Privacy Policy
1.
Introduction
1.1.
Trovio Group Ltd and its subsidiaries (collectively
referred to as 'Trovio', 'Company', 'we', 'us' or 'our'), respect the privacy
rights of our clients and other organisations with whom we deal. Trovio is
committed to complying with all applicable privacy laws including
Singapore’s Personal Data Protection Act 2012 (the ‘PDPA’), Australia’s Privacy
Act 1988 (Cth) (the 'Privacy Act') and the Australian Privacy Principles (the
'APPs').
1.2.
Personal
Information may be collected by us and by our third party service providers who
assist us in operating our website, including its subdomains and any other
website we operate from time to time (collectively, the 'Website'). We also
provide platform as a service to institutional clients who may authorise other
users to access such platform (the 'Services').
1.3.
All natural persons or other
entities who view or log on to this Website are considered users of the
Website. For convenience, the users and clients who use the Services are
referred to as 'you'.
2.
Personal information
'Personal Information' is information or an opinion, whether
true or not, and whether recorded in a material form or not, that could
reasonably be used to identify an individual. This includes technical data and
other identifiers that, in combination with other data, could potentially
identify an individual..
3.
Purposes of this Privacy Policy
The purpose of this Privacy Policy is to inform you about
the kinds of Personal Information that we may collect and retain about you by
your use of this Website and/or the Services, how we collect, retain, use and
disclose that Personal Information, choices you have regarding our use of that
Personal Information, and your ability to access or correct that Personal
Information.
4.
Your consent
4.1.
We obtain explicit consent from
individuals before collecting, using, or disclosing personal information,
especially when it involves sensitive data. Consent is obtained in a clear and
transparent manner, ensuring that individuals understand the purposes for which
their data will be used. You may withdraw your consent at any time by
contacting us using the details provided in Section 14.
4.2.
To ensure that you have full
confidence in our handling of Personal Information, you are advised to read and
understand the terms of this Privacy Policy in detail. In particular, when you
read, browse or download information from our Website or use the Services,
regardless of whether you register with the Website, you will be deemed to have
provided your consent to the following:
(a)
you consent to us using your
Personal Information as set out in this Privacy Policy
(b)
you consent to the collection, use,
storage and processing of your Personal Information through the use of our
Website, your registration with the Website, and your use of the Services
offered by us;
(c)
you agree to any changes and modifications
that we may make to our Privacy Policy in the future; and
(d)
you consent to our branches,
affiliates and employees using your Personal Information for sending you
information, including promotional material, and that they may contact you in
connection with our products and services that you may be interested in, now
and in the future (unless you have indicated that you do not want to receive
such information). You also consent to us sending you such information by means
of direct mail, email, SMS and MMS messages.
5.
What Personal Information do we
collect?
5.1.
We limit the collection of personal
information to what is necessary to provide our services, comply with legal
obligations, and fulfill our business functions. We do not collect personal information
beyond what is required for these purposes.
5.2.
The Personal Information we may
collect, hold and/or use about you will depend on the type of product and
service you request. Examples of Personal Information we may collect include,
but are not limited to:
(a)
your contact details, including your
name, postal or street address, email address, telephone numbers and other
contact details;
(b)
your identification information,
including age or date of birth, gender, tax file number;
(c)
your financial information,
including bank account numbers, credit card information or other information about your financial
circumstances;
(d)
details relating to your employment
history;
(e)
details relating to your investment
profile;
(f)
other identity verification
information, including driver’s licence number, copy of driver’s licence, motor
vehicle registration number, vehicle plate number, birth or citizenship
certificate, passport number, and photographs;
(g)
your device ID, device type,
geo-location information, computer and connection information, statistics on
page views, traffic to and from the sites, ad data, IP address and standard web
log information;
(h)
details of the products and services
we have provided to you or that you have enquired about, including any
additional information necessary to deliver those products and services and
respond to your enquiries;
(i)
any additional information relating
to you that you provide to us directly through our website or indirectly
through your use of our website or online presence or through other websites or
accounts from which you permit us to collect information;
(j)
your IP address, location, analytics
and remarketing collected through the use of our Website; and
(k)
any other information that we deem
necessary in your dealings with us.
