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Privacy Policy

Jen Holdings Pty Ltd ACN 618 551 607 trading as Insyde Investment ABN 40 618 551 607, its subsidiaries, related brands and affiliates in Australia (together as “Insyde”, “we” or “us”) are committed to protecting and managing personal information in accordance with the Australian Privacy Principles (APPs) established under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.

This document is referred to as our Privacy Policy, and it sets out our policies for managing your personal information, including how we collect, use, hold, store and disclose your information.

In this Privacy Policy, “you” refers to any individual about whom we collect information from or about.

Broadly speaking, when we are referring to personal information, we are referring to information or an opinion about you, or information that is reasonably recognisable as you. It includes information or an opinion that may or may not be accurate or recorded in a hardcopy or electronic form.

This Privacy Policy applies to your personal information regardless of how we collect it from you or how we received it from third parties. When you interact with us or submit information to us, access or use our websites, mobile applications or social media platforms, or connect your account to third-party services, then you acknowledge and agree to us collecting and handling your personal information in accordance with this Privacy Policy.

About Insyde

Insyde is a new social platform enabling peer networking and connectivity for users to remain informed and empowered with up-to-date financial market information. Insyde offers its products and services through its website (“Website”), mobile applications downloadable through third-party platform providers (“App”) and related social media channels. Insyde also conducts research and development initiatives and provides access to other service providers and applications.

Insyde is not designed to provide personal financial or investment advice, nor is it designed to be a share trading platform. The information provided or displayed on our Website, App or related social media channels does not take into account a user’s particular investment objectives, financial situation or investment needs. Please refer to our disclaimer for further information, which is accessible at https://www.insyde.io/disclaimer.

This policy is effective as of 3 March 2021. From time to time, we may need to change it, and will post the updated version on our Website at https://www.insyde.io/privacy-policy. Please check this Privacy Policy regularly for any updates.

What information we collect

The types of information that we collect, and how we use or disclose it, will vary depending on the circumstances of collection and the nature of our relationship or dealings with you. We will gather, acquire or obtain information about you or your organisation if we receive the information from you directly or from another source.

When you interact with us, a record is made which includes your personal information. The types of information that we may collect include:

  • Contact Information & Personal Data: your name, date of birth, sex, contact details (address, email address, telephone details) and occupation.
  • Payment Details: your payment details to process billing or facilitate purchases.
  • Financial Information: your financial details in relation to your investment portfolio and share trading history and preferences.
  • Social Media Accounts & Handles: your social media accounts, handles, and other personal websites, profiles and account information.
  • Peers & Friends: your friends, family and other people or groups that you are associated or connected with.
  • Photographs & Videos: any pictures, videos, sound recordings and other audio-visual recordings that you provide to us or authorise us to take of you.
  • Employer & Profession: your professional details and information about your employer or an organisation who you represent.
  • Location-based Information: your current or last known location which is used in the determination of your locality through various methods, including collecting your Wi-fi, Guidance Positioning System (GPS), Cellular or other technology in your electronic device or web browser.
  • Cookies & Other Browser or Device Information: your session cookies and persistent cookies when you visit our Website, your device type, browser type, Internet Protocol (IP) address, your URL information, the date and time (including time zone) of your visit, the pages you have accessed on our Website and third-party websites, your software and hardware information concerning your mobile device or computer. Please note that cookies that we place may be removed by following instructions that are provided by your browser.
  • Interaction & Behavioural Information: your interactions, use, habits, preferences, behaviours when dealing with us, our Website and other applications.
  • Employment Information: we collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you. We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions which involve working with children).
  • Other Information: any other administrative and additional information that you provide to us directly, we obtain from third parties, or that is provided by the business that employs or engages to facilitate the provision of our products and services or as a part of your interaction with Insyde.

