In this Privacy Policy, 'us' 'we' or 'our' means AtlasTrend Pty Ltd (ABN 83 605 565 491) and our related bodies corporate. We are committed to respecting your privacy. Our Privacy Policy sets outs out how we collect, use, store and disclose your personal information.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy. You can also contact us to obtain a copy of our current Privacy Policy.

Personal information which an individual or that can reasonably enable their identity to be determined. For example, this may include your name, date of birth and contact details.

Personal information includes “sensitive information”. Sensitive information is any information, or an opinion concerning about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices or criminal record. It also includes health or genetic information, biometric information and biometric templates. We will only collect “sensitive information” if you have consented to the collection of the information and the information is reasonably necessary for one or more of our functions or activities or if the collection of sensitive information is authorised or required by a court/tribunal order or an Australian law, including the following Australian laws:

• Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• Corporations Act 2001 (Cth);
• Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth);
• Privacy Act 1988 (Cth) (Privacy Act).

What personal information do we collect?

We may collect the following types of personal information:

• name;
• mailing or street address;
• email address;
• telephone number and other contact details;
• date of birth;
• credit card information;
• if you seek to open an Elevate Super account - your Tax File Number (TFN);
• 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;
• 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;
• 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;
• information you provide to us through customer surveys; or
• any other personal information that may be required in order to facilitate your dealings with us.

We may collect these types of personal information either directly from you, or from third parties (for example, identity verification service providers, publicly or commercially available sources or third parties you have authorised us to contact). We may collect this information when you:

• register on our website;
• register on the website for Elevate Super at www.elevatesuper.com.au;
• communicate with us through correspondence, chats, email, or when you share information with us from other social media applications, services or websites;
• interact with our sites, services, content and advertising; or
• invest in our business or enquire as to a potential purchase in our business.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

If it is lawful and practicable, we offer you the opportunity to deal with us anonymously or by using a pseudonym. For example, we can provide general information to you about our products or services, or general guidance on how to fill out our forms without collecting any personal information.

However, if we are unable to collect and/or verify some or all of your personal information, we may not be able to enter into a business relationship with you or provide certain services to you. In order for us to provide our services to you it is normally impracticable for us to deal with you anonymously or by using a pseudonym. For example if you do not provide your personal information to us, we will be unable to properly administer your investment, contact you about your investment or adequately provide our services.

Why do we collect, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:

• to enable you to access and use our website and apply to invest in investment fund or superannuation products.
• to operate, protect, improve and optimise our website, investment fund products, superannuation product, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
• to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
• (if applicable) to consider your employment application.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

If you cease your relationship with us, we will only retain your personal information on file to the extent necessary to meet our regulatory obligations and we will only contact you with your consent.

Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, provided in accordance with the Spam Act 2003 (Cth) and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this Privacy Policy to:

• our employees and related bodies corporate;
• the responsible entity for any investment fund products offered via our website;
• the trustee for any superannuation product promoted by us;
• third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you, which may include the member administrator or associated insurance provider for any superannuation product promoted by us);
• professional advisers, dealers and agents;
• payment systems operators (eg merchants receiving card payments);
• our existing or potential agents, business partners or partners;
• our sponsors or promoters of any competition that we conduct via our services;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

We may require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected.
If you do not consent to us collecting, using and/or disclosing your personal information for such other purposes, this may affect our ability to deliver and improve our products and services, or to engage or do business with you.

Disclosure of personal information outside Australia

We will only disclose your personal information to a recipient overseas in accordance with the Privacy Act.

We may disclose personal information outside of Australia to third party suppliers such as cloud providers located in the United States.

When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian privacy laws. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles under the Privacy Act.

Using our website and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we use third party cloud based providers that utilise multi-layered encryption to electronically store and restrict access to our files. We regularly review, monitor and update our security policies and systems. However, we cannot guarantee the security of your personal information.

You are responsible for keeping any account details, username and password confidential and secure at all times.
We take reasonable steps to destroy or permanently de-identify personal information that we are not required by law to retain.

Third party websites and services

Please note that:

• our website may contain links to websites operated by third parties (which, unless otherwise specified, we are not responsible for and have no control over), which are provided for convenience and may not remain current or be maintained;
• we may use social networking services (for example, Twitter, Facebook, YouTube or Linked In) to communicate with current and potential customers; and
• we may use third party service providers to manage contact lists and event registrations or to collect feedback about our services.

Our privacy policy does not apply to these third parties. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Accessing or correcting your personal information

You can seek to access the personal information we hold about you by contacting us at info@atlastrend.com. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you contact us about your personal information. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected (and, if we are unable to do so, we will tell you why).

To ensure that the information we hold about you remains accurate, complete and up-to-date, we may ask you to check and correct your personal details from time to time. We may do this as part of our regular communications with you, when you make a telephone enquiry, or through other means.

Making a complaint

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us at info@atlastrend.com. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.

If you are not satisfied with the manner in which we deal with your complaint you may refer it to the Office of the Australian Information Commissioner (OAIC). You can contact the OAIC: Online: by visiting www.oaic.gov.au
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
Mail: GPO Box 5218
Sydney NSW 2001

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below: info@atlastrend.com