Privacy Policy

Vector Capital Management Pty Ltd (“VCM”)

PRIVACY POLICY

The purpose of this Privacy Policy is to inform clients of VCM as to the information we collect, what we do with this information, and how your information is protected. This Privacy Policy will outline our information administration practices in relation to the information we acquire at VCM through its affiliated services, including information in the Client Portal. At all times, VCM strives to uphold the privacy of individuals and abides by the Australian Privacy Principles set out in the Privacy Act 1988 (Commonwealth).

References to the Client Portal are in relation to the secure online platform provided by VCM to you access via your login information.

Privacy Policy Consent

By using VCM and its affiliated services, you consent to the Privacy Policy and its information administration practices. VCM may provide additional disclosures in relation to the privacy policy. These documents will apply supplementary to VCM’s Privacy Policy. These disclosures may expand on information administration practices or provide further clarification for specific practices. If you disagree with or are not comfortable with any aspect of VCM’s Privacy Policy, you should immediately cease the use of VCM’s services.

Changes to the Privacy Policy

VCM reserves the right to alter and/or modify this privacy policy at any time. Please review this policy periodically in case of any changes. If any significant or substantive Privacy Policy Amendments are made, we will notify you by email.

Who Does VCM’s Privacy Policy Apply To?

VCM’s Privacy Policy applies to users of VCM’s services, including individuals, merchants, and legal entities. VCM’s users are those who use and/or purchase VCM or affiliated services. VCM services include, but are not limited to Digital Currency Exchange and Advisory services.

What Personal Information Do We Collect?

VCM only collects information that is vital to the provision of our services. The information that we may collect includes, but is not limited to:

(a) Identification Information: Full name, date of birth, age, nationality, gender, signature, phone number, home address, email, utility bills, passport number, driver’s license details, national identity card details, photograph identification cards, taxation ID numbers, Client Portal login credentials and activity logs.

(b) Financial Information: Transaction history, trading data, payment card numbers, bank account information, and your data stored on the Client Portal.

(d) Sensitive Information: Health, religious beliefs or affiliations, philosophical beliefs, criminal record, ethnic origin.

(e) Any other relevant information: Will generally depend on the circumstances, relationship, and factual situation as between VCM, as service provider, and you, the client.

Personal Information is collected during your application to use VCM’s services, automatically through the Client Portal, or from third-party sources like government databases or credit bureaus, as permitted by law.

You will receive this Privacy Policy or a link to it when registering for VCM’s services, which serves as notification of the collection of your personal information. For information collected after registration, VCM will notify you as soon as practicable, including the purpose of collection, entities it may be disclosed to, consequences of non-provision, and your rights to access and correct the information.

Sensitive information will only be collected with your explicit consent, as required by the Privacy Act 1988 (Cth).

Why Do We Collect This Information?

(a) To Create a Better Experience for Our Clients

The collection of data will allow us update and create new services that will better meet our client’s needs. At VCM, we endeavour to create a more personalised experience for our clients.

(b) To Protect Our Clients

The collection of transaction information will allow us to identify any suspicious activity that may lead to fraud or loss of funds.

We provide a designated service and are registered with AUSTRAC as required under Australian law. We also align our internal processes with international regulatory standards. Therefore, we treat the services offered by VCM as subject to both Australian and international regulatory obligations, which require us to collect your personal information. Information collected will be used to maintain compliance with International Know Your Customer, Anti Money Laundering and Counter Terrorist Financing Regulations, as well as any other regulations that are legislated in the future. Some of the information that is required to be collected pursuant to these regulations include personal identification information, personal usage information, financial information, and employment information.

(d) To Enforce our Internal Processes

It is important for VCM to regulate its services and its customers relating to the prevention and mitigation any potentially prohibited activities, enforcing our agreements with third parties, and violations of our internal processes. For these purposes, it is essential for VCM to collect user data.

If VCM is unable to process user information for these reasons, the consequence is the termination of your engagement as we cannot perform our services in accordance with our terms.

(e) Maintain your Registration as a Client

This will allow you to access your engagement safely and securely whenever and wherever you are.