Insyde generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in-person. We may also collect personal information about you from other sources, for example:

  • an authorised or responsible person acting on your behalf;
  • our affiliated and related entities and brands;
  • third-party agents, suppliers and contractors who assist us to operate our business;
  • recruitment service providers and any referees provided on employment applications;
  • third-party service providers that assist us to provide you with our relevant product and services or who you use to download and access our Website or App; or
  • your family and friends through any marketing or promotional activity that we conduct.

Insyde may collect personal information about other individuals who are not users of Insyde. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to Insyde, and other individuals who interact with us on a commercial basis. If you are participating in an event we are managing or delivering, we may take video records, images or other audio-visual recordings which identify you.

We may collect personal information about children and minors (for example, when children participate in events we are involved with). Where those children and minors do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians (known as a responsible persons) to make decisions on their behalf. However, we are unable to distinguish the age or identity of the people accessing and using our Website, App, social media platforms, or who attend events or activities run by us. This may result in the accidental collection of personal information from children and minors without the consent of a parent or guardian. If this does occur, then we recommend that you contact us and ask for the personal information to be de-identified or destroyed.

We understand that you might not want to give us certain information. We can accommodate this, although it might mean that we cannot provide you with the products or services you need, or the level of service or functionality on which we pride ourselves. If you have any concerns about the types of personal information that we collect, please let us know.

How and why we collect and use your personal information

We collect personal information from you in many ways and for different purposes. For example, we may collect your personal information through our Website or App, through third-party service providers, when you contact us or visit one of our social media sites (such as Facebook, Twitter or Instagram).

We only collect personal information that is necessary for, or related to, conducting our business, offering our Website and App services to users, assessing and managing our customers and business needs or for one or more of our functions or activities. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing customer relationships.

We may receive information about you that we have taken no active step to collect. If this occurs, then we may keep records of this information or choose to destroy or de-identify the information.

The purposes for which Insyde collects personal information, and how we use or disclose it, will vary depending on the circumstances of collection and the nature of our relationship or dealings with you.

The reasons or purpose for why we collect personal information from you may include:

  • to enable communication with you and to respond to requests, general enquiries and complaints;
  • for administrative, management and operational purposes;
  • to inform you about our business or partner offerings, news, activities, updates and promotions.
  • for direct marketing of promotions and other advertising material and event invitations;
  • managing, planning, advertising and administering programs, events, competitions and performances;
  • for research, development and expansion of our product and services or facilities;
  • for specific data and market research purposes and to otherwise develop and innovate the experience and delivery of products and services;
  • for recruitment processes (including for volunteers, internships and work experience);
  • for testimonial, marketing or other promotional purposes that includes photographs, videos or other audio-visual recordings of you;
  • to enable access and use of our App and other software or platforms, including all widgets, functions and other features;
  • processing your purchases, orders, transactions or sales, including the processing of payments, and providing you with invoices, receipts or order confirmations;
  • for any other purpose that you would reasonably expect us to use or disclose your information and if that purpose is directly related to the primary purpose of collection; and
  • to enable us to comply with our obligations under the law or where the use and disclosure is required or authorised under an Australia law or court/tribunal order.

How we disclose your personal information

During the conduct of our business, we may use and disclose your personal information in a variety of circumstances, including to the following parties:

  • our affiliated and related entities;
  • our engaged contractors, agents or suppliers who assist us to operate our business;
  • commercial partners under an agreed information sharing arrangement;
  • third party service providers that assist us to provide you with our relevant product and services or who you use to download and access our Website or App;
  • payment and debit service providers and processors;
  • our data and marketing research service providers, partners and digital marketing agents;
  • third-party website service providers and website plugin or widget service providers;
  • our professional advisors, such as our lawyers, accountants and financial advisors;
  • relevant courts, tribunals, government and regulatory authorities or other law enforcement bodies;
  • investors, buyers or prospective buyers of Insyde’s assets or business;
  • anyone else to whom you authorise us to disclose your information or that would be reasonably expected; and
  • other companies or individuals as necessary to enable us to provide you with our products and services.

