Privacy Policy

Privacy Policy

Microequities Asset Management Group Limited and its related bodies corporate (“we”, “our” or “us”) are committed to protecting your privacy and respecting your rights in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (APPs). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit or make an enquiry from our website (the “Site”), investor portal, or otherwise interact with us.

You can read more about the APPs on the Office of the Australian Information Commissioner (OAIC) website at: www.oaic.gov.au.

What is your personal information?

“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not. This includes information such as your name, contact details, identification information, and digital identifiers such as your IP address if they can be used to identify you.

What personal information do we collect and hold?

We may collect the following types of personal information:

• Identification and contact details: name, postal/street address, email address, telephone number, date of birth.
• Financial and regulatory information: bank account details, investment details, tax file number, and information about your financial position where required for our services.
• Information collected automatically: IP address, browser type, device information, time zone, and browsing activity on our Site (including through cookies, web beacons, tags, and pixels).
• Any other information you provide to us directly, such as through forms, surveys, calls, or meetings.
• Sensitive information (such as health, political or religious beliefs) only where required by law or with your explicit consent.
• Identification verification information: document details such as driver licence, passport, or Medicare card information provided for identity verification purposes using the Document Verification Service (DVS).

How do we collect your personal information?

We collect information:

• Directly from you (via forms, calls, meetings, or emails).
• Automatically when you use our Site or investor portal.
• From third parties (e.g., financial advisers) where authorised or required.
• Where we verify your identity, we may collect document details (e.g., licence number, passport number) and check them through the Australian Government’s Document Verification Service (DVS). We will only do this with your express consent in accordance with the Identity Verification Services Act 2023.
• As required by law (e.g., Corporations Act 2001 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)).

Cookies and tracking technologies:

We use cookies and analytics tools (such as Google Analytics) to improve our Site, monitor traffic patterns, and deliver relevant advertising. You can disable cookies in your browser settings, though this may affect functionality. Where cookies or analytics tools involve the collection of personal information, we comply with the APPs and obtain your consent where required.

For what purposes do we collect, hold, use and disclose your personal information?

We handle your personal information for purposes including:

• Processing and administering your investments.
• Verifying your identity using the Document Verification Service (DVS) in accordance with law and your consent.
• Providing access to secure areas of our Site or investor portal.
• Communicating with you about your investment, the market, or our services.
• Complying with legal and regulatory obligations.
• Sending marketing material where permitted and with your consent (you can opt out at any time).
• Improving our products, services, and online experience.

We do not sell your personal information to third parties.

To whom may we disclose your information?

We may disclose your personal information to:

• Our employees, related bodies corporate, contractors, or service providers.
• Government and regulatory bodies such as ASIC, ATO, AUSTRAC, or law enforcement.
• Third parties where you have provided consent.

Overseas disclosure: Your information may be disclosed to recipients outside Australia, including our service providers in countries such as the United States, United Kingdom, Singapore, New Zealand, and other jurisdictions as required. Where we disclose personal information overseas, we take reasonable steps to ensure recipients handle it in accordance with the APPs or have comparable privacy protections.

Identity Verification (DVS) Use: We use the Australian Government’s Document Verification Service (DVS) to verify your identity when required by law or regulation (such as under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006). We will inform you before each DVS check, provide a link to this Privacy Policy, and obtain your express consent. Your consent will be recorded (date, time, method, and staff member). DVS information is used solely for verifying identity and is not retained longer than necessary, except where required for audit (minimum seven years). You may refuse consent to a DVS check, but this may limit our ability to provide certain services.

Direct marketing materials

We may send you information about our products and services that we think may interest you, in accordance with the Spam Act 2003 (Cth). You can opt out at any time by using the unsubscribe link or contacting us directly.

Data retention

We store personal information securely in electronic or hard copy form and take reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification, or disclosure. We retain personal information for as long as required by law (generally at least 7 years) and then destroy or de-identify it.

Records relating to DVS use (including consent, verification logs, and training records) are retained for a minimum of seven years and protected with strict access controls.

How can you access and correct your personal information?

You may request access to or correction of your personal information by contacting us. We will respond within a reasonable time and may require verification of your identity. If we refuse access or correction, we will provide written reasons.

What is the process for complaining about a breach of privacy?

If you believe we have breached your privacy rights, please contact our Privacy Officer. We will investigate and respond in writing.

Complaints relating to identity verification or DVS use can also be made via invest@microequities.com.au

If you are not satisfied, you can contact the Office of the Australian Information Commissioner (OAIC) at:
Website: www.oaic.gov.au
Phone: 1300 363 992
Email: enquiries@oaic.gov.au

Changes to our privacy policy

We may update this Privacy Policy from time to time, with the latest version published on our website.

Contacting us

Privacy Officer – Microequities Asset Management Group Limited
Post: Suite 3105, Governor Macquarie Tower, 1 Farrer Place Sydney NSW 2000
Phone: +61 2 9009 2900
Email: compliance@microequities.com.au