 - In certain circumstances, you also have the right to request that the personal information collected from you is erased, to request that its further processing is restricted and to object to its further processing. You also have the right to data portability. You can request that personal information provided by you to us is transmitted to another party. You may withdraw your consent where it has been provided as a condition of our processing your information in certain circumstances.
8.2 - If we refuse any request you make in relation to these rights, we will write to you to explain why and how you can make a complaint about our decision.
8.3 - To make a request in relation to these rights or to make a complaint, please contact us.
8.4 - You also have the right to lodge a complaint with a relevant data protection supervisory authority (for example in the place you reside or where you believe we breached your rights).
- Your rights
9.1 - Except in limited circumstances, you have the right to request access to or correct any of the personal information we hold about you. You also have the right to request us not to pass on your personal information and to make a complaint about any of the personal information we hold about you. However, under various laws and regulatory requirements, we may have to pass on certain information to other organisations. If you would like to exercise any of these rights, please contact us at: firstname.lastname@example.org
9.2 - The Vest Platform may contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies.