Privacy Policy
1. Overview
Veye Pty Ltd ACN 623 120 865 (Veye, we, our or us) is committed to the protection of the privacy of the people we deal with, and we seek to uphold high standards of privacy practice and security. This policy outlines how we collect, hold, use and disclose your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles.
Whenever we handle personal information, we seek to ensure that appropriate standards of privacy practice and security are applied.
This policy sets out why we need to collect personal information, how we collect it, what we do with it, how it is stored and who we might share it with. The policy also describes how you can access or correct information we hold about you, how you can ask further questions or make a complaint. We will update this privacy policy when our information handling practices change. Updates will be published on our website.
2. Collection of Personal Information
For most products and services, it is necessary for us to collect ‘personal information’ such as your name, contact details, transaction information and other personal details where needed. This may include information required to verify your identity, records of communications with you and information relating to your use of our website or services. Where lawful and practicable, individuals may deal with Veye anonymously. However, in many circumstances this will not be practicable because Veye may be required to verify identity or collect personal information in order to provide financial services or comply with legal obligations.
3. Sensitive Information
Generally, we do not collect sensitive information about you unless required by law or where you consent for us to do so (only where it is relevant to your product). Sensitive information includes information relating to race, political or religious beliefs, sexual preferences, criminal history and association memberships. We may collect information about your affiliation with certain organisations, such as professional associations.
4. Purpose for collecting personal information
We collect personal information about you which is reasonably necessary to:
a). provide you with quality products or services;
b). conduct marketing;
c). fulfil our legal obligations, such as those relating to taxation and anti-money laundering and counter-terrorism financing
or as otherwise authorised by you. Without such information, we may not be able to provide you with products or services, verify your identity, comply with legal obligations or otherwise provide you with an appropriate level of service.
5. Procedure for collecting personal information
We may also collect your personal information from third parties including public sources, your product issuers, our related companies and service providers (including credit reporting bodies and information service providers).
Some information requested by us may be mandatory in order for us to verify your identity, provide services to you or comply with legal obligations. If you do not provide requested information, we may not be able to provide services to you or otherwise deal with you effectively.
6. Storage of personal information
We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include storage on the cloud. Where this occurs, we take steps to protect personal information against misuse or loss.
We also keep records of our interactions with you (including by telephone, email and online), your transaction history and your enquiries or complaints. Telephone calls with us may be monitored or recorded for training, verification, compliance and record-keeping purposes.
We retain personal information for as long as reasonably necessary to fulfil the purposes for which it was collected and to comply with applicable legal and regulatory obligations.
Generally, we will retain your personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including to provide our services and comply with our legal, regulatory and record-keeping obligations. In most cases, we may retain your personal information for up to seven (7) years after you cease using our services, unless a longer retention period is required.
Once your personal information is no longer required for these purposes, we will take reasonable steps to securely destroy or de-identify the information.
You may request access to, correction of, or deletion of your personal information at any time by contacting us using the contact details set out in this policy. Please note that, in some circumstances, we may be required or permitted by law to retain certain personal information despite a request for deletion.
7. Use of Personal Information
We use personal information about you for the purpose for which it was provided to us, including to:
a) administer and manage our services (including monitoring, auditing, and evaluating those services); and
b) communicate with you and deal with or investigate any complaints or enquiries.
We may also use your personal information for related purposes which would reasonably be expected without your permission. For example, we may from time to time use your personal information to provide information about products and services which we expect may be of interest to you. However, if you do not want to receive such communications you can tell us by using any of the methods listed below or by using the ‘unsubscribe’ link included in the communication.
While we may sometimes share personal information with companies we do business with (e.g., research service providers), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.
8. Disclosure of Personal Information
8.1 Disclosure of Information outside Veye
Veye’s research services are outsourced to Veye Research Private Limited (Veye Research), a related body corporate services company, which is located in India; and we may share personal information with Veye Research for the purpose of issuing investment research reports.