(f) Ensure Quality Control

We store user information for quality control and staff training, to ensure we provide users with accurate information.

(g) Additional Service Offerings

We use information relating to your usage of VCM to provide better suggestions of our service offerings which may suit your needs and requirements. Should we provide you with marketing information in relation to any of the VCM services, you have the right to opt out by clicking on the unsubscribe button in the email or contacting us at compliance@vantagefo.com.

(h) To Provide and Maintain the Client Portal

The collection of data allows us to provide secure access to the Client Portal, display your portfolio, and facilitate the management of your account, including viewing deposits, withdrawals, and transaction history.

Who Will We Share Your Information With?

Information that VCM collects may or may not be used or disclosed to:

• Individuals, entities, organisations, as part of VCM providing their services to clients and includes, but is not limited to, experts, accountants, law firms, enforcement agencies, and other associated professionals;

• Persons the client has expressly authorised or consented;

• VCM’s associated commercial and business partners, which include, but are not limited to, professional advisors, related organisations, and business agents;

• Technology providers necessary for the operation of the Client Portal, which are bound by privacy obligations to protect your data, including cloud hosting and data storage providers or payment providers which may store data overseas;

• Comply with legal obligations or requirements;

• Develop business and commercial relationships;

• Respond to any enquiries where necessary; and

• All other matters, services, engagements, business developments, and commercial enterprises to the maximum extent permitted by law.

Where we disclose your personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient handles the information in accordance with the Australian Privacy Principles (for example, by imposing contractual obligations to maintain privacy and security standards equivalent to those required in Australia).

How Is Your Information Protected?

VCM considers our user privacy to be of great importance. That is why we have implemented multiple security measures to ensure that client data is secure, free from unauthorised access, alteration, disclosure, and destruction. For example, we implement the following security measures:

• Security procedures within our offices;

• Technological security measures in relation to the Client Portal such as two-factor authentication;

• IT security procedures including password protection and firewalls; and

• Mandatory confidentiality guidelines for all staff within the business.

VCM is dedicated to protecting your personal information through robust security measures, including encryption and, firewalls, and regular audits. While no system is entirely immune to risks, we will act promptly to mitigate any breach and comply with legal obligations. Your role in safeguarding account credentials is vital to maintaining security.

In the unlikely event of a data breach involving your personal information that is likely to cause serious harm, we will comply with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth). This includes promptly assessing the incident and, where required, notifying both you and the Office of the Australian Information Commissioner (OAIC).

Do we use cookies? (Website Usage Only)

Cookies are small files which a website uses to identify you when you come back to the site and to store details about your use of the site.

Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our websites.

VCM and our authorised third parties, may use cookies, and/or other tools to store and sometimes track information, such as analysing website traffic to help us provide a better website visitor experience. We may also collect certain information such as browser type, operating system, IP address, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

Obtaining Information Through Third Party Sources

VCM will occasionally obtain information about you through third party. Information will only be obtained as required permitted by applicable law. Examples of this include government and public databases and credit bureaus.

Automatically Collected Data

VCM receives and stores certain types of data whenever you interact with VCM’s services. Data collected automatically includes any category listed under personal usage information. Such data collected also includes data collected in relation to your Client Portal, such as login activity, IP addresses, and device information.

Why We Share Personal Information with Other Parties

VCM will never sell or rent your personal information. We will only share your information in the following circumstances:

• We share your information with third party identity verification services to prevent fraud. VCM shares this information to confirm your identity with relevant public records to prevent fraud. These third-party services will store your information; however, they will only use this information for purposes of identity verification.

• VCM may share your information with affiliated service providers. These affiliated services providers may include but is not limited to accountants, lawyers, and technology services providers. All affiliated service providers are contracted to solely use this information for purposes that affiliate with VCM.

• We may share your information with financial institutions which VCM has partnered with to process payments.

• We may share your information with companies or entities that we purchase or merge with. The new company or entity will uphold this Privacy Policy.

• We may share your information with law enforcement officials or other entities when required to do so under applicable law.

