WAVIA Privacy Policy

 

This Privacy Policy explains how IA Asset Management Pty Ltd (“WAVIA” or “IA”, “us”, “we” or “our.”), uses, collects, stores, and discloses personal information. It also explains how an individual may seek to access or correct their personal information or make a privacy complaint. It should be read in conjunction with the Terms of Service that apply to the use of our website or the WAVIA app (“the WAVIA platform”), joining our email list, registering as a user and/or using the services operated by WAVIA. By accessing and using the WAVIA platform, and/or using our services, you consent to the use, collection, disclosure and storage of your personal information in accordance with this Privacy Policy. If you choose not to provide the personal information when we ask for it, you may not be able to fully utilise the WAVIA platform or our services.

  1. Individuals in the EU

If you are in the European Union (EU) (including the European Economic Area (“EEA”)), the collection and processing of your personal information will be subject to the General Data Protection Regulation (2016/679) (“GDPR”). In providing our services to you, we may collect and process personal information as outlined below. We will be a data controller for the purposes of the GDPR and this policy includes information that must be provided to you when we collect your personal information.

  • What personal information do we collect?
      1. We may, in addition to other information, collect the following personal information about you:
        1. Information you provide to us when you register an account to  use the WAVIA platform and our services and when you maintain your account;
        2. Information you provide to us when you contact us via our website, email, telephone or otherwise.
        3. Your name, email address, residential address, contact telephone numbers, date of birth and password;
        4. Financial information, such as your bank account details;
        5. Specific documents to verify your identity and other personal details;
        6. Details of transactions you carry out through the WAVIA platform; 
        7. Details of your visits to the WAVIA platform; and
        8. Information obtained from third parties in accordance with this Privacy Policy (such as Facebook or Linkedin).
      2. We have statutory responsibilities to collect and disclose certain information to comply with regulatory requirements and contractual obligations. For example, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) we are obliged to run anti-money laundering checks and verify the identity, and source of funds, of, persons who use the WAVIA Platform and services. To comply with those responsibilities, we may use third parties to verify your personal information. If those third parties are not able to verify your identity to our satisfaction, we may request that you send us further identification information. While you hold an account with us, we may also need to run additional identity checks on you. By using the WAVIA Platform, you agree that we may run these identity checks on you, and that you will not be able to use the WAVIA platform or our services unless we are able to complete those checks to our satisfaction.
  • Cookies
      1. We may also collect technical information through the use of cookies and other means whenever you use the WAVIA platform, including information about the way you arrive at, browse through and interact with the WAVIA platform. Cookies are small text files stored on your device, to help operate the WAVIA platform and collect information about online activity. For example, we use cookies to store your preferences and settings, help with sign in, combat fraud and analyse site operations. We may also collect information about your computer, including your IP address, operating system and browser type, for the purposes of system administration. 
      2. If you are an individual in the EU and we use cookies that identify you or monitor your behaviour in an ongoing manner or other identifiers or information, we will inform you and obtain opt-in consent for the use of cookies, and provide you with the option to withdraw your consent to any cookies you have agreed to at any point.
  • How do we use personal information?

We may use personal information for any of the following purposes:

  1. Verifying any information that you give to us, or information that we collect from third parties and any third party databases;
  2. Carrying out credit and identity checks;
  3. Assessing your suitability to register with us and use the WAVIA platform and our services;
  4. Providing our services to you;
  5. Satisfying any obligation arising from any agreement between you and us;
  6. Complying with our legal and regulatory obligations or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;
  7. Storing, accessing and making information available through the WAVIA platform;
  8. Contacting you with information about us, our services and new investment opportunities that we think may be of interest to you;
  9. Monitoring, operating, maintaining and improving the WAVIA platform; and
  10. any other purpose permitted under the Privacy Act 1988 (Cth) or that we notify you of at the time personal information is collected. By using the WAVIA platform, you are agreeing to authorise any third party to provide your personal information to us for any of the above purposes.
  1. If we disclose your personal information to a credit reporting agency, that agency may hold your information on their credit reporting database and use it for providing credit reporting services and for any other lawful purpose and the agency may disclose your information to their subscribers for the purpose of credit checking or debt collection or for any other lawful purpose.
    1. When do we disclose personal information?
      1. We may disclose personal information to our related companies, service providers (including credit reporting agencies) and others working with us to help us provide, improve and promote the WAVIA platform and our services.
      2. We may also disclose any of the personal information we hold:
        1. For the purposes for which the information was collected;
        2. With your express consent;
        3. For any purpose which is permitted under the Privacy Act 1988 (Cth);
        4. In relation to any proposed purchase or acquisition of our business or assets; or
        5. Where required by applicable law or any court, or in response to a request by a law enforcement agency.
      3. We may share non-personal and aggregated information for research or promotional purposes. Except as set out in this Privacy Policy, we do not sell or trade personal information to third parties, or allow such third parties to use that personal information.
  • How do we store personal information?
      1. We store your personal information in our electronic database and in print form. The information that we collect may be transferred to, and stored in Australia and overseas. If any information is stored overseas, it may also be processed by staff operating outside Australia who work for us or for one of our suppliers.
      2. Any third parties to whom we disclose or permit access to your personal information in the course of providing services on our behalf will be subject to strict contractual restrictions to ensure that they protect personal information and keep it confidential, consistent with relevant privacy and data protection laws.
      3. We will keep your personal information for as long as necessary to achieve the purposes for which we collected it, and in all cases for such periods as we are required to in order to comply with any relevant legislation and regulations. Where we no longer need to keep your personal information, we will take reasonable steps to destroy or de-identify your personal information.
  • Protection of data
      1. We will take steps to ensure that your personal information will be afforded the level of protection required of us under and in accordance with this Privacy Policy and applicable data protection laws, and in accordance with current legally recognised data transfer mechanisms.
      2. Please note that the transmission of information via the internet is not completely secure. Although we will take steps to protect your personal data, we cannot guarantee the security of your data transmitted to the WAVIA platform and any transmission is at your own risk. 
  • Access and complaints if you are in the EU
      1. In certain circumstances, you also have the right to request that the personal information collected from you is erased, to request that its further processing is restricted and to object to its further processing. You also have the right to data portability. You can request that personal information provided by you to us is transmitted to another party. You may withdraw your consent where it has been provided as a condition of our processing your information in certain circumstances.
      2. If we refuse any request you make in relation to these rights, we will write to you to explain why and how you can make a complaint about our decision.
      3. To make a request in relation to these rights or to make a complaint, please contact us at: gdpr@wavia.global
      4. You also have the right to lodge a complaint with a relevant data protection supervisory authority (for example in the place you reside or where you believe we breached your rights).
  • Data controller

For the purposes of the GDPR, WAVIA is a data controller for the WAVIA platform and the services provided through the WAVIA platform.

  • Your rights
      1. Except in limited circumstances, you have the right to request access to or correct any of the personal information we hold about you. You also have the right to request us not to pass on your personal information and to make a complaint about any of the personal information we hold about you. However, under various laws and regulatory requirements, we may have to pass on certain information to other organisations. If you would like to exercise any of these rights, please contact us at: gdpr@wavia.global
      2. The WAVIA platform may contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. 
  • Amendments

We may add to, remove or change the provisions of this Privacy Policy from time to time. All additions and changes will be notified to you by being posted on this page. It is your responsibility to refer to these additions and changes. This privacy policy was last updated on 16 April 2020.