We may also disclose personal information outside Veye:
a) as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator;
b) as contained in the terms and conditions of our service.
c) to our service providers, who provide services in connection with our financial services business (including auditing, accounting, legal, mailing, marketing, insurance, identity verification, website and technology services);
8.2 Disclosure of Information to other countries
In some circumstances the parties to whom we disclose personal information may operate outside of Australia, e.g., Veye Research. We may also use third party service providers, including technology and cloud storage providers, which may store or process personal information outside Australia. It is not practicable to specify every country in which overseas recipients may be located from time to time.
Where personal information is disclosed overseas, we take reasonable steps to protect personal information against misuse, interference and loss, and unauthorized access, modification or disclosure.
9. Keeping information accurate and up to date
We take reasonable steps to ensure that all information we hold is as accurate as is possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.
10. Keeping information secure
We use security procedures and technology to protect the information we hold. Access to and use of personal information within Veye seeks to prevent misuse or unlawful disclosure of the information – this includes internal policies, training and monitoring of staff.
If other organisations provide support services, we require them to appropriately safeguard the privacy of the information provided to them.
Where the personal information we collect is no longer required, we delete the information or permanently de-identify it in accordance with relevant laws.
We maintain physical, electronic and procedural safeguards to protect personal information. These safeguards include staff training, confidentiality requirements, access controls and secure system protections designed to safeguard the personal information we hold.
If we experience a data breach that is likely to result in serious harm, we will comply with our obligations under applicable privacy laws, including notifying affected individuals and the Office of the Australian Information Commissioner where required.
11. Accessing or correcting personal information
You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
Requests for access to or correction of personal information should be made using the contact details below. We will respond to requests within a reasonable period. We do not generally charge a fee for access requests, although we may charge a reasonable administrative fee in certain circumstances.
12. Dealing with Veye Online
When you visit the Veye website you will browse anonymously unless you have logged into a client portal or accessed the website from a personalised communication from Veye.
For all visitors to our website, we use cookies and similar technologies to collect anonymous information such as the server your computer is logged on to, your browser type (for example, Internet Explorer or Chrome, and your IP address (An IP address is a number that is assigned to your computer automatically and required for using the Internet). We may also derive the location associated with an IP address.
Once you have logged into a Veye portal, accessed our website from an e-mail or other personalised communication sent to you, or provided us with personal information by completing a form online, we may be able to identify you and we may combine that with other information in order to provide you with a better online experience. If you would prefer not to be identified, you can delete the cookies and reconfigure the cookie preferences on your internet browser (see below).
13. Cookies
A 'cookie' is a packet of information placed on a user's computer by a website for recordkeeping purposes. While cookies are not considered personal information, they are generally used on Veye’s website to:
a) access online services – if you log into our secure areas on our website we will use cookies to authorise your access and save your preferences;
b) manage advertising – when you see one of our ads on a third‑party website, cookies are sometimes used to collect anonymous information about the page you visit and the type of software you are using;
c) monitor traffic – we use anonymous information to track how people are using the Veye site. This may include time of visit, pages visited and some system information about the type of computer you are using; and
d) monitor your use of our website – if we have identified you as a result of you logging into a Veye client portal, accessing our website from a personalised communication or providing us with personal information by completing a form online, we may use cookies to collect personal information about you.
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the Help menu of your browser to learn how to change your cookie preferences).
If you disable the use of cookies on your web browser or remove or reject specific cookies from the Veye website or linked sites, then you may not be able to gain access to all of the content and facilities on those websites.
14. Contact Us
If you have any questions or complaints regarding privacy or information handling, please write to [email protected] or contact us by telephone on (02) 9052 4957. Please mark communications to the attention of our Privacy Officer. We will acknowledge receipt of your complaint and let you know who will be handling your matter and when you can expect a further response. We will investigate your complaint and respond within a reasonable timeframe.
If your concerns are not resolved to your satisfaction, you may be able to lodge your complaint with the Office of the Australian Information Commissioner (details below)
Office of the Australian Information Commissioner (OAIC)
Telephone: 1300 363 992
Website: www.oaic.gov.au