LEGAL

Privacy Policy

20th February 2018

This Privacy Policy (“Policy”) was prepared on and dated 20 February 2018, and issued by Clover.com.au Pty Ltd (“Clover”) ABN 83 602 834 597, AFSL No: 479416.

OUR COMMITMENT

At Clover we recognise that your privacy is very important to you. We are committed to providing you with high quality financial services within a secure and confidential environment.

This Policy sets out how we deal with personal information as part of managing your relationship with us, including:

  • what personal information we may collect from you,
  • how your personal information may be used or disclosed,
  • the security of any personal information you provide to us,
  • how you may access and correct or update your personal information, and
  • how you can contact us if you have any concerns.

We are committed to collecting and protecting your personal information in accordance with the Australian Privacy Principles established under the Privacy Act 1988 (Cth) (Privacy Act), including the Privacy Amendment (Notifiable Data Breaches) Act 2017.

By accessing our website and using our service, you consent to the terms of this Policy which forms part of the terms and conditions of opening and operating an account with us. We will update this Policy from time to time and you should regularly check our website for updates at https://www.clover.com.au.

COLLECTION OF YOUR PERSONAL INFORMATION

We may collect personal information from you directly when you:

  • register to use our service,
  • use our service,
  • visit our website, or
  • contact the Clover.com.au support team.

The types of information we collect includes your name, residential and/or postal address, email address, phone number, date of birth, gender, occupation, tax file number, tax residency status, employment status and certain financial information such as assets, liabilities, income and expenses. We may also collect information on your marital status and dependents (if any) and bank account(s).

We collect personal information for the purpose of providing financial services to you. Certain laws require us to obtain and hold personal information about your individual objectives, financial situation and needs. This information will also assist us in our ability to provide you with the appropriate advice and service given your objectives, situation and needs. You can always choose not to provide your personal information to us, but it may mean that we are unable to provide you with an appropriate level of service.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We only collect personal information about you when you give it to us, through our website (https://www.clover.com.au).

SOCIAL MEDIA

We may use social networks to communicate with the public about our services and financial industry updates and thoughts. When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you. Each social network service will also handle your personal information for its own purposes. These services have their own privacy policies. You can access the privacy policies for each service on their respective websites.

ANONYMITY

Given the nature of the financial services that we provide, you will not be able to deal on an anonymous basis with us.

Certain laws require us to establish your identity by collecting and verifying personal information. During the course of your dealings with us, we may request that you provide further information about yourself.

USE OF YOUR PERSONAL DATA

We will use your personal information for the main purpose of providing financial services to you, and in particular to:

  • implement your investment instructions and manage your investment account,
  • process contributions and withdrawals,
  • report on the investment performance of your account,
  • assist you with queries,
  • comply with our legal and regulatory obligations, and
  • take measures to detect and prevent fraud, identity theft or money laundering.

We may also use the information for other purposes where you consent to this.

We may contact you to participate in surveys and to obtain feedback on our services or our website. We may also use your personal information for marketing and internal communication purposes such as sending you research, newsletters and notifying you of promotions, new products and services that we believe may be of interest to you. Any information provided in connection with such activities will be treated in accordance with this Policy, except as specifically contained in the rules for those surveys or promotions. Our electronic communications include an ‘unsubscribe’ link which enables you to opt out of receiving such communications in the future.

DISCLOSURE

We will only disclose personal information to external organisations carrying out functions on behalf of Clover on a confidential basis, including for example:

  • issuers of securities and their agents,
  • registrars of securities,
  • clearing houses,
  • trade execution and clearing agents,
  • our bank and your bank,
  • your cash management account provider,
  • professional advisers, including our auditors and lawyers, our insurers and external complaints handling organisations, and
  • other agents who may assist us in providing services to you (including, for example, email campaign management providers to enable us to send information to you).