These parties are only required to use the personal information that we disclose to them for the purpose that it was provided to them. You should review the relevant third party terms and conditions and privacy policies before using a third party service or product. We are not responsible for these services and products.

Insyde may also use Google Analytics to help us understand how our customers and clients use our platforms, products and services. You can read more about how Google uses your Personal Information via https://www.google.com/intl/en/policies/privacy/. You may also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. Google may update their URLs from time to time.

How we disclose personal information to third parties and overseas recipients

Where we share your information with a third party service provider, we take reasonable steps to ensure that they have first agreed to protect your information and comply with the APPs. In some cases, as is standard practice for cloud services, we may share your information with our trusted service providers located in various countries such as Australia, New Zealand, countries within the European Union, United Kingdom, Canada and the United States of America. Where we do this, we require these parties to take appropriate measures to protect that information in accordance with Australian standards and to restrict how they can use it.

Accordingly, there may be mechanisms available to you to enforce protection of your personal information under overseas law in specific jurisdictions. To the extent permitted by law, we will not be liable for a breach of the APPs if your personal information is mishandled by these third parties. We also disclaim responsibility to the fullest extent permitted by law and note that should a loss of data or information take place then you may not have a remedy under Australian law.

Direct marketing

Insyde may use or disclose your personal information to inform you about our services, upcoming promotions and events, or other opportunities that may interest you on an ongoing basis. This marketing may be carried out in a variety of ways (including by direct marketing by mail, telephone or electronic message or by customising online content and display advertising on our Website or App) and may continue for a period of time after you cease acquiring or using any products or services from us.

If you do not want to receive this type of direct marketing, you can opt-out at any time by following the steps in the marketing communication, or by contacting us using the contact details below.

If you opt-out of receiving marketing material from us, then we may still contact you concerning our ongoing relationship or dealings with you.

How we hold and store your personal information

Insyde takes reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. For example, we may maintain computer and network security, use firewalls and other security methods and other security systems such as user identifiers and passwords to control access to our computer systems.

Please be aware that there is no method of transmission of information over the internet or through electronic storage that is fully secure and safe. We cannot guarantee the security of your personal information that we hold, but we do take reasonable steps to protect your information. If we are required by law to inform you of any misuse, interference, loss or unauthorised use of your personal information, then we will notify you electronically, in writing or by telephone.

Our Website, App, other applications or email systems may not use encryption or other technologies to ensure the secure transmission and receipt of information via the internet. Anyone using our Website, our App, or receiving an email from us is encouraged to exercise care in sending personal information or depositing money via the internet. We recommend that you refrain from clicking any unsecure links, accessing third-party websites or applications, or downloading or opening unknown attachments or files.

If you hold any concerns or become suspicious of any misuse, interference, loss or unauthorised access to our Website, our email systems or to our business more generally, we ask that you contact us immediately to verify your concern or suspicion.

Insyde may hold and store your personal information in paper-based files, other electronic record keeping methods in secure databases (including third party storage providers based in Australia and overseas), which may include cloud-based storage providers.

Paper-based Storage

Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

Electronic Storage

Your personal information is generally collected in electronic form for use or storage with the third-party storage provider that we engage.

Third-Party Storage

Your personal information is generally collected in electronic form for use or storage with the third-party storage provider that we engage.

We cannot ensure that your personal information is or will remain secure. This is due to us not having control over the third-party provider’s policies and procedures concerning the handling and storage of your personal information. We take reasonable steps to ensure that the third-parties we engage take reasonable steps to protect your personal information in accordance with the APPs and a similar manner with this Privacy Policy.

What are the choices that you can make about your personal information?

At any time, you can request us to:

  • delete or destroy your personal information; or
  • de-identify your personal information; or
  • access or correct your personal information; or
  • provide you with a copy of your personal information.

