Privacy Policy

We collect personal information necessary to provide our financial services and manage your investments. This may include:

• Identity Information Full name, date of birth, Tax File Number (TFN), and government-issued identification documents for AML/KYC compliance.
• Contact Information Email address, phone number, and residential or postal address.
• Financial Information Investment objectives, risk profile, financial situation, brokerage account details, and transaction history.
• Usage Information IP address, browser type, pages visited, and interaction data collected when you use our website or Mosaic platform.

We collect information directly from you, from your authorised representatives, or via third-party service providers, in accordance with applicable laws. We do not actively seek sensitive information unless it is essential for our business purposes and permitted by law.

We use your personal information for the following purposes:

• Service Delivery To manage and administer your investments, execute trades on your behalf, and provide ongoing advisory services.
• Legal & Regulatory Compliance To comply with Anti-Money Laundering / Counter-Terrorism Financing (AML/CTF) obligations, ASIC reporting requirements, Australian tax laws, and other applicable legislation. This may involve disclosure to the ATO, AUSTRAC, ASIC, or other regulatory authorities.
• Communications To send investment recommendations, portfolio updates, market research, and service-related notices.
• Marketing To send promotional material about our products and services. You may opt out at any time by contacting us or using the unsubscribe link in any marketing email.
• Platform Improvement To analyse usage of our website and Mosaic platform in order to improve functionality and user experience.

We may disclose your personal information to third parties where necessary to deliver our services or meet legal obligations, including:

• Service Providers Brokers, OTC product issuers (including StroPro), custodians, third-party platform providers, and technology vendors who assist in delivering our services.
• Professional Advisers Licensed financial advisers, accountants, lawyers, and dealer groups where you have provided consent or where required.
• Regulatory & Law Enforcement Bodies Where required or authorised by law.

We do not sell your personal information to third parties. Where we engage overseas third parties (e.g., cloud service providers), we take reasonable steps to ensure your information is handled consistently with the APPs.

We apply reasonable technical and organisational safeguards to protect your personal information from misuse, loss, interference, and unauthorised access, modification, or disclosure.

• Physical Security Personal information in physical form is stored in secure office premises with restricted access.
• Electronic Security Access to our systems and databases is restricted to authorised personnel via password controls and multi-factor authentication where applicable.
• Data Retention We retain personal information only as long as required by law or necessary for our business purposes. Information is securely destroyed or de-identified once no longer needed.

Under the Privacy Act 1988, you have the right to request access to, and correction of, your personal information held by us. To make a request, please contact our Privacy Officer. We will respond within a reasonable timeframe and may ask you to verify your identity before granting access.

Our website uses cookies and similar tracking technologies to improve your browsing experience, analyse site traffic, and support marketing activities. You may disable cookies through your browser settings, however this may affect the functionality of our website. We use Google Analytics and other third-party tools to collect anonymised usage data.

If you believe we have mishandled your personal information or breached the Australian Privacy Principles, please contact our Privacy Officer at the address above. We will acknowledge your complaint promptly and respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The current version will always be available on our website. Continued use of our services following any update constitutes your acceptance of the revised policy.