When we refer to “WayFinder” or “we” or “us“, we’re referring to WayFinder Capital Managers Pty Ltd (ACN 645 959 128) . References to the Privacy Act are to the Privacy Act 1988 (Cth), which we are bound by. We also refer to the Australian Privacy Principles (APPs), which are contained in the Privacy Act.
WayFinder recognises the importance of your privacy, and that you have a right to control how your Personal Information is collected and used. We know that providing Personal Information is an act of trust and we take that seriously. Unless you directly give us consent to do otherwise, WayFinder will only collect and use your Personal Information as set out below.
What is Personal Information?
Personal Information is information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
How we collect Personal Information
The main ways we collect Personal Information about you are:
- when you create or log into an account with us (including through our website (www.wayfindercapital.com.au) (Website) ;
- when you invest in one of our funds;
- in the course of administering or providing any of our products or services;
- when you contact us;
- when you subscribe to our email, newsletters or social media;
- when you apply for employment with us;
- when you access or use our Website, in which case our system automatically collects information (including through cookies) relating to your visit to that website, such as your IP address;
- as otherwise required to manage our business.
- where possible, have that person provide us with their Personal Information directly.
What information do we collect?
When you create an account on our Website, request services or information from us, or contact us, we collect Personal Information from you, which may include:
- your name, date of birth, age, gender, postcode and other demographic information;
- your contact details, such as your e-mail address, phone number, and postal and work address;
- if applicable, your organisation’s details such as the organisation’s name, your job position and business registration number; and
- information to verify the above, such as your driver’s licence or passport.
If you are applying to us for an employment opportunity, we may collect employment related information, such as job application information.
We also collect any other information you provide us from time to time, such as your preferences or opinions relating to our products and services, investment opportunities, and information relating to surveys, enquiries or complaints.
We may also collect other information from you in the course of your use of the Website, including:
- your location, if your computer or mobile device enables the sharing of your location;
- information relating to your use of the Website such as your browser type, IP address, requested URL, referring URL, browser language; the pages you view, and the date and time of your visit; and
If you invest with us, the financial institutions that facilitate the payment may collect Personal Information from you for the purposes of processing your payment. We are not responsible for any personal information these third parties may collect. You should review their privacy policies for further information.
Why we collect, hold, use and disclose your 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 provide you with a service which you have requested;
- to operate, protect, improve and optimise our Website, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to verify your identity and create, maintain and administer your account(s) with us;
- to process and validate investments you make with us;
- to generally manage and administer our products, services and business, including providing training and performing administrative functions such as billing and accounts and records management;
- for compliance and regulatory purposes in relation to any investments you make with us;
- for investment and research purposes;
- provide you with a better service experience with more appropriate content and investment opportunities;
- to create an information database and associated content for use as part of our investments;
- to assess, monitor, log and action security and other incidents relating to use of the products and services we provide, which may involve disclosure of Personal Information to law enforcement agencies, government bodies and insurers;
- to protect the rights, property or personal safety of another member of the public or us;
- to communicate with you;
- to consider job applicants for current and future employment;
- other purposes related to the above purposes or as required or permitted by law, including to comply with our obligations at law;
- for any purpose disclosed to you and to which you have consented; and
- for any purpose that you would otherwise reasonably expect.
If you do not provide the requested information, we may not be able to provide you with the services you request, or give you access to or full use of sections of our Website.
Disclosing information to third parties
We recognise the trust you place in us when you share your Personal Information. In order to operate the Website or our investment platforms, and provide associated services, we may share your Personal Information with:
- our related entities, agents and organisations and their personnel;
- our service providers, contractors and advisers including:
- information technology service providers;
- communications carriers and exchange providers;
- data analytics providers;
- research partners, including those performing surveys or research projects in partnership with us or on our behalf;
- service providers that assist us to enhance the safety and security of our website;
- external business advisors or consultants (such as auditors and lawyers); and
- the entities in which you have chosen to invest through us. This may include your name, address, email address, date of birth and other information as required by law;
- companies that you are associated with (for example, your employer or financial planner), and employees of those companies; and
- other third parties and for other purposes where we are required or permitted by or under law to do so (including where you have provided your consent).
Where there may be a change in who controls WayFinder, we may disclose your Personal Information to an entity seeking to acquire all or part of our business and their advisors.
Disclosing information overseas
If in future we do propose to disclose personal information overseas, we will do so in compliance with the requirements of the Privacy Act (1988) (Cth) (Privacy Act). We will, where practicable, advise you of the countries in which any overseas recipients are likely to be located.
If you do not want us to disclose your information to overseas recipients, please let us know.
In order to give you the most worthwhile experience of the Website, our investment opportunities, and our associated services, we may use your Personal Information to send you information and updates about the Website, investment opportunities and the services we offer.
If you give your consent, we may also:
- provide you with other information about other products, services or social initiatives which you may be interested in;
- send you details of other parties’ products and services, or permit other parties to send you information about products or services which may be of interest to you.
If you receive marketing material from us but do not wish to continue receiving it, you may remove your name from our list by contacting us and asking to be removed from our mailing list or, in the case of emails, clicking the “unsubscribe” link at the bottom of the message. Please allow up to 5 working days for this request to be processed.
Access to the information we hold
You can request access to the Personal Information we hold about you by making a request to us. We will provide you with access unless we are legally authorised not to do so.
Correcting and deleting the information we have about you
If at any time you wish to correct Personal Information that is inaccurate or out of date or to have your Personal Information deleted, please contact us.
We will take all reasonable steps to correct or delete information in response to such a request. If there is a reason that we cannot make that correction or deletion (such as for legal reasons), we will inform you of that reason.
Storage and security of your Personal Information
We endeavour to take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate and up to date.
For security purposes, we will store your personal information in physical storage, in a locked area or secured area. Where we store personal information in electronic storage, we use up-to-date computer storage facilities and network security systems. In both cases, access to your personal information is restricted to staff or third parties properly authorised to access your personal information.
You should note that the internet is not a secure method of transmitting information and, as such, we are not responsible for the security of any information sent or received over the internet.
Third party websites
Our Website contains links to third party websites and the contact details for entities not directly linked with us including investment opportunities. You acknowledge that these third party websites and entities are not under our control and we are not responsible for their conduct.
- Name: Nima Sedaghat
- Telephone number: 0402 931 525
- Postal address: Unit 5, 110 Hay Street, Subiaco, WA 6008
- Email address: firstname.lastname@example.org
If you have a complaint or concern about how WayFinder deals with privacy, please contact us using one of the methods set out above. We will consider and respond to all questions and complaints, and will respond within a reasonable time in writing. If you are not satisfied with how your complaint or concern is resolved, you can refer your complaint to the Privacy Commissioner using the contact details below:
- Website: www.oaic.gov.au
- Email: email@example.com
- Phone number: 1300 363 992
Or write to:
- Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001