5.3.
We will at all times take reasonable
steps to ensure that the Personal Information collected and held by us is
protected from misuse, loss, unauthorised access and disclosure. You have the
right, where it is lawful and practicable, of remaining anonymous when entering
into transactions with Trovio. However, should you wish to remain anonymous, we
may not be able to provide you with our Services.
5.4.
Where you provide us with
unsolicited Personal Information which we do not require to deliver the
Services to you, such information will be subject to our normal security
arrangements for client information. Where reasonable to do so, we will not
hold unsolicited Personal Information we do not require, however often we are
unable to delete such information, particularly where it forms part of
correspondence or other interactions that we do need to retain. Deletion in
such circumstances is generally not reasonable or practicable.
5.5.
Personal Information records are
held for a period considered appropriate to provide you with the Services you
require and consistent with applicable laws, including PDPA and the Privacy
Act.
5.6.
Should you cease to be a client of
Trovio, any Personal Information which we hold about you will be maintained for
the relevant periods required by applicable laws.
6.
How do we collect and hold your
Personal Information?
6.1.
In most cases, we collect your
Personal Information directly from you, face to face meetings, application
forms or correspondence (written and verbal). However, if this is not
practical, we may collect information about you from another person or entity –
for example, receiving information from a person to whom you have granted a
delegated authority or power of attorney.
6.2.
When you use the Website or the
Services, we may collect more information necessary in any manner that we
consider as in compliance with relevant requirements, for the purpose of
improving the functions of the Website or the Services, enhancing your experience
of using the Website and the Services as well as the security thereof, or as is
required by any court order, any applicable law, administrative regulation or
any order of any other competent government agency. We may also use various
technological methods from time to time to track the visiting patterns of individuals
accessing our Website. The collecting methods set out below:
(a)
Click Stream Data:
When you visit our Website, our
Website host and other third parties engaged by us may collect Personal
Information for statistical, reporting and maintenance purposes. The
information collected may include: the number of users visiting our Website and
the number of pages viewed; the date, time and duration of a
visit; the IP address of your computer; o the path taken through our Website. Our
Website host uses this information to administer and improve the performance of
our Website.
(b)
Cookies: If you access our Website, we may collect Personal
Information electronically. For example, we may collect information about your
visits by using ‘cookies’. A cookie is a packet of information which is sent by
our Website to your computer to track your use of our Website and to allow you
to efficiently access your account information. Generally, we use cookies for
security purposes and to assess the usage and improve the functionality of our
website. We use both session cookies and persistent cookies. A session cookie
is temporary and is automatically destroyed once your web browser is closed.
All of the transaction functions of our Website rely on session cookies. These
web pages will not work if session cookies are explicitly blocked or disabled
within a web browser. A persistent cookie is a small text file stored on the
user’s computer for an extended period of time. You can opt to set your browser
to reject cookies, or to notify you as soon as possible if you are loaded on
cookies. If you reject persistent cookies you will still be able to access our
Website, but may not be able to use certain features or the web service may not
recognise you.
(c)
Google Analytics: We may use Google Analytics to help analyse how you use our
Website. Google Analytics generates statistical and other information about
website use by means of cookies, which are stored on users' computers. The
information generated is used to create reports about the use of our Website.
Google will store this information. If you do not want our Website visit data
reported by Google Analytics, you can install the Google Analytics opt-out
browser add-on. For more details on installing and uninstalling the add-on,
please visit the Google Analytics opt-out page at http://tools.google.com/dlpage/gaoptout.
