High Conviction Limited is committed to complying with the Privacy Act 1988 (Cth) including the Australian Privacy Principles.
What is personal information?
Under the Privacy Act 1988 (Cth) personal information is defined to mean information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Personal information can include sensitive information. Sensitive information is defined as information or an opinion about a person's race, ethnic origin, political opinions, membership of political associations and trade associations, religious or philosophical beliefs, sexual orientation or practices, criminal record, health information, genetic information about an individual that is not otherwise health information, biometric information that is used for the purpose of automated biometric verification or biometric identification and biometric templates.
Personal information that we collect and hold
High Conviction Limited collects, holds and uses personal information during the course of your dealings with us.
We generally collect your personal information in the following ways when you:
invest in High Conviction Limited;
request information about High Conviction Limited;
telephone, email or write to us;
have a face to face meeting;
attend our presentations to investors, potential investors and financial planners;
attend conferences where we are presenting;
subscribe to receive information from us;
apply for work experience with us;
apply for employment with us;
accept an offer of employment; or
We may collect personal information from other organisations and people (e.g. third party stock brokers, and from our share registry, Registry Direct Limited who provide share registry, investor communication and voting services for High Conviction Limited, or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly.
The types of information that we can collect and hold include:
your contact details including address, email address and telephone number;
your date of birth . financial information, age and employment status; and
sensitive Information, including details of your professional memberships.
Information such as your bank account details and fax tile number (TFN) are collected by the share registry (Registry Direct Limited) and are not disclosed by the share registry to us. Please refer to their privacy policies for further details on how they manage privacy of this information.
We may also collect other personal and sensitive information from you (for example, if you are applying for employment then we may collect your resume, qualifications, skills, education provider and history, work history and residency status). We may also collect any details contained within identity documents provided to us, including but not limited to government identifiers (for example, a passport number, driver’s licence number, Medicare card number, etc.). We do not generally collect (or, if it is provided by you to us, retain) any sensitive information about you.
We use Google Analytics to collect information about the use of our website. Google Analytics collects information about your visit to our website but does not collect your personal information.
Some of the information that Google Analytics collects includes:
server and IP address;
type of browser used;
date and time of visit;
pages accessed and documents downloaded;
the previous website that you visited; and
if you have visited our website before.
Google Analytics is a tool to measure website traffic and usage. You can opt out of the collection of this information using a tool like the Google Analytics Opt-out Browser Add-on.
help the website to function correctly or to improve the usability, content or user experience of the website;
monitor our website's performance;
build up a picture of the websites, products and services you prefer, so that we can then provide you with a personalised experience of our website and provide you with information of interest to you;
place advertisements for our products on other external sites; and
monitor how our marketing is performing.
Most browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies. You may delete or decline cookies by changing your browser settings. (Click “Help” in the toolbar of most browsers for instructions or review the cookie management guide produced by the Interactive Advertising Bureau – www.allaboutcookies.org.) If you do so, some of the features and services of the site may not function properly.
Disclosure of your personal information
High Conviction Limited never sells any personal information.
High Conviction Limited may disclose your personal information to:
our related entities;
organisations providing share registry services under an arrangement with us;
those to who we outsource certain functions, for example information technology support and payroll services;
auditors and insurers;
government and law enforcement agencies and regulators; and
entities established to help identify illegal activities and prevent fraud.
Use of your personal information
High Conviction Limited uses personal and sensitive information that is reasonably necessary for conducting our business or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our uses of personal and sensitive information include but are not limited to:
establishing your identity;
managing your investment and our relationship with you;
provide you with updates in relation to your investment and other investments;
engaging with investors (including calls to investors, emails and ad hoc surveys);
assessing your application for a financial product;
conducting and improving our business, and improving the investor experience;
complying with our legal obligations, and assisting government and law enforcement agencies and/or regulators;
identifying other products and services that we think may be of interest to you;
communication with you about the products and services that we offer; and
in the case of employees, pay your wages and employee entitlements.
We may also need to collect personal and sensitive information in order to comply with our legal obligations, such as the Anti-Money Laundering and Counter-Terrorism Financing laws, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
Marketing and advertising
High Conviction Limited will never use or disclose any sensitive information for marketing or advertising purposes.
We may use and disclose your personal information (other than sensitive information) to provide you with information about our financial products, our general activities and advocacy. You consent to receipt of direct marketing information including by email or SMS.
If at any time you do not wish to receive marketing communications from us or you do not want your personal information disclosed for marketing purposes, please contact our Privacy Officer and we will remove your details from our marketing database.