Please understand that we may not be able to entertain your request if it is unlawful to do so or is otherwise impractical or unreasonable to do so in our discretion.

Delete or destroy your personal information

Until you request for it to be deleted or destroyed, your personal information is kept by us for as long as necessary to provide our products and services to you and for legitimate and essential business purposes, such as complying with our legal obligations or settling disputes. This means that your personal information can be held for some time. Please note that we do take steps to destroy or de-identify information that we no longer require or are no longer required to retain by law, regulation or policies.

Remaining Anonymous & De-Identification

Insyde may require you to provide specific details and information to enable us to provide our products and services to you. We try to provide everyone with the opportunity of staying anonymous or using a pseudonym in their dealings with us where it is lawful and practicable to do so. An example of this would be when making a general and nonspecific enquiry. Typically, it is not possible for us to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect your personal information, you may not be able to utilise our products and services, deal with us or participate in our events, programs or activities we manage or deliver.

Accessing or correcting your personal information

You are entitled to access or request a copy of your personal information held by us by sending us a request. You will not be charged for making a request to access or copy your personal information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

You are responsible for ensuring that your personal information with us is accurate and updated regularly. We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. You can help us to do this by letting us know if you notice errors, inaccuracies or discrepancies in the information we hold about you and letting us know if your details change.

On occasions, we may decline your request to access or correct your personal information in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

Does the European Union General Data Protection Regulation apply to us?

The European Union (the EU) General Data Protection Regulation (commonly referred to as GDPR) contains new data protection requirements and is effective as of 25 May 2018. GDPR replaces national privacy and security laws that previously existed within the EU with a single, comprehensive EU-wide law that governs the use, sharing, transferring and processing of any personal data that originates from the EU. The GDPR applies to the data processing activities of businesses, regardless of size, that are data processors or controllers with an establishment in the EU.

Consequently, Australian businesses of any shape and size may need to comply if they have an establishment in the EU, if they offer goods and services in the EU, or if they monitor the behaviour of individuals in the EU. There are also some notable differences, including certain rights of individuals (such as the ‘right to be forgotten’) which do not have an equivalent right under the APPs and the Privacy Act.

In some circumstances, the GDPR provides additional protection to individuals located in Europe. Where this is the case, there may be additional rights and remedies available to you under the GDPR if your personal information is handled in a manner inconsistent with that law.

What should you do if you have a complaint about the handling of your personal information?

You may contact us at any time if you have any questions or concerns about this Privacy Policy or about how your personal information has been handled. You may make a complaint to the Privacy Officer using the contact details set out below.

Complaint handling process

Our Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will contact you within a reasonable timeframe of the date we receive the written details of your complaint to acknowledge that we have received it. We may ask you to provide further information about your complaint and the outcome you are seeking.

Our Privacy Officer will review the way we dealt with your personal information, conduct an internal investigation (if necessary) into the complaint and will likely respond to you within a reasonable timeframe acknowledging receipt of your complaint. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will use reasonable endeavours to investigate and respond to a complaint within thirty (30) days of receipt of the complaint. If the matter is more complex or our investigation takes longer than anticipated, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Insyde may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website https://www.oaic.gov.au.

How changes are made to this Privacy Policy

We reserve the right to change this Privacy Policy at any time. If a change or update occurs to our Privacy Policy, we will notify you by posting the updated version on our Website, displaying a notice on our App or providing notice to you by email. We recommend that you regularly visit our website to keep up to date with any changes or updates. If there are any material changes to our Privacy Policy or the purpose for which your information was collected, then we will take reasonable steps to notify you by email to your last known email address, by posting or displaying a notice on our Website or on our App, and where necessary seek your consent.

Our contact information

We welcome any comments or questions about our Privacy Policy. All enquiries should be directed to Insyde’s Privacy Officer at the following contact details:

Attention:

Privacy Officer

Email:

contact@insyde.com.au

This Privacy Policy was last updated on 3 March 2021.