Curve Securities Pty Ltd (ACN 143 558 598) (Curve Securities, Curve or our or we) is in the business of providing interest rate based investment solutions and web-based software allowing the user to manage and control their investment portfolio and access various assets, data, deals, rates and/or information as sourced by Curve (exclusively or otherwise) (Services).
This Policy governs how Curve Securities will deal with your Personal Information collected in connection with the Services.
This Policy also applies to Personal Information collected by Curve Securities in connection with its website, social media accounts, software and other technological means (Online Platforms), as well as in connection with any direct communication between you and Curve Securities.
Curve Securities uses third parties located both locally and overseas in addition to its own resources to provide these Services.
- We are committed to protecting the privacy of everyone who uses our Online Platforms and/or our Services, for them to understand what Personal Information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their Personal Information in our possession, and with complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act) and the General Data Protection Regulation (EU) 2016.679 (GDPR)
2. THE INFORMATION WE COLLECT
We may collect Personal Information that allows us to identify who an individual is and share Personal Information.
The type of information we may collect includes:
- Personal Information – We may collect personal details such as an individual’s name, location, date of birth and nationality allowing us to identify who the individual is;
- Contact Information – We collect information such as an individual’s email address, telephone & fax number, third-party user names, residential, business and postal address and other information that allows us to contact the individual;
- Financial Information – We collect financial information such as any bank account or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our Services;
- Statistical Information – We collect behavioral and statistical information about an individual and businesses in connection with the Services and/or the Online Platforms.
- Any other details as required by the signatory and/or onboarding letter provided by Curve Securities to You or details required by Curve Securities in order for it to comply with all applicable anti-money laundering and counter-terrorism funding pieces of legislation and regulations, including the Anti-Money Laundering and Counter-Terrorism Funding Act 2006 (Cth) (as amended)
3. WHY WE COLLECT PERSONAL INFORMATION
- We collect your personal information so that we can carry out the following actions:
- to provide our Services;
- to enable you to use our Online Platforms;
- to communicate with you, including about our Services and offers which might interest you;
- to provide you with information or advice;
- to process payments by or to you in connection with our Services;
- to create accounts, tax invoices or receipts;
- to provide your personal information to third parties in order for them to supply the Services to you;
- to consider and respond to complaints made by you.
- We may disclose additional purposes for collection of your personal information in collection statements at the point of collection.
4. HOW INFORMATION IS COLLECTED
Information is collected in association with your use of the Services, an enquiry about Curve Securities or generally dealing with us directly or via our Online Platforms.
5. WHEN PERSONAL INFORMATION IS USED & DISCLOSED
- We will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission
- Subject to clauses 8 and 14, we will not sell an individual’s Personal Information to unrelated third parties
- There are some circumstances in which we must disclose an individual’s information
- where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
- as required by any law (including the Privacy Act and GDPR); and/or
- in order to sell our business (in that we may need to transfer Personal Information to a new owner).
6. SENSITIVE INFORMATION
Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.
It is our policy to only collect your sensitive information where it is reasonably necessary for our functions or activities and either you have consented or we are required or authorised under law to do so.
7. OPTING “IN” OR “OUT”
- An individual may opt to not have us collect their Personal Information (for example by unsubscribing to any marketing emails received). This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us
- If an individual believes that they have received information from us that they opted out of receiving, they should contact us on the contact details set out in clause 15
8. DE-IDENTIFIED INFORMATION
- We may use your Personal Information in de-identified form (de-identification being a process by which a collection of data or information is altered to remove or obscure personal identifiers and personal information) to assist us in running our business. We may also provide, including by way of sale, de-identified information in aggregated form, to third parties. This information may include (but is not limited to):
- Investment statistics
- Trends in investments, investment rates, investment strategies and other characteristics;
- Portfolio performance analysis and comparisons;
- Such other data and/or information that is collected via the Platform and/or Services and is not capable of identifying You.
- Statistics in connection with the Services.
- When your Personal Information is included in de-identified, aggregated data, it is not possible to identify you or anything about you from that data