Independent Reserve Pty. Ltd. (we, us or Independent Reserve) is bound by the Privacy Act 1988 (Cth), including the Australian Privacy Principles. This Policy describes our policies and practices for collecting, handling, storing, using and disclosing personal information for the purposes of our functions and activities. It also deals with how you can complain about a breach of the privacy laws, access the personal information we hold about you and have that personal information corrected (where necessary).
What is personal information?
'Personal information' is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Examples include an individual name, address, contact number and email address.
‘Sensitive information’ is a special category of personal information. Sensitive information includes health information and information about an individual’s race or ethnic origin, philosophical beliefs, membership of a professional or trade association, membership of a trade union, religious or philosophical beliefs.
The kinds of personal information we collect and hold
We collect and hold a range of personal information in carrying out our business and functions as a cryptocurrency and Bitcoin exchange. The kinds of personal information we collect and hold about you will depend upon the nature of our relationship with you and the circumstances of collection, including whether we collect the information from you as a customer, supplier, job applicant or some other capacity.
For example, if you are a customer:
- your identity and contact details including; name, previous and current address, email address, Tax File Numbers, phone number, date of birth, gender, passport or other identification details;
- payment information and transaction history in connection with account;
- IP address or MAC address when using our website or mobile applications (and other associated details, including the city associated with your IP or MAC address, the date and time of your visit to our website, pages viewed, the URL of the website that you viewed before our website and the type of browser you use);
- your feedback and, opinions about our products and services; and
- information relating to your dealings with us and our related entities, including insights about you so that we can better understand your preferences and interests.
If you apply for a job with us, we may collect your name and contact details as well as information in relation to your past or current employment. If you are or become an employee, the handling of your personal information may be exempt from the APPs if it’s directly related to your current or former employment relationship with us.
If you deal with us in some other capacity, we may collect your name and contact details and any other information you choose to provide to us.
We do not generally collect sensitive information and we will only collect sensitive information about you with your consent (unless we are otherwise required or authorised by or under law to do so).
How do we collect personal information
We collect personal information in a variety of ways, including:
- from you directly (such as when you interact with us in writing, electronically or by telephone);
- when you communicate with us through our website and Platform; and
- social media (such as LinkedIn and Facebook).
The purposes for which we collect, hold, use and disclose personal information
We collect, hold, use and disclose personal information for a range of purposes including:
- to supply our products and services to you;
- to process your transactions and communicate with you about those transactions;
- to respond to your enquiries about the Independent Reserve’s Platform;
- to process payments made to us;
- to carry out research, planning, service development, security and risk management;
- to contract out some of our functions to external service providers and suppliers (such as advertising, marketing and campaign managers, market research and recruitment);
- for our administrative purposes and internal record keeping;
- to provide you with customer service or technical support and deal with any complaints or feedback you have;
- to prevent or investigate illegal or potentially illegal activities;
- to perform research and analysis and improve or develop Independent Reserve’s Platform;
- to maintain, manage and develop our relationships with our customers, suppliers and contractors;
- to assess and consider applications from prospective employees, contractors and service providers;
- to develop and manage relationships with our employees, contractors and service providers;
- to manage insurance; and
- to conduct further searches and enquiries regarding the information you have provided to us or more generally to collect additional personal information about you or your associates for our regulatory or prudential purposes.
We may use and disclose your personal information for other purposes required or authorised by or under law (including purposes for which you have provided your consent).
We may use your personal information so we can contact you with information about our products and services, special offers, promotions and events that may be of interest to you.
We may contact you by email, mail or telephone .If you do not wish to receive promotional offer you may unsubscribe from receiving these communications at any time by contacting us at firstname.lastname@example.org.
What if you don’t provide personal information to us?
If you do not provide us with some or all the personal information that we ask for, we may not be able to verify your identity and as such you may not be able to open a trading account with Independent Reserve or use our Platform.
