DCM (“we” or “us”) are committed to protecting and respecting your privacy. This Privacy Policy sets out our policies and procedures for collecting, using and disclosing information provided to us by users of DCM’s products and services. DCM is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), upon which this policy is based. If you have further questions relating to this policy please contact us using the contact information below.
If at any time our Privacy Policy changes, the updated details will be available here on our website. Any information we hold about you will be governed by the most current version of the privacy policy. Your continued use of our site, products and services indicates your acceptance of any changes.
We maintain information you submit in your profile on the website and when receiving services from our consultants, we collect user submitted content about companies and investing, and we collect information from you when you send us feedback.
Some information collected is not explicitly submitted by the user. Examples of such information include (but are not limited to): browser-type related information, IP address, requested URL, referring URL, and timestamp. We use this non-personally identifiable information to perform statistical analyses of user behaviour and characteristics in order to measure interest in and use of the various areas of the site.
Where required, we collect, use and exchange your information so that we can:
Unless you direct us otherwise, we may use your personal information for direct marketing, and may share it with third party provider companies for the sole purpose of facilitating the direct marketing. If you don’t want to receive direct marketing, please tell us by emailing investorservices@digitalfund.io.
Staff members at DCM will be able to access the information you share with us, but only when they need it to provide you with a product or service.
We never share your personally identifiable information with advertisers without your express permission. If you choose to use the goods and services advertised, disclose your personal information directly to those companies or grant them permission to collect information about you, then their use of your information is governed by their privacy policies.
We will only exchange your information with third parties where this is permitted by law or for any of these purposes:
We may disclose personal information outside of the jurisdiction of Australia including the United States of America, European countries and Asian countries. The most common reason will be when we use service providers to perform some functions on our behalf. The privacy laws of those countries may not provide the same level of protection as the privacy laws of Australia. However, this does not change our commitment and obligation to safeguard your privacy and we will comply with all applicable laws relating to cross-border data disclosure.
We reserve our right to transfer your personal information in the event of a transfer of ownership of DCM.
Our website may contain links to third party websites to which we have no affiliation. Unless you give us permission, we will not share your personal information with third party websites. These websites have different privacy policies, and we recommend you read them before utilising the websites and third party services.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect online.
We may store your personal information in hardcopy documents or electronically. Both methods have locks, security systems and network security, and our staff policies require our staff to respect the confidentiality of any personal information held by us. Our electronic storage is on our own server and secure cloud-based servers of third party companies. We will ensure any overseas third parties have appropriate data handling and security arrangements in place.
While we do everything we can to protect your information, we cannot assure you that personally identifiable information will never be disclosed in a manner that is inconsistent with this Privacy Policy. By using our services and products, you acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us form any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
You have a right to contact us to access the personal information we hold about you. We will make it available to you within 30 days. There is no fee, however if your request is complex we may pass on an access charge for the time we spend locating, compiling and explaining the information you ask for. If this is the case, we will give you an estimate upfront and confirm it with you before we proceed.
In certain circumstances we’re allowed to deny your request, or limit the access we provide. For example we might not provide you access to commercially sensitive information. Whatever the outcome, we’ll write to you explaining our decision.
Your request should be made out by email to the Director of DCM to investorservices@digitalfund.io.
If you believe that the personal information we hold is inaccurate, incomplete or out-of-date, you have a right to update or correct your information at any time by contacting us.
If we disagree with you that information should be corrected, we’ll let you know in writing our reasons. You can ask us to include a statement with the relevant information, indicating your view that the information is inaccurate, misleading, incomplete, irrelevant or out-of-date. We will take reasonable steps to comply with such a request.
Your request should be made out by email to the Director of DCM to investorservices@digitalfund.io.
Please note that when we close your account, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. There may be latency in deleting information from our servers and back-up versions might exist after deletion.
When we no longer need to use your information, or are no longer required to retain it by law, we will take steps to properly de-identify or destroy it.
We accept that sometimes we can get things wrong. If you have a concern about your privacy, you have a right to make a complaint and we’ll do everything we can to put matters right.
To lodge a complaint, please contact us at the details listed below. Within 7 days we will contact you and assign you a contact person within DCM. We’ll review your situation and try to resolve it straight away. We keep you updated on the progress we’re making towards fixing the problem.
Usually, it takes only a few days to resolve a complaint. However, if we’re unable to provide a final response within 45 days, we’ll contact you to explain why and discuss a timeframe to resolve the complaint.
If you’ve raised the matter with us and it hasn’t been resolved or you are not satisfied with the outcome or how we handled the matter, you can refer your complaint to external dispute resolution. We suggest you do this only once you’ve first followed our internal complaint processes set out above.
The Financial Ombudsman Service (FOS) offers a free and independent dispute resolution service for the Australian banking, insurance and investment industries. FOS will consider privacy disputes if they’re about the provision of credit, the collection of a debt, credit reporting or the banker-customer relationship, or if the privacy issue is part of a broader dispute with us. Please contact FOS at 1300 780 808, online at www.fos.org.au or write to Financial Ombudsman Service Limited, GPO Box 3, Melbourne VIC.
If your complaint is about the way we handle your personal information, you may also contact the Office of the Australian Information Commissioner by calling them at 1300 363 992, online at www.oaic.gov.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NDF 2001.
Digital Capital Management Pty Ltd is a Corporate Authorised Representative (CAR) of the Australian Financial Service License 479 974. CAR Number 126 0311.
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