Privacy Policy

Introduction

Gabcus Investment (ABN: 77 098 038 030, AFSL: 238189) is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy explains how we collect, use, disclose, and protect your personal information.

Information We Collect

We may collect the following types of personal information:

Personal Identification Information

• Name, date of birth, and contact details (address, email, phone number)
• Government-issued identification (driver's license, passport)
• Tax File Number (TFN) where authorized
• Employment and income information
• Bank account and payment details

Financial Information

• Investment goals and risk tolerance
• Current assets and liabilities
• Investment portfolio holdings
• Transaction history
• Credit information (where applicable)

Usage Information

• Website usage data and cookies
• Communication preferences
• Device and browser information
• IP address and location data

How We Collect Information

We collect personal information through various means:

• Account application forms and onboarding processes
• Direct interactions with our advisors and staff
• Website interactions, forms, and online portals
• Phone calls and email correspondence
• Third-party service providers (with your consent)
• Publicly available sources
• Verification services for identity confirmation

Why We Collect Information

We collect and use your personal information for the following purposes:

• Service Provision: To provide investment advice, manage your portfolio, and execute transactions
• Legal Compliance: To meet our obligations under anti-money laundering (AML), counter-terrorism financing (CTF), and taxation laws
• Identity Verification: To verify your identity and prevent fraud
• Communication: To contact you about your investments, market updates, and service changes
• Product Development: To improve our services and develop new products
• Marketing: To inform you about products and services that may interest you (with your consent)
• Risk Management: To assess and manage risks associated with our services

Information Disclosure

We may disclose your personal information to:

• Service Providers: Third-party providers who assist us in delivering our services (e.g., platform providers, custodians, payment processors)
• Financial Institutions: Banks, brokers, and other financial institutions involved in executing your transactions
• Professional Advisors: Lawyers, accountants, auditors, and consultants
• Regulatory Bodies: ASIC, AUSTRAC, ATO, and other regulatory authorities as required by law
• Related Entities: Other companies within the Gabcus Investment group
• Your Representatives: Financial advisors, accountants, or lawyers acting on your behalf

We do not sell your personal information to third parties. We only disclose information when necessary for the purposes outlined above or where required by law.

Overseas Disclosure

In some circumstances, we may disclose your personal information to overseas recipients, including:

• Cloud service providers located in the United States, Singapore, or the European Union
• International investment platforms and exchanges
• Overseas regulators (where required for international investments)

We take reasonable steps to ensure that overseas recipients comply with the APPs or are subject to similar privacy protections.

Data Security

We implement robust security measures to protect your personal information from misuse, interference, loss, unauthorized access, modification, or disclosure:

• Encryption of data in transit and at rest
• Secure data centers with restricted physical access
• Regular security audits and penetration testing
• Employee training on privacy and data security
• Access controls and authentication systems
• Secure disposal of information no longer required

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by law (typically 7 years for financial records).

Your Rights

Under the Privacy Act 1988 (Cth), you have the following rights:

Cookies and Website Tracking

Our website uses cookies and similar technologies to:

• Remember your preferences and settings
• Analyze website traffic and user behavior
• Improve website functionality and user experience
• Provide personalized content

You can control cookies through your browser settings. However, disabling cookies may affect your ability to use certain features of our website.

Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to review their privacy policies before providing any personal information.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated policy will be posted on our website with the revision date. Material changes will be communicated to you via email or through our website.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

Complaints to the OAIC

If you are not satisfied with our response to your privacy complaint, you have the right to contact the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au