Privacy Policy

Introduction

Here at Veteran Invest, (we, us or our) are committed to protecting your privacy and treating your personal information with care is of paramount importance to us. This Privacy Policy explains why we collect personal information and how we collect, use, disclose, store and protect your personal information when you use our services (our referral services to third party suppliers of goods and services to veterans and anything we add to those services from time to time).

It also explains how to contact us to correct, update or delete any personal information provided to us, or make a complaint if you have concerns. We are compliant with the privacy principles of Australia.

We will only collect and process personal information about you where we have a lawful basis to do so. Lawful basis includes consent (where you have given consent such as filling out our “contact us” form), contract (where processing is necessary for the performance of a contract with you) and legitimate interests (including security threats or frauds, compliance with applicable laws, and enabling us to administer our business).

You expressly and voluntarily grant your informed consent to Veteran Invest to deal with your personal information in accordance with the terms and conditions of this Privacy Policy. You have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

Changes that we make to our Privacy Policy

We will notify you about any changes to our Privacy Policy by updating the “Last updated” date of this Privacy Policy.  You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Veteran Invest services after the date such revised Privacy Policy is posted.

Which entities does this Privacy Policy cover?

This Privacy Policy applies to Veteran Invest with respect to all our services.

What is personal information?

Personal information is defined as information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Why do we collect your personal information?

We may collect your personal information when required by law but generally we collect personal information from you (or about you) to allow us to:

· supply you with our Veteran Invest services;

· supply you with tailored service offerings that may benefit you;

· communicate more effectively with you about our services such as our investment opportunities;

· supply marketing or promotional materials and other information to you;

· ensure your experience with us is a positive one; and

· notify you about our new services or product offerings, discounts, promotions or upcoming events.

Personal information collected or received by us will only be used for the stated purpose for which it was provided.

When you access the Veteran Invest services, we may collect certain information automatically, including, but not limited to, your operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data (Usage Data).

When do we disclose your personal information?

Your personal information will not be used contrary to this Privacy Policy but may be disclosed to third parties in the following circumstances:

· for the purpose it was collected (such as a referral to a third-party service provider) namely Growth Point Capital (GPC);

· if we sell all or part of our business and the purchaser also requires your personal information;

· to enforce our legal rights or those of others;

· to prevent actual or potential fraud or illegal activity; or

· if we are required to do so by law.

If personal information is disclosed to a third party, we are required to take reasonable steps to ensure your personal information is treated in accordance with the laws that apply to personal information.

When and how do we collect your personal information?

We collect most personal information directly from you when you make an enquiry about the services we provide. Your consent may be express (e.g. you agree to the use of your information by ticking a box) or implied by an action you take or do not take (i.e. because you have agreed to terms and conditions that contain information about the use or disclosure of your information).   At the date of this policy, your consent is given when you register your interest in a service, sign up for our newsletter or complete our contact us registration form.

What if you don’t want us to collect your personal information?

You are not obligated to provide us with your personal information. You may choose whether you receive communications from us. Whilst it is your choice not to provide your personal information to us this may impede our ability to provide you with all of the functionality of our services.

Your Consent.

By using our website, or by accepting our Terms & Conditions which refer to this Privacy Policy, you are agreeing to our collection, disclosure, use and storage of your personal information in accordance with this policy.

What if you don’t want to receive further communications from us?

Should you wish to remove yourself from our contact database you may do so at any time by unsubscribing or contacting us at invest@veteraninvest.com.au.

How can I access, correct and/or update personal information you have collected?

At any time, you may contact our Privacy Officer and request your personal information be modified. We will make all efforts to correct data once we have proved your identity.

We will deal with all requests for access to personal information as quickly as possible, but no later than 30 calendar days from the date of your request (unless any complexities arise).

We will refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings. Further, we will refuse access where your request is frivolous or vexatious, and where we reasonably believe that: giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; unlawful activity, or misconduct of a serious nature, is being or may be engaged in against Veteran Invest and giving access would be likely to prejudice the taking of appropriate action in relation to that matter.

