Waitlist Privacy Policy

This privacy policy (‘the Privacy Policy’) explains how Stockpay Pty Ltd ACN 66 646 770 952 and its affiliates and related companies (together, ‘Stockpay’, ‘we’, ‘us’ or ‘our’) collect, manage, use and share Personal Information, including Personal Information collected on our websites, mobile applications, via email, cloud-based services, or controlled widgets embedded in communication platforms (“Websites”). By “Personal Information” we mean information that is associated with a specific person and can be used to reasonably identify that person. Personal information does not include information that has been made anonymous and cannot reasonably identify a specific person.

We are committed to respecting and protecting the privacy of your Personal Information in accordance with the Australian Privacy Principles (‘APPs’) set out in the Privacy Act 1988 (Cth) (‘Privacy Act’).

The Websites may also contain links to third party websites. These linked sites are not under our control, and we are not responsible for content on these sites, nor are these sites subject to this Privacy Policy. Before disclosing your personal information on any third-party website, we recommend that you examine the terms and conditions and privacy policy of that site.

This Privacy Policy applies when you sign up for, access or use our services, features, technologies, functions or purchase goods and services offered on our Websites (collectively ‘Stockpay Services’) and in relation to Personal Information we may otherwise collect during the course of our business as set out in this Privacy Policy.

Stockpay may amend the Privacy Policy at any time. The updated version will be available by following the ‘Privacy’ link on the Websites. The revised version will be effective from the time we post it on the Websites.

Collecting Personal Information

Stockpay strives to be fair and open about the way we collect information about you and what we intend to do with the information.

We receive and store certain types of information from you when you interact with our Websites to deliver Stockpay Services and to help improve your overall online experience. For example, like many other websites, we store “cookies” and other web-based files on user devices to get certain types of information when your web browser, mobile phone, or other device accesses our Website. The information sent to us may include data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from our site. When you visit our Websites or use Stockpay Services, we may also collect information about your transactions and your activities.

In addition, if you open an Stockpay account with us or use Stockpay Services, we may collect the following types of information:

• Contact information, such as your name, address (including your geolocation), phone number and email.

• Financial information, such as the full bank account numbers and/or credit or debit card numbers and Tax File Number (TFN) that you link to your Stockpay account or give us when you use Stockpay Services.

•Personal Information as required by law to verify your identify (in accordance with the AML/CTF Legislation), to allow us to conduct our business functions and to market our products, including your date of birth, driver’s license number, or other identification information or documents.

We may also obtain information about you from third parties including our Partners and related companies, as well as credit reporting bodies and identity verification services, and publicly or commercially available sources for the purposes of complying with relevant legislation (e.g., anti-money laundering laws).

You may choose to provide us with access to certain Personal Information stored by third parties such as social media sites (e.g., Facebook and Twitter). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your Stockpay account and authorising Stockpay to have access to this information, you agree that Stockpay may collect, store and use this information in accordance with this Privacy Policy.

We may also collect your Personal Information if you enter a competition or promotion we run (either directly or through our marketing agents or our Partners), or if you apply for employment with us either directly or through a recruitment or employment agency.

In order to help protect you from fraud and misuse of your Personal Information, we may collect information about your use and interaction with our Websites or Stockpay Services. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

We may also collect additional information from or about you in other ways, such as through contact with our customer support team, suppliers or service providers and from interactions with Stockpay’s Partners or as otherwise notified to you at the time.

Using Personal Information

Stockpay only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by law, court, or tribunal order.

We may use and disclose your personal information for the primary purpose for which it was collected, or for related purposes, or as permitted or required by law or regulatory reasons including the following purposes:

• Providing you with information about our business and the services that we offer;

• Communicating with you, including to respond to your enquiries, feedback or complaints about our products and services;

• Customising and improving Stockpay Services and the content, layout, and operation of our Websites;

• Delivering targeted marketing, service update notices, and promotional offers based on your communication preferences; and

• Complying with our legal and regulatory obligations.

How we share Personal Information with other parties

We may share your Personal Information with:

• our affiliates and organisations we partner with for the primary purpose(s) for which it was collected;

• our external service providers and professional consultants, including our accountants, auditors and lawyers;

• Federal and state or territory regulatory authorities;

• Companies that we plan to merge with or be acquired by or who may invest in us; and

• Other third parties with your consent or direction to do so.

We may also disclose your personal information if:

• it is required or authorised by law;

• if it is necessary in the interests of public health and safety; or otherwise

• if it is permitted under the Privacy Act.