High Conviction Limited endeavours to ensure that all personal information that it holds is accurate, complete and up-to-date. To assist us with this, individuals should contact us if any of their personal information changes, or if they believe that the personal information we have is not accurate or complete.
When personal information that we collect is no longer required by High Conviction Limited, we will destroy or de-identify that personal information unless we are required by law or a court/tribunal to retain the personal information.
We may retain personal information for so long as it is required for any of our business purposes, for the prevention of fraud, for insurance and governance purposes and in our IT back-up.
We may hold your personal information in electronic formats or in hard copy. Generally, we aim to store your personal information securely to ensure that your personal information is not protected from unauthorised access, modification and disclosure, and from other types of misuse, interference and loss.
While we will take reasonable steps to protect the personal information that we hold from misuse, loss, unauthorised access, modification or disclosure, you should be aware that no system is completely secure against cyber-attack.
In addition, the open nature of the internet is such that information exchanged via the internet may be accessed and used by people other than those for whom the data is intended. Any information sent via the internet is sent at the sender's risk.
You should contact us immediately if you believe that there has been unauthorised access or disclosure with respect to any personal information that we hold about you.
Information about third parties
If you provide us with personal information about a third party, in doing so you will be representing to us that you have that person's consent for us to collect and handle their personal information in accordance with this policy – and we will be collecting the information on that basis.
High Conviction Limited is unlikely to disclose your personal information overseas to persons other than technical service providers, hosting providers, IT companies and manufacturers, however if we do so, it will be in accordance with the Australian Privacy Principles.
You consent to any disclosure of your personal information by High Conviction Limited overseas on the understanding that if the overseas recipient handles the personal information in breach of the Australian Privacy Principles, the entity will not be accountable under the Privacy Act 1988 (Cth), and you will not be able to seek redress under the Privacy Act 1988 (Cth). The overseas recipient may not be subject to privacy obligations or to any principles similar to the Australian Privacy Principles. Individuals may not be able to seek redress in some overseas jurisdictions, and overseas recipients may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.
You consent to High Conviction Limited using and disclosing your de-identified data (data that no longer identifies you) for any purpose, including without limitation research, statistical analysis, product development, marketing and business planning and any other commercial purpose. We undertake technical measures to make sure that this data cannot be associated back to you.
Government related identifiers
High Conviction Limited may collect government-related identifiers for the purposes set out in this policy, but High Conviction Limited does not use any government-related identifiers, such as driver's licence or passport numbers, as its own internal identifier of any individual. High Conviction Limited will not use or disclose any government-related identifiers other than in accordance with the Privacy Act 1988 (Cth).
Access and correction
Individuals can request access to their personal information held by High Conviction Limited by sending a written request to our Company Secretary.
High Conviction Limited does not impose a charge for making a request for access, however we may charge for reasonable administrative costs incurred in providing access.
You can ask our Company Secretary to request or update your personal information. High Conviction Limited does not impose any charge with respect to requests for correction or updates.
Before providing access to personal information, or correcting or updating personal information, High Conviction Limited will require your identity to be confirmed.
Requests for access or correction may be refused upon the grounds contained in the Privacy Act 1988 (Cth). If we refuse to provide access, or to correct or update personal information, High Conviction Limited will provide you with reasons for the refusal. If we refuse to correct your personal information you have the right to associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. We will take such steps as are reasonable in the circumstances to associate that statement with all records we hold that contain the relevant information.
Notifiable data breaches
We will notify you and the Office of the Australian Information Commissioner about any data breach that is likely to result in serious harm to you. There are exceptions where notification is not required, for example where we have already taken appropriate remedial action that removes the risk of serious harm to any individuals.
Privacy related complaints should be directed to our Company Secretary in writing at the address below.
We will do our best to ensure that our investigation is completed, and a decision about your complaint is communicated to you, within 30 days of our being advised of the complaint. We will inform you if we need more time.
If you are dissatisfied with High Conviction Limited's response, you can take your complaint to the Office of the Australian Information Commissioner. For more information see https://www.oaic.gov.au/privacy/privacy-complaints/.
High Conviction Limited's Company Secretary
High Conviction Limited's Company Secretary's contact details are:
Address: Suite 803, 25 Bligh Street, Sydney NSW 2000
This policy may be amended from time to time. We will publish any updated versions of this policy on our website at [▪]. By continuing to use our website, order any product or use any High Conviction Limited service, you will be deemed to have consented to any amended versions of this policy that are published on our website.
Last updated 20 July 2022