• We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.

How We Protect and Store Personal Information

VCM may hold sensitive information in our facilities or service providers located worldwide. This includes information accessed or stored through the Client Portal. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

VCM cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please note that each client plays a critical role in ensuring their own personal information.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, messaging services (i.e. Whatsapp) or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

We retain personal information for as long as necessary to provide our services and comply with legal and regulatory requirements (including Anti-Money Laundering and Counter-Terrorism Financing obligations). Typically, this means we will retain records for at least seven years after your relationship with us ends. After the required retention period, we will securely destroy or de-identify personal information, unless it is subject to a legal hold, investigation, or other legitimate business need.

Personal Information Rights

With VCM, you have a right to access, correct, object, and delete personal information.

You have a right of access to the personal information that we hold about you under Australian data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.

You have a right to access, correct, object, and delete personal information, including information displayed or stored in the Client Portal.

You can object to our use of your personal information at any time and you may have the right to object to our processing of some or all your personal information (and require them to be deleted) in some other circumstances.

If you wish to exercise any of these rights, please contact us as set out below.

How You Can Access or Change Personal Information

You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this by contacting us at compliance@vantagefo.com.

If your account is closed or terminated, VCM will keep your account information in our database for at least seven years for regulatory purposes. This ensures that those who are attempting to avoid fraud cannot achieve this by simply closing or terminating their account. When your account is closed or terminated, your information will not be used by VCM for any further purposes, including being shared to third parties.

General Data Protection Regulations (GDPR)

The General Data Protection Regulations (GDPR) apply to organisations who process data in the EU as well as organisations that offer goods or services to or monitors the behaviour of the people inside the EU. The GDPR applies to all information that can directly or indirectly influence an individual.

For individuals in the European Union, we process your personal information only where a legal basis applies under the GDPR. The legal bases we rely on include:

• Performance of a contract (e.g. to deliver our services to you).

• Compliance with legal obligations (e.g. anti-money laundering requirements).

• Legitimate interests (e.g. maintaining security of our platform and improving our services).

• Consent (where we rely on your explicit consent, e.g. for certain marketing or sensitive information).

If you withdraw consent, we will cease processing the relevant personal information unless another lawful basis applies.

VCM has prepared itself for the General Data Protection Regulations by providing information as to when VCM data is deleted, have provided a transparent overview of VCM’s use of the personal information it has collected, and detailed how you can exercise your privacy rights.

European Union Residents have the following rights:

1. You will have the right to withdraw your consent to process your personal information.

2. You have a right to request VCM provide you with a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others.

3. You have the right to request VCM update any of your personal information that you believe incorrect or inaccurate.

4. Right to Erasure

You have the right to request erasure of your personal information that:

a. is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

b. was collected in relation to processing that you previously consented, but later withdraw such consent; or

c. was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

5. Right to Data Portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

A “controller” Is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.

6. Right to Restriction of or Processing

You have the right to restrict or object to us processing your personal information where one of the following applies:

(a) You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.

(b) The processing is unlawful, and you oppose the erasure of your personal information and request the restriction of its use instead.

(c) We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defence of legal claims.

(d) You have objected to processing, pending the verification.

7. Restricted Personal Information shall only be processed with your consent or for the establishment, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

8. Notification of Erasure, Rectification and Restriction

VCM will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.

9. Right to Object to Processing

Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.

10. Automated individual decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

If you believe VCM has infringed your rights, we kindly request that you contact prior to lodging a complaint with the relevant authorities so that we may attempt to resolve the dispute. Please contact us at compliance@vantagefo.com. We aim to resolve all complaints within 30 calendar days of receiving them. If additional time is required due to the complexity of the matter, we will notify you in writing and provide an updated timeframe for resolution.

If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au

• Phone: 1300 363 992

• Mail: GPO Box 5288, Sydney NSW 2001

CONTACT US

If you have an enquiry regarding our Privacy Policy surrounding the collection or use of your personal information, including information accessed or stored through the Client Portal, you can contact us at compliance@vantagefo.com.