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Privacy Policy

Principles of Privacy Policy

Privacy Policy of the Site explains how we will handle your personal information according to the Privacy Act 1988 (Cth) and the Australian Privacy Principles, as applicable.

 

Personal Information and Collection

Vellum will collect information only where necessary for the primary purpose of:

 

  • providing you with our services and products or with information you have requested

  • notifying you about other Vellum services or promotions from time to time

  • identification purposes as required for anti-money laundering and counter-terrorism financing purposes or other Australian or extraterritorial taxation, legal or regulatory obligations

  • meeting our obligations under laws and regulations

  • managing our relationship with you.

We endeavour to collect personal information in a lawful and non-obtrusive way.

 

The types of personal information that Vellum collects and maintains generally comprises:

 

- your name

- contact details such as telephone numbers, address and e-mail address

- birth date

- tax file number

- bank account details

- citizenship

- other information that may be required for identification, product design and distribution or taxation purposes.

Unless require by law, we DO NOT collect your sensitive, such as information about your religion, race, political views, criminal convictions, health information or membership of professional or trade associations or unions.

 

How we collect Personal Information

We will normally collect your personal information directly from you, unless you have appointed a person, agent or broker to act on your behalf.

 

The ways we may collect your personal information include:

 

  • direct from you when you complete an application form in relation to our service(s) (either hard copy or on-line application forms)

  • when you contact us via email or telephone

  • when you participate in surveys or competitions or promotions or add your name to any mailing lists.

  • From third parties when you have provided authority for us to do this, e.g. from attorneys, financial advisers, platform providers, brokers, lawyers, identification verification service providers.

  • From public or commercially available sources for the purposes of complying with customer due diligence obligations, product design and distribution obligations or to ensure contact details are up to date and accurate.

 

Vellum may record and monitor telephone calls for security, training and compliance purposes.

 

Use and Disclosure of the Personal Information

Vellum will typically use personal information for the following purposes:

 

  • to comply with applicable laws and regulations, including anti-money laundering, product design and distribution, taxation and associated laws

  • to process and verify your application for our products and/or service(s)

  • to inform you of other products or services or offers that may be of interest to you and to improve and customise our products and services

  • to manage your investment with us

  • to conduct product and market research, including product suitability assessments.

We will only use and disclose personal information about you for the purpose for which it is collected, unless consent has been obtained to use the information for additional purposes. Exceptions to this include where disclosure is:

 

  • required by law(s) and/or regulation(s)

  • reasonably necessary to assist a law enforcement agency

  • reasonably required by a third party service provider to meet their legal or regulatory obligations

  • required by external companies for the purposes of issuing statements and handling mail.

 

Vellum may disclose your personal information to:

 

  • your attorney, financial adviser, platform provider, broker or any other person you have authorized

  • professional services firms that have a legitimate need to access this information, such as lawyers, auditors

  • electronic identification verification providers.

Storage, Access and Change of Your Personal Information

 

We take reasonable steps to protect the personal information that we hold from misuse and loss and from unauthorised access, modification and disclosure.

 

From time to time, Vellum or its third-party providers may store your information in hard copy(ies),in cloud or other types of networked systems. Information stored in cloud or network-based systems can be accessed from and transferred between, various countries over the internet, and as such, it is not always practicable to know in which country your information may be held. By providing your personal information to us, you acknowledge that countries in which your information may be held will have privacy and data protection laws that may differ from those of Australia and overseas organisations may be required to disclose information that Vellum has shared with them, under foreign laws.

 

You can access and request the change of most of the personal information we hold and request changes subject to some exceptions. Such exceptions include:

  • you may be unable to obtain access to your personal information which would reveal personal information about another person, or

  • we may be prevented by law from disclosing such information.

 

Governing Law

 

These Terms and Conditions are governed by the laws in force in New South Wales, Australia. You agree to submit to the non-exclusive jurisdiction of the courts exercising jurisdiction in that state.

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