We may disclose aggregated personal information in a non-personally identifiable manner to:

  • external organisations who will help us measure the performance of our online campaigns or analyse visitor activity on our website,
  • external organisations engaged to provide services to Clover (such as market research firms),
  • users of our service for purposes of comparison of their personal financial situation relative to the broader community, and
  • communicate or publish our analysis, statistics or research of user data to the public.

Such information does not identify you individually and will remain anonymous.

Disclosure to regulators, external dispute resolutions schemes or as directed by law

You should note that information we collect from you may also be disclosed to third parties if that disclosure is required or authorised by law, including regulators such as the Office of the Australian Information Commissioner (OAIC), Australian Securities & Investments Commission (ASIC), AUSTRAC, the Australian Securities Exchange Ltd (ASX), Chi-X Australia or other market operators, or by reason of a court order.

We may also disclose information that relates to a complaint to the Financial Ombudsman Service (FOS) who operates the external dispute resolution (EDR) scheme Clover utilises.

Will my information be disclosed overseas?

Given that the internet is a global environment, we may occasionally use third-party service providers or outsourcing services based outside of Australia. Any overseas disclosure does not affect our commitment to safeguarding your personal information and we will take reasonable steps to ensure any overseas recipient undertakes to protect your privacy.

Where we may be transferring your personal information overseas, we will take reasonable steps to ensure that the overseas entity protects your personal information in accordance with our obligations under Australian privacy law. The relevant countries will vary depending on the circumstances, and so it is not practicable to list them here. By providing your personal information to Clover, you consent to such disclosure to overseas recipients.

HOW WE SECURE YOUR INFORMATION

We are committed to safeguarding your privacy and protecting your personal information from unauthorised access or disclosure. We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your personal information and your account. While constant changes to technology mean that we cannot guarantee that data transmission will be totally secure or safe from attack by unauthorised intruders, we have a range of security measures, practices and procedures in place to provide a robust security environment. We review and update our security measures in light of current technologies.

You can also play an important role in keeping your personal information secure, by maintaining the confidentiality of passwords and accounts used on our website.

We will retain information for a period of time (generally not more than seven years) after closure of your account, in accordance with our legal and regulatory requirements. Once your information is no longer required for these purposes, we will take all reasonable steps to destroy the information or ensure that it is de-identified. All such information will be held in accordance with this Policy.

HOW YOU CAN ACCESS AND UPDATE YOUR INFORMATION?

Once we hold personal information we will take reasonable steps to keep it accurate, complete and up-to-date. You should let us know when your information becomes out-of-date or requires correction.

You are able to access and update the personal information that we hold about you at any time by emailing privacy@clover.com.au. We will endeavour to address your request promptly but in any event within 14 days of receipt.

IDENTIFIERS

We will not adopt as our own identifiers any you may provide to us such as tax file numbers. Each client account is allocated a unique client account number, which you should keep confidential.

OUR WEBSITE COOKIES

A cookie is a small file placed on your computer which may enable us to identify you or your browser while you are using our site. Cookies contain information about your visit to our website and are used for a variety of purposes, including security and personalisation of services. These cookies may be permanently stored on a computer or alternatively may be temporary session cookies.

You can adjust the settings on your browser to be notified when cookies are being used and to either accept or reject a cookie. If you do not wish to use cookies, this may impact our ability to provide you with an appropriate level of service.

Our website may contain links to other websites and Clover is not responsible for the privacy practices or the content of these websites.

PRIVACY COMPLAINTS

We are committed to providing our clients with a fair and responsible system for handling privacy issues. If you have any concerns with regard to your privacy, please contact our Privacy Officer at privacy@clover.com.au so that we may resolve your concerns.

For more information about privacy issues in Australia and protecting your privacy, visit the Office of the Australian Information Commissioner’s website www.oaic.gov.au or telephone 1300 363 992.

HOW TO CONTACT CLOVER

If you have any questions or feedback about this Policy or you have any privacy issues concerning Clover, please contact the Privacy Officer in writing at privacy@clover.com.au or at PO Box 599, Collins Street, West Melbourne VIC 8007.