Privacy

This Privacy Policy sets out how On-Market BookBuilds Pty Ltd (“OnMarket”), uses and protects any information that you give OnMarket when you use this website or mobile application. This policy explains how OnMarket is in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Any information you provide when using this website and mobile application will only be used in accordance with this privacy statement.

The privacy of your personal information is of upmost importance to us. Please note these important aspects of OnMarket.

1. We are committed to ensuring that your privacy is protected.
2. We won't disclose your personal information to anyone without your permission.
3. We use cookies. Most websites do.
4. We may collect anonymous information about how you use OnMarket to help us improve the website and mobile application. Google Analytics (a third party) records this data for us.

OnMarket may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

This policy is effective from 1 February 2019.

What information do we collect?

We collect your personal information directly from you most of the time, however on occasion, we may also collect information about you from other people and organisations.

We collect personal information when you:

• enquire about, apply for, or use our products or services
• contact us to make an enquiry or give us feedback
• visit our website or use our digital services
• participate in other activities we offer, such as competitions or surveys
• talk to us or do business with us.

While we are required to collect some types of personal information to meet our legal obligations, we do attempt to keep our collection of your personal information to what is necessary to offer you the products and services you require.

When you apply for financial products issued by a company or entity, Chapter 2C of the Corporations Act 2001 (Cth) requires information about you as a potential shareholder or unitholder to be collected.  This includes your name, address and details of the financial products that you apply for.  If your application is successful, this information will then be included in the public register of the company or entity in which you bought shares or units. This information is collected to administer your share or unit holding.  If you do not provide all of this information, it may not be possible to complete an application for those financial products.

1. Name.
2. Address.
3. Email Address.
4. Country of residence.
5. Investment account information that you would like the shares or units to be registered under, including, name, address and Holder Identification Number (if applicable).
6. Financial product application information in respect of applications or bids that you make, such as the number of shares or units that you are applying for.
7. Bank account information (for refunding cancelled bids or unsuccessful applications).

Many offers of financial products requires client identification to be verified prior to the shares or units being allocated. We have engaged GB Group plc and its group companies including GBG (Australia) Pty Ltd (branded greenID) as a 3rd party ID verification service. 

greenID allows you to verify your individual name, address, date of birth and document identifier against independent and reliable data sources, online in real time. greenID data security measures are outlined in their privacy policy which can be found on their website:  https://www.gbgplc.com/apac/legal-and-regulatory/privacy-policy-anz/

We do not hold member identification details (such as Medicare or your Driver’s License) on our secure OnMarket server, unless a manual verification is required.

We store transaction information about transactions that you have made using our products and services. 

We may ask you your preferences for the types of offers, businesses or securities that you are most interested in, and whether you are a retail, experienced, sophisticated or professional investor under the Corporations Act. We may ask you socio-demographic information, such as your gender identity, marital status, age, gender, and occupation.  If you provide this information, we store it.

We collect information from you electronically when you use our services. This includes information such as:

• location information (if enabled on your device)
• IP address
• details of the device used to access our digital services, their operating systems, browsers, other applications and settings
• details of the wi-fi network or mobile network used by your device
• type of authentication used (for example touch ID)
• Information about the way you use your devices while accessing our platforms, such as pages you visit on our platforms, click rates, scrolling or swiping activity, mouse movements, or typing speed. We may collect and process this information to generate a 'biometric fingerprint' that relates specifically to you, which we can use to identify unusual behaviour.

How we use the information you provide

We use information we collect about you for the following primary purposes.

1. Assisting you to make applications for financial products.
2. Alerting you of offers available via OnMarket.

When assisting you to make applications for financial products your personal information will be provided to other parties.  These include the company or entity offering the shares or units and their share registry provider. If the entity is listed, it will also include ASX or NSX.

If you register your interest in a particular upcoming offer, we may provide your details to the company or entity making the offer.

We may also use personal information for purposes that are related to the primary purpose of collection.  Such secondary purposes enable us to do the following things.

1. Manage and enhance our products and services.
2. Communicate with you.
3. Provide you with ongoing news and information about our products and services.
4. Do other things necessary and incidental to the provision of products and services by us to you.

OnMarket may provide aggregated anonymous information about bidders and financial product applications made through its service in order to promote its services.  The recipients of aggregated information may include potential issuers and their advisers, share registries, regulators, ASX or NSX and other persons involved in the business of capital raising.

If you become a member of this website or mobile application through a referral by another member, that other member will receive aggregated data about the total stamping fees payable in respect of shares that have been allocated to members that they have referred.

This information is required to be provided in order to administer aspects of reward program that we offer. 

We use your information to improve the products and services we provide through activities such as:

• reviewing customer feedback and assessing how you use our products and services
• testing and validating the effectiveness of products, services and system enhancements
• monitoring and reviewing call recordings, online chats and other business activity for quality assurance, training and compliance purposes.

We use your information to:

• prevent, detect and investigate suspicious or fraudulent activities
• monitor our properties, for example using camera surveillance to ensure the safety of our people and customers
• investigate health and safety incidents involving our people and customers
• support the management of our information security and network controls to prevent cyber-attacks, unauthorised access and other criminal or malicious activities.