You can contact us to make a general query without using your name or by using a pseudonym. However we may need your name or contact details to respond to you.
Disclosure of personal information to third parties
If you ask us to, we will share your personal information with your financial adviser, or other professional and business advisers (such as lawyers and auditors). This could include making information held in your Independent Reserve account available for viewing by your advisers through the Iress Platform.
Other third parties
In conducting our business, we may disclose your personal information to third parties for the purposes outlined above. These third parties may include, where appropriate:
- our related companies (including Independent Reserve SG Pte Limited);
- financial institutions and payment services providers for payment processing;
- identity verification services;
our contracted service providers, including:
- IT service providers;
- marketing, promotional and market research agencies; and
- external business advisers (such as auditors and lawyers);
- in the case of a sale of our business (in whole or in part) to the purchaser (as an asset of the business); or
- if you are a job applicant, referees whose details you provide to us.
We may disclose your information to law enforcement agencies in Australia if requested as part of an investigation or to other third parties and for other purposes where we are required or authorised by or under law to do so (including where you have provided your consent).
We do not sell, trade, or rent your personal information to others.
Overseas disclosures of personal information
Some of our service providers and related companies are located outside Australia. As a result, personal information collected and held by us may be transferred to recipients in other countries. In particular, we may disclose personal information to our related companies located in Singapore. We may also use service providers located in a range of countries to conduct identity verification.
We may disclose personal information to external service providers located overseas in New Zealand and the United States so that they can provide us with services in connection with the operation of our business, such as marketing services and data storage.
How we hold personal information
We generally hold personal information in computer systems, including computer systems operated for us by our service providers. We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. This includes taking appropriate security measures to protect electronic materials and requiring our service providers to do so.
We store hardcopy files in offices and cupboards within an access controlled premises. Under our records managements system, access to files is appropriately limited. We may apply additional security measures limiting access to information about files or store files in locked cupboards or access restricted rooms as necessary or desirable based on our clients' needs.
We store electronic records within our own secure network and through third party data storage providers. Personal information within our network is password protected and access is appropriately limited.
Our third party data storage providers are required to protect personal information in accordance with applicable laws and take appropriate technical and organisation measures against unauthorised or unlawful use of personal information or its accidental loss, destruction or damage.
Access and correction
You have a right to request access to personal information that we hold about you and request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading.
To protect your privacy and the privacy of others, we may require evidence of your identity before we can give you access to information about you or change it.
If you wish to access or correct your personal information, you should contact us via the Support screen or by contacting us at email@example.com. We do not charge for receiving a request for access to personal information however we may charge you for our reasonable expenses incurred in providing you with access to your information. Charges will include the cost of our staff to compile the records requested, any postage charges and development costs for any bespoke data requests.
In some limited situations, we may need to refuse access to your personal information or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal.
We use technology to collect, store and use anonymous data about how you use our website / mobile technology. For example, when you browse our website our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. We use this information to recognise you as a customer and user of the Independent Reserve’s platform, and to improve the content and functionality of our website, to better understand our clients and markets and to improve our services. This information alone cannot be used to discover your identity.
Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. Cookies allow websites and browsers to operate more efficiently, improve your browsing experience as well as to provide anonymised information to the owners of the site.
We may also utilise cookies to assist in delivering targeted advertising campaigns at certain times through third party sites.
What happens if you want to complain?
We will consider your complaint through our internal complaints resolution process and we will try to respond with a decision within 30 days of you making the complaint. If you are not satisfied with our response, you can contact us to discuss your concerns or lodge a complaint with the Australian Information Commissioner (oaic.gov.au).
If you would like to complain about a breach of the Australian Privacy Principles, you may contact our Privacy Officer at the details below. We will respond to complaints within a reasonable period of time (usually 30 days). If you disagree with our decision, you may refer your complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, calling 1300 363 992 or by emailing firstname.lastname@example.org.
Amendments to the policy