(d)
Third party content (e.g. social
media links): Some of the content used on our Website includes applications
made available by third parties, such as social media buttons or links that
allow you to share content or links to our Website through the relevant third
party platforms. These third party applications themselves may facilitate
collection of information by those third parties, through your interactions
with the applications and sometimes even if you do not interact directly with
them. We are not responsible for the technical operation of these applications
or the collection and use practices of the relevant third parties. Please visit
the relevant third party websites to understand their privacy practices and
options they may make available to you in relation to their collection of your
Personal Information.
6.3.
We take care to ensure that the
Personal Information you give us on our Website is protected. Trovio uses a
range of security measures to help ensure this security. Our Website contains
more detailed information on specific privacy and security procedures.
7.
How do we use your Personal
Information?
7.1.
We use your Personal Information
that we collect about you to primarily manage, deliver and administer the
Services to you. Personal Information may also be used so that we can offer
products and services to you including special offers (with your consent, and
subject to your right to unsubscribe or opt-out, as described in paragraph 11.2
below) to extend our relationship with you and to develop products and services
better suited to your needs.
7.2.
We also use your Personal
Information for the purpose of:
(a)
conducting identity verification and
customer due diligence;
(b)
preventing and detecting money laundering
and terrorism financing;
(c)
determining whether you have any
history of defaulting on payment or delivery of securities;
(d)
handling/routing your customer
service or technical support questions or issues;
(e)
helping us manage our business
operations;
(f)
for business support purposes,
including maintenance, backup and audit;
(g)
providing you with products,
services or information in accordance with your requests or reasonable
expectations;
(h)
administering any accounts you hold
with Trovio or any of its affiliates worldwide;
(i)
enabling Trovio or any of its
affiliates worldwide to ascertain whether or not they have other services or
products which may foreseeably meet your needs or may be of interest to you,
and to notify you about these services or products;
(j)
conducting research, planning,
product development, risk assessment, risk modelling and marketing by Trovio or any of its affiliates worldwide;
(k)
sending you marketing, promotional
messages and other information that may
be of interest to you;
(l)
considering your employment
application and verifying your suitability to work with us;
(m)
complying with our legal
obligations including but not limited to
our obligations under the applicable and relevant regulations and legislation;
(n)
resolving any disputes that we may
have with any of our users, and enforce our agreements with third parties;
(o)
improving our customer service;
(p)
collecting and processing payments;
(q)
any other purpose to which you have
consented; or
(r)
disclosure where required or
authorised by law.
7.3.
We may also use and analyse your
information to meet our obligations, and our service providers' obligations (if
applicable), under applicable laws, for example the Know Your Customer
requirements of the AML Act.
7.4.
We reserve the right at all times to
monitor, review, retain or disclose any information as necessary to satisfy any
applicable law, but we have no obligation to monitor the use of the Website or
to retain the content of any user session.
7.5.
We may occasionally hire other
companies to provide services on our behalf, including but not limited to
handling customer support enquiries and processing transactions. Those
companies will be permitted to obtain only the Personal Information they need to
deliver the Services. We take reasonable steps to ensure that these
organisations are bound by confidentiality and privacy obligations in relation
to the protection of your Personal Information.
7.6.
We do not sell, trade or rent your
Personal Information to others. We may share generic aggregated demographic
information not linked to any Personal Information regarding visitors and users
with our business partners, trusted affiliates and advertisers for the purposes
outlined in paragraph 9.1 below.
7.7.
We may otherwise collect, use or
disclose your Personal Information where the collection, use or disclosure is
in accordance with this Privacy Policy or any agreement you enter into with us,
or required or authorised by law, including without limitation PDPA and the
APPs under the Privacy Act.
8.
Who do we disclose information to?