Where required, we use your personal information to comply with the law, including our regulatory obligations, including to:

• confirm your identity
• share relevant information with law enforcement agencies, tax authorities and other regulatory bodies
• screen applications and monitor accounts to identify criminal activity such as fraud, terrorist financing, bribery, corruption and money laundering
• investigate financial crime.

We use your information to run our business in an efficient and proper way. This includes managing our financial position, business capability and planning, testing systems and processes, as well as managing communications, corporate governance, and audit.

Who do we share your data with?

We may share your information with our service partners, external service providers and other organisations that help us to supply products and services. These include information technology and cloud service providers and the email marketing platform program that we may use from time to time, such as Campaign Monitor and Google Ads SDKs. We may collect and share your information with other banks, third party payment providers, superannuation funds and financial services providers to provide you services, for example to process your transactions, facilitate payment reversals and provide refunds. We confirm that any third-party service provider with whom we share user data will provide the same or equal protection of user data as stated in this privacy policy.

We may share your information with regulatory bodies, government agencies and law enforcement bodies to comply with our legislative or regulatory obligations in any of the jurisdictions where we operate.

Protection of data

All information you provide is stored on secure servers. Only authorised employees, agents and contractors (who have agreed to keep information secure and confidential) have access to this information.  However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

All information provided by you on the OnMarket website or mobile application will not be provided to overseas third parties (unless you are applying for shares in a company that is domiciled overseas, in which case it will be disclosed in the offer document).  However, if the particular offer requires the identity of the applicant (you) to be verified, and if you provide verification information from a country other than Australia, it is possible that greenID may transfer personal information to a country which is a member country of the United Nations or a country having observer status at the United Nations.

Therefore, we strongly recommend you check the GBG/greenID Privacy Policy;

https://www.gbgplc.com/apac/legal-and-regulatory/privacy-policy-anz/

Collection of information via web site activity

For statistical purposes we collect information on web site activity.  For example, this includes the number of users who visit our web site, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site.  When users enter our web site from another web site, we collect the address of that web site through the use of ‘cookies’. This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our web site. We may also collect your personal information via your use of our web site. Generally, the information that we collect is what you give us when you complete a form or otherwise make an enquiry or transaction via the web site. To evaluate the effectiveness of our web site advertising, we may use third parties to collect statistical data. No personal data is collected on these occasions.

Cookies

OnMarket uses ‘cookies’ and other measures to monitor traffic patterns and to serve you more efficiently when you visit the site. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Cookies do not contain information by which we can identify you but they identify your computer to our servers. You may set your browser so that you are notified before a cookie is downloaded and this will provide you with the opportunity to accept or reject it on each occasion. The help menu within your Internet browser will explain how to do this.

Links to other websites

Our website and mobile application may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

How you can update and gain access to your personal information

You can update your personal information by logging into your OnMarket account and changing your personal information at any time. If you are unable to update your personal information for any reason, you can contact us and we will do it for you. However, we are unable to update member banking details.  This must be updated by each OnMarket member.  Provided you have met your obligations under our Terms of Use and have successfully answered your security questions, OnMarket will provide you with your data on request. 

There is no fee to ask for your information, but sometimes we might charge a fee to cover the time we spend gathering the information you want. If there’s a fee, we’ll let you know how much it is likely to be, so you can choose if you want to go ahead.

We try to make your information available within 30 days after you ask us for it.

In some cases, we can refuse access or only give you access to certain information. For example, we might not let you see information that involves other people. If we do this, we will write to you explaining our decision.

The right to erasure

You have the right to ask us to delete your personal information if there is no need for us to keep it. You can make the request verbally or in writing. There may be legal or other reasons why we need to keep your personal information and if so we will tell you what these are.

How long we keep your personal information

We will keep your personal information while you are a customer of ours. We aim to keep your personal information for only as long as we need it.

We generally keep your personal information for up to 7 years after you stop being a customer but we may keep your personal information for longer:

• To fulfil legal or regulatory obligations
• For internal research and analytics 
• To respond to a question or complaint

Notification and Email Opt-Out

OnMarket will send you emails, SMS and push notifications covering a variety of topics such as account activation, Offer alerts, allocation notifications, product updates and newsletters.

All communications will clearly describe how you can be removed from the mailing list. Members can also manage notifications by signing into OnMarket>Menu>Member Details.

Please contact privacy@onmarket.com.au if you have any questions about changing your notifications.

For questions about your personal information or any questions of a more general nature about privacy, please contact us on privacy@onmarket.com.au or refer to our FSG which outlines our complaint procedure.

Privacy questions or complaints

OnMarket is committed to providing a high standard of service to clients. If you have a query about our privacy policy or level of service regarding our privacy, we would like to hear from you.

OnMarket has established the following resolution procedures:

Step 1:       Contact Us

Usually problems can be quickly rectified and the sooner you refer an issue to us the better.  This can be done by:

Step 2: Complaints Officer

If you are unhappy with our response, you should write to our Complaints Officer who will work closely with you to address your concern quickly and amicably. We will update you regularly until the matter is resolved.

Step 3: Contact OAIC

If you are not satisfied with the resolution offered by our Complaints Officer, you may lodge a complaint with the Office of the Australian Information Commission (OAIC) in writing.

For more information, please see the OAIC website:

 https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint