Privacy Policy

This is the Privacy Policy of Shares in Value  Pty Ltd ABN 56 643 558 436 (“SIV”, “We”, “Our” or “Us”). The Privacy Policy should be read in conjunction with the SIV Terms and Conditions (the “Terms and Conditions”) and forms part of the Terms and Conditions.  By using the Site or using SIV’s services, you agree to abide by these Terms and Conditions and agree to the  terms of the SIV Privacy Policy.  Your use of the Site or use of SIV’s services will constitute your acceptance of the Terms and Conditions and of the Privacy Policy.

The Privacy Policy explains the information We collect, how We use and protect the information, how to access and update your information, and how to manage your privacy settings when using the SIV services.

In order to provide you with information and other services We may collect and retain “Personal Information” that may identify you or contribute to identifying you. “Personal Information” can include information such as your name, email address, your photo, contact details and, in some cases, general financial information. We will generally not collect your personal information unless We believe that it is necessary to provide the information, advice or service you have requested.

We will generally only collect your personal information from you or from someone you have authorised to provide it to Us.

SIV’s Site may contain links to other websites owned and operated by third parties. These third party websites have their own privacy policies therefore We urge you to review them. Those third party privacy policies will govern the use of personal information you submit when visiting their respective websites.  We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

How is information collected?

We collect information in a number of ways, including:

• Directly from you such as when you provide the information at meetings, by phone, email, in data collection forms and when you visit the Site.
• The Site may use “cookies”. Cookies are small data files that are downloaded from the Site and stored on your computer when you visit the Site. Cookies are used to allow Us to see which pages and what information is of most interest to visitors to the Site, which in turn enables Us to improve Our offerings to Our customers. Your computer’s web browser will allow you to configure your computer to refuse to accept cookies. You can also delete cookies from your computer’s hard drive at any time. However, please note that doing so may hinder your access to valuable areas of information within the Site.

How will SIV use personal information about me?

Our use of your personal information will always have a lawful basis, either because you have consented to Our use of your personal information or because it is reasonably necessary to provide services including, but not limited to:

• answering your general queries;
• confirming your identity;
• communicating with you;
• administering Our services;
• notifying you of the services We offer;
• carrying out marketing, training or promotional activities;
• responding to feedback, comments, or any other contact;
• sending you emails or newsletters to which you have subscribed;
• carrying out competitions;
• enhancing the Site or services;
• helping you to resolve technical issues with the Site;
• helping you to identify products and product providers appropriate for your needs and circumstances; or
• referring you to product providers;

By using Our services, you consent to us collecting, holding and using your personal information in this way.

We may also access, hold and use aggregated information about the people that use Our services.  Aggregated information will not identify you or any other individual but simply provides Us with non-personally identifiable data that We can use to improve Our services, understand Our users’ needs and develop tailored content.

As noted above, We may use your personal information to offer you products and services that we believe may interest you. We may also disclose your personal information to external associates and Our service providers who assist Us to market Our products and services.

If you do not want to receive marketing offers from Us please inform Us.  Our contact details are included at the end of this policy.

Are you obliged to provide Us personal information?

You are not required to provide Us the information that We request, or to allow Us to collect information from third parties.  However, where you choose not to provide Us with the information We request, We may not be able to provide you with services that you have requested from us.

What happens if We obtain information about you which We have not solicited?

Where We receive unsolicited personal information about you, We will consider if We could have collected the information if We had solicited the information.  Where We determine that We could have collected the personal information from you, We will treat your personal information in the same manner as if We had solicited the information directly from you.  Where We determine that We could not have collected the personal information, We will destroy the information or ensure that the information is de-identified as soon as practicable.

Disclosure of information

We may disclose your information to Our representatives and Our external service providers in order to provide you with the services you have requested.

Government related identifiers

If We are required to collect government identifiers such as your tax file number, Medicare number or pension card number, We will not use or disclose this information other than when required, authorised by law or unless you have voluntarily consented to disclose this information to any third party.

Cross-border disclosure of information

We may transfer information to related bodies corporate or external service providers in locations outside Australia, including, but not limited to Germany, Canada, Philippines and India, in the course of storing that information and when using or disclosing it for one of the purposes referred to above.  When transferring information to foreign jurisdictions, We will ensure that We satisfy one of the requirements below:

• we will take reasonable steps to ensure the overseas recipient does not breach the Australian Privacy Principles in relation to the information;
• we form a reasonable belief that the overseas recipient is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the Australian Privacy Principles protect the information and there are mechanisms that the individual can access to take action to enforce that protection of the law or binding scheme; or
• we will seek your informed consent prior to disclosing your information overseas.

Storage and security of information

We store personal information in Our computer database and hard copy files.  We take reasonable steps to ensure the personal information collected and held by Us is protected from misuse, interference, loss, unauthorised access, modification or disclosure.

Any personal information which We hold about you will be maintained for a period of not less than 7 years in order to comply with legislative and professional requirements.

Notifiable data breaches

We are required to notify you and the Information Commissioner of an eligible data breach.  An eligible data breach happens if:

• there is unauthorised access to, unauthorised disclosure of, or loss of personal information held by us; and
• the access, disclosure or loss is likely to result in serious harm to you.

If you receive a statement of an eligible data breach from us, you should read and implement the recommendations about the steps you should take in response to the eligible data breach.

Access and correction of information

You may request access to the personal information We hold about you, and We will respond within a reasonable period after the request is made.  Where We provide you access to such information, We may charge a reasonable fee to cover Our costs.  We will disclose the amount of such costs to you prior to providing you with the information.

We will take reasonable steps to ensure that the personal information that We collect, use or disclose is accurate, up-to-date, complete and relevant.  In the event that you become aware, or believe, that any personal information which We hold about you is inaccurate or incomplete, you may contact Us to correct the information.

If We disagree about the correction you have supplied, and refuse to correct the personal information, or if We believe that We are unable to comply with your request to access the personal information that you have provided Us, We will give you a written notice to that effect.  You have a right to make a complaint if you disagree with Our decisions in relation to these matters (see below).

Complaints

If you believe that We have breached the Australian Privacy Principles, or disagree with a decision that We have made in relation to Our Privacy Policy, you may lodge a complaint with Us.  To enable Us to understand and deal with your complaint in a timely fashion you should set out a brief description of your privacy problem, the reason for your complaint and what action or remedy you are seeking from Us.  Please address your complaint to Our Privacy Officer.  Contact details are included at the end of this policy.

Your complaint will be investigated and responded to within 30 days.  If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner.

Policy updates

This policy is subject to change from time to time.  The most current version of Our Privacy Policy can be obtained from the Site or by contacting us.

Contact details

Privacy Officer:   Compliance Manager

Address:              Level 34, 259 George Street, Sydney NSW 2000

Telephone:          (02) 9067 6599