Trovio will only disclose Personal Information to third
parties for the purposes of managing, delivering and administering the Service
you require and in accordance with this Privacy Policy and applicable laws. For
example, we may disclose relevant Personal Information to:
(a)
agents and brokers (intermediaries)
to enable them to efficiently answer enquiries and process transactions;
(b)
for legal reasons, disclosure may
need to be made to law enforcement agencies, government agencies, courts or
external advisers, for example to meet our obligations under the AML Act;
(c)
a person acting on your behalf
including a financial adviser, trustee, attorney or person to whom you have
granted a delegated authority;
(d)
service providers engaged to carry
out functions on our behalf (e.g. other financial institutions as required,
solicitors, software or IT service vendors and auditors/investigators);
(e)
some of these service providers may
be located overseas, including in The Netherlands and Germany. Your Personal
Information will only be disclosed to one of our service providers, or stored
overseas in accordance with this Privacy Policy (as set out in Section 10)
and applicable laws;
(f)
if you have acquired a product or
service through a related entity, your Personal Information may be shared with
that related entity on a confidential basis;
(g)
your financial adviser/consultant
who in turn may disclose information to superannuation funds, trustees,
insurance providers and product issuers for the purpose of giving effect to
your financial plan/strategy and recommendations made by them;
(h)
if a financial adviser/consultant
has referred you to our products and services then your details (including
ongoing investment and transaction details) may be provided to that financial
adviser/consultant, the dealer group, the broker or the organisation for whom
they work; and
(i)
other third parties with your
consent or direction to do so.
9.
Third party websites
You may find advertising or other content on our Website
that link to the websites of our partners, suppliers, advertisers, sponsors,
licensors and other third parties. We do not control the content or links that
appear on these websites and are not responsible for the practices employed by
websites linked to or from our Website. In addition, these websites or
services, including their content and links, may be constantly changing. These
websites and services may have their own privacy policies and customer service
policies. Browsing and interacting on any other website, including websites
which have a link to our Website, is subject to that website's own terms and
policies.
10.
Disclosure of Personal Information
overseas
10.1.
Some of your Personal Information
may be disclosed, transferred, stored, processed or used overseas by us, or by
third party service providers. This may happen if:
(a)
our offices are or related entities
are located overseas;
(b)
we outsource certain activities
overseas;
(c)
transactions, information, services
or products have an overseas connection; or
(d)
our computer systems including IT
services are located overseas.
10.2.
When transferring personal
information outside of Australia or Singapore, we ensure that the receiving
party provides a standard of protection comparable to that under the applicable
privacy laws.
10.3.
In particular, your Personal
Information may be disclosed to third parties in the Netherlands or Germany,
and such other countries in which those parties or their, or our, computer
systems may be located from time to time, where it may be used for the purposes
described in this Privacy Policy. In these circumstances, you consent to the
collection, use, storage and processing of your Personal Information in those
countries, without us being responsible under PDPA and the Privacy Act for such
use (or for any breach). Where such parties are located overseas, you may have
rights to enforce such parties' compliance with the applicable data protection
laws, but you might not have recourse against those parties under PDPA and the
Privacy Act in relation to how those parties treat your Personal Information.
11.
Marketing
11.1.
Trovio may use your Personal
Information for direct marketing purposes in accordance with Section 7.
(a)
clicking on the 'Unsubscribe' or
subscription preferences link in a direct marketing email that you have
received from us;
(b)
logging into your account on the
Website and editing your communication preferences; or
(c)
contacting us using the contact
details specified in Section 14
below.
12.
How do we protect your Personal
Information?
12.1.
We have systems and processes in
place designed to hold your information securely. Only authorised personnel are
granted access to your information. We also have in place processes designed to
identify you when you deal with us by phone, online or face to face. These
processes are designed to ensure we only disclose your information to you, or
someone properly authorised by you. You need to keep access details like user
names and passwords confidential and not share them or leave them somewhere
that is easy for others to access or find.
12.2.
The platform for our Services is
built on international security standards.
12.3.
We provide regular training to our
employees on their privacy obligations and the importance of protecting
personal information.
12.4.
Despite the above-mentioned
technical and security measures, we cannot guarantee that information
transmitted via the Internet is absolutely safe, so we cannot absolutely
guarantee that the Personal Information that you provide to us through our
Website or the use of the Services will be safe at all times. We will not be
held liable for any loss or damage arising from or caused by any event that may
occur in connection with unauthorised access to your personal data, and we
shall not be held liable in compensation for such loss or damage.