If we refuse to give you access, we will provide you with reasons for our refusal, unless doing so would be unreasonable in the circumstances. We will also take reasonable steps to give you access in a way that meets your needs without giving rise to the reasons of our refusal. Further, we will provide details of how you may make a complaint about our decision.

Please note that the access and correction requirements under this Privacy Policy operates alongside and do not replace other informal or legal procedures by which an individual can be provided access to, or correction of, their personal information.

How do we store and protect your personal information?

For us to provide excellent service we are required to store some personal information and take the greatest of care to ensure this information is treated as private and confidential. 

Transmitting personal data via the internet does have inherent risks associated with it. We will however take all reasonable steps to ensure the security of this data. Note that no information transmitted over the Internet can be guaranteed to be completely secure. While we will endeavor to protect your personal information as best as possible we cannot guarantee the security of any information that you transmit to us, or receive from us. The transmission and exchange of information is carried out at your own risk.

Although we take measures to safeguard against unauthorized disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

We have taken the necessary measures to ensure the personal information (including the financial information about yourself) we hold is not compromised. In accordance with and as permitted by applicable law and regulations we will retain your information as long necessary to serve you, to maintain your registration or as otherwise need to operate our business.

It is important that you protect your privacy by ensuring that no one obtains your personal information and you must contact us directly if your details change. Should your information be erroneously provided to us or no longer remain valid within the constraints of this Privacy Policy we will securely destroy or de-identify it as soon as practicable, as long as it is lawful to do so.

We have obligations to notify you if you are affected by an data breach. We will take all reasonable precautions to take remedial action to prevent such an event. However, as we cannot guarantee that remedial action will be sufficient to prevent all instances of a breach, we will take steps to notify you of an eligible data breach as soon as practicable and provide recommendations as to what steps you should take to mitigate any serious loss or damage.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior's information. When you visit our website, we may collect information from you automatically through cookies or similar technology.

Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

How do we use cookies?

We use cookies in a range of ways to improve your experience on our website, including understanding how you use our website.

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

· Functionality – we use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

· Advertising – we use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Sometimes we share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies.

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Third party sites.

Our site has links to other websites and services provided on those websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practice's of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

Disclosure Policy.

Veteran Invest is in no way associated with the Department of Veteran Affairs (DVA). We are an online service providing information that has affiliate agreements with Growth Point Capital (GPC). Veteran Invest is remunerated for its services rendered to GPC. Please note that some of the links on our website are affiliate links of GPC. This means that Veteran Invest will earn a commission if you decide to proceed with the services that GPC are providing. 

Please understand that we have completed our due diligence and we recommend GPC because they are valuable and beneficial for veterans, not simply because we make money from referring you to them. Please don’t proceed with this service if you don’t think they will benefit you or your family. 

Veteran Invest is purely designed to promote the awareness of these services and does not accept payments from veterans directly.

Direct Marketing.

By submitting your personal information to us, you expressly consent to us or our partners using your personal information to provide you with information about our products, services or events which we consider may be of interest to you or engage in any other direct marketing activity.

We may also use your personal information for the purpose of providing you with other information, if it is within your reasonable expectations that we would send you such information given the nature of previous communications with you.

You may at any time opt out of receiving any communications from us (other than as required for the provisions of our services) by using the “unsubscribe” facility included in an email you receive from us or by contacting us using the details set out at the bottom of this document.

Data Security.

We store personal information contained in electronic records, in a controlled and secure environment.

Your personal information is only accessible by those persons who require access to the personal information for the purposes of carrying out their work on our behalf.

When personal information (such as payment information) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

We will take all reasonable steps to protect the personal information we hold from misuse and loss and from unauthorized access, modification or disclosure.