When we disclose your Personal Information to third parties overseas, we will take all reasonable measures to ensure that your information is held, managed and accessed in accordance with appropriate standards for the handling of Personal Information. Please note that these third parties may be in countries where the laws on processing Personal Information may be less stringent than in your jurisdiction.

Consent

We may require your consent to use and/or disclose your Personal Information if we need to use your information for a purpose that is not related to the purpose for which it was collected.

If you do not consent to Stockpay collecting, using and/or disclosing your Personal Information for such other purposes, this may affect Stockpay’s ability to deliver and improve our products and services, or to engage or do business with you.

When you provide us with your name, date of birth and residential address in establishing your profile with us, you consent to us disclosing that information to credit reporting bodies/agencies and other external agencies, and requesting an assessment of whether it matches personal information held by the body/agency to assist in verifying your identity, including if required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. The body/agency may provide us with that assessment and use your personal information, and the names, residential addresses and dates of birth of other individuals, to prepare that assessment. The assessment will not affect your credit score.

If you do not want to proceed in this way to verify your identity, you should contact us, as provided below.

Marketing and privacy

Stockpay may send marketing materials from time to time to those who have provided Stockpay with Personal Information about products and services offered by Stockpay and our Partners.

If you signed up to receive newsletters or other marketing communications from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message. You can also log-in to your account to opt-out and update your marketing preferences at any time.

Even after you opt-out or update your marketing preferences, please allow us sufficient time to process your marketing preferences. Unless otherwise required to process your requests earlier by law, it may take up to 5 days to process your opt-out requests in relation to receipt of electronic marketing materials such as emails and SMS, and up to 30 days for all other marketing-related requests.

Even after you’ve opt-out of receiving marketing communications from us, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, returns or product-related inquiries, outstanding payment inquiries, surveys or recalls, or any questions regarding a specific order.

You may also contact us on:

Email: [email protected]

Mail: PO Box 303 Pyrmont NSW 2009, Australia

Controlling Our Tracking Tools

Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Websites. If you block or delete cookies, not all of the tracking that we have described in this policy will stop. If you continue without changing your settings, we will assume that you are happy to receive all cookies on this Site. You can change your cookie settings at any time. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.

Cookies and third party analytical services

We use cookies and track IP addresses via our Websites so we can improve our services provided by our Websites and enhance your user experience.

When you access our Websites or use Stockpay Services, we (including our Partners and companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively ‘Cookies’). We use Cookies to ascertain which web pages are visited and how often, to make our Websites more user friendly, to give you a better experience when you return to a website and to target advertising to you that we think you may be interested in.

For example, Cookies allow us to save your password so you do not have to re-enter it every time you visit our site.

Most web browsers automatically accept Cookies. You can find information specific to your browser under the “help” menu. You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our Websites and Stockpay Services.

Protecting Personal Information

Stockpay will keep your Personal Information secure by taking reasonable steps to protect it from misuse, loss, and unauthorised access, use, modification, and disclosure.

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.

We also review our security procedures periodically to consider appropriate new technology and updated methods. Only properly authorised people who have a need to access Personal Information to perform their job will be able to see or use that information. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.

Accessing and requesting correction of Personal Information

We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under privacy law, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your Personal Information or

do not agree to correct your Personal Information we will tell you why.

If you wish to obtain access to and/or correct your Personal Information held by Stockpay, please contact Stockpay on:

Email: [email protected]

Mail: PO Box 303 Pyrmont NSW 2009, Australia

Unless we do not agree to your request for access to Personal Information, in most cases Stockpay will provide you with access as soon as reasonably possible following receipt of your request. If you request corrections to your Personal Information and Stockpay agrees with your request, these changes will be made as soon as practicable. If Stockpay does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you are dissatisfied with our refusal to provide you with access to, or correct, your Personal Information you may also complain to the applicable regulator in your jurisdiction.

Subject to the terms set out in the Stockpay User Agreement, you can also close your Stockpay account through our Websites. If you close your Stockpay account, we may retain information from your account for a period of time to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud or risk, enforce our User Agreement, or take other actions as required or permitted by law.

Resolving your concerns

If you have a complaint regarding Stockpay’s management of your Personal Information, please prepare your complaint in writing and email it to us at [email protected]

Stockpay will provide written acknowledgement of your complaint within 7 days of receipt. We will investigate and advise you of the steps we have taken to resolve your complaint within 30 days of receipt of your complaint.

If you require a copy of this Privacy Policy in a different format, such as a PDF or hard copy, please contact us at [email protected] and Stockpay will use its reasonable efforts to comply with your request.