13.
Access and Correction
13.1.
You have the right to correct your
Personal Information held by us if you believe it to be inaccurate or out of
date. We will then amend your records accordingly. If we disagree with the
correction, we will advise you of the reasons for doing so and will make a note
on your record of this.
13.2.
You are generally entitled to access
your Personal Information. This can be arranged so by calling or writing to our
Privacy Officer. The details of the Privacy Officer's contact information are
listed in the Section 14
below. Your request should include a detailed description of the information
required. To ensure information is only disclosed to those entitled to it you
may be asked for identification, or in the case of a telephone call asked to
answer a series of questions to verify your identity.
13.3.
In some circumstances, there may be
some legal or administrative reasons to deny access to your Personal
Information. If we are unable to provide you with access to your information,
we will provide you with reasons for the refusal where we are required by law
to give those reasons.
13.4.
Data Portability Obligation: Under
the updated PDPA, individuals have the right to request the transfer of their
personal data to another organization. Trovio has implemented processes to
handle such requests efficiently, ensuring that the transfer is completed
within the timelines prescribed by law. We are committed to facilitating the
exercise of this right in a secure and compliant manner.
14.
Privacy Enquiries and Complaints
14.1.
If you have any requests, comments,
enquiries or complaints about our information handling practices, please
contact useither via email or via mail:
Privacy Officer/Data Protection Officer
privacy@trovio.io
Level 37, 259 George Street, Sydney NSW 2000, Australia
14.2.
You can also contact us if you
believe that the privacy of your Personal Information has been compromised or
not adequately protected.
14.3.
It is our intention to resolve any
complaint as quickly as possible and to your satisfaction. If you are not
satisfied with the response provided by us, please let us know and our Privacy
Officer will investigate further and respond to you. If you are still not
satisfied or if we do not respond to your complaint within 30 days, you can
contact relevant external bodies that deal with privacy complaints.
14.4.
If you are dealing with TCM Capital
AM Pty Ltd, you may contact the Australian Financial Complaints Authority:
Australian Financial Complaints Authority
GPO Box 3, Melbourne VIC 3001
Tel: 1800 337 444
Fax: +61 3 9613 6399
Website: www.afca.org.au
Email: info@afca.org.au
If you are dealing other Trovio’s related entities or your
dispute with the Australian Financial Complaints Authority fails to reach a
satisfactory outcome, you may with to contact the Office of the Australian
Information Commissioner. This body may forward your complaint to another
external dispute resolution body if it considers the complaint would be better
handled by that body.
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Website: www.oaic.gov.au
14.5.
This Privacy Policy is provided for
the purposes of information only. While we have taken care to ensure that it is
accurate and current, we provide no guarantee as to its accuracy or currency.
We accept no liability for loss or damage suffered as a result of reliance on
the information provided in this Privacy Policy.
15.
Data Breach Notification
Trovio is required to notify the relevant authorities and
affected individuals in the event of a data breach that is likely to result in
serious harm. Notifications will be made promptly and will include details of
the breach, the affected data, and the steps Trovio is taking to mitigate any
potential harm. Trovio has established procedures to ensure compliance with
these requirements, and we will take all necessary actions to protect your
data.
16.
Modification to the Privacy Policy
16.1.
We reserve the right to amend the
Privacy Policy from time to time and at any time. We will inform you of the
modifications made to the Privacy Policy by updating and publishing the
effective date of the release of new versions hereof. We may issue a notice to
inform you of any modifications made to the Privacy Policy, but we are not
obliged to do so.
16.2.
You are required to regularly review
the Privacy Policy and focus on its modifications, and if you do not agree to
such modifications, you shall immediately stop accessing this Website. When an
updated version of this Privacy Policy is released, your continued visit to
this Website will indicate and show that you agree to the update and agree to
comply with the updated Privacy Policy.
This Privacy Policy was last updated on 15th
August 2024.