If we suspect that a data breach has occurred, we will follow the requirements of the Data Breach Notification scheme under the Privacy Act. The requirements include notifying affected individuals and the Office of the Australian Information Commissioner in some circumstances.

Destruction & De-Identification.

We will retain your personal information whilst it is required for any of our business functions, or for any other lawful purpose. We will destroy or de-identify personal information in accordance with our data security and data destruction policies or when our legal obligations to retain the information have expired and the information is no longer needed by us.

Access To Your Personal Information.

You will have access to the personal information we hold about you and the ability to amend such information by logging into the customer profile we create for you.

Your Payment Information.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information supplied is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures and encryption methods, when a user places an order or enters, submits, or accesses their information, to maintain the safety of your personal information.

All transactions are processed through a secure gateway provider and your credit card information is not stored on our systems.

General Data Protection Regulation - Processing EU Personal Data.

This section entitled “General Data Protection Regulation – Processing EU Personal Data” only applies if you access our products or services in the EU and your personal data (as defined in this section) is processed and/or monitored as a result.

General - When we process your personal information, we will comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”), any local implementing laws and any successor legislation to the GDPR and the local implementing laws. We are the data controller (as defined in GDPR) of the data you pass to us pursuant to this policy.

Where we refer to “personal information” throughout this policy, it has the meaning set out in the Privacy Act (as explained at the beginning of this policy) and also the meaning given to “personal data” in the GDPR. “Processing” has the meaning set out in GDPR and, in practice, means doing anything with your personal information, including storing it.

Grounds for Processing.

We collect most of your personal information on the grounds of our legitimate interests or fulfilment of engagement with you. If we deem it appropriate, we may also rely on legitimate interests to send you marketing communications. If we are unable to rely on legitimate interests or another ground to process your personal information, we will seek consent from you in accordance with the requirements of GDPR.

If we have obtained consent from you to process your data, you have the right to withdraw your consent at any time. To withdraw your consent, please contact us using the contact information set out below. Please bear in mind that if you withdraw your consent it may affect our ability to carry out tasks for your benefit. Withdrawal of your consent will not affect any processing we have carried out in respect of your personal information prior to you withdrawing consent.

In the section entitled “What we do with your personal information”, we have explained that we may need to disclose your personal information to certain third parties. If any of those third parties are located outside of the European Economic Area (EEA) we will ensure that there are appropriate safeguards in place when the data is transferred in accordance with the requirements of GDPR.

Automated decision making – part of our engagement with you may be determined as a result of a process of automated decision making. We carry out this example of automated decision making on the grounds that it is necessary to fulfil the engagement we have with you.

Your rights – there are a number of rights available to you under GDPR. These include:

· the right to access your personal information and ask us to provide certain information about the processing we carry out in respect of your personal information;

· the right to ask us to rectify any personal information we process that you believe is incorrect or incomplete;

· the right to ask us to erase your personal information; the right to ask us to restrict the processing we carry out in respect of your personal information, or to object to the processing we carry out; and

· the right to have your data provided to another data controller in a structured, commonly used and machine-readable format (data portability).

Please note that there are some exceptions and caveats to the rights listed above.

Complaints – in addition to your rights set out above in the section entitled “Complaints and Concerns”, you are entitled to complain to the relevant supervisory authority in your jurisdiction.

Complaints & Concerns.

If you have a problem, complaint or wish to enquire about our Privacy Policy, please contact our Privacy Officer.

We will respond to your complaint in accordance with the relevant provisions of the APPs as soon as practicable. We treat complaints relating to privacy very seriously. If you submit a concern or complaint, we will endeavor to deal with it comprehensively and reach an outcome where all parties are satisfied.

If you are not satisfied with our response to your complaint, or if you would like further information about privacy in Australia, then we suggest you contact the Office of the Australian Information Commissioner at oaic.gov.au.

Our Contact Details.

If you have any questions about this policy or if you have any complaint regarding the treatment of your privacy by us, please contact us using the following details:

Email:invest@veteraninvest.com.au