Global Funding Partners Pty Ltd trading as Enable Funding ABN 84 602 324 658 is committed to protecting and respecting your privacy, and takes its obligations under the Privacy Act 1988 (Cth) very seriously. As a result, Enable Funding has implemented practices, procedures and systems to comply with its legal obligations and, in particular, to:
- maintain the confidentiality and security of personal information it collects and holds; and
- manage its systems, practices and procedures in an open and transparent way.
By “personal information”, we mean information or an opinion about an identified individual or about an individual who is reasonably identifiable from the information. This Policy sets out how we handle personal information we collect and hold.
1. What personal information does Enable Funding collect and hold?
The kinds of personal information we may collect and hold are:
- your name, address and contact details (including email address);
- credit card and bank account details;
- financial histories (including any bankruptcies);
- personal information in answers to security log-in questions and survey questions (including investor status); and
- user IDs and passwords (including details of other social media accounts such as Gmail, Facebook or LinkedIn, and provided as a proxy for Enable login details or other purposes).
Also, from time to time we may, for anti-money laundering purposes, need to collect from you copies of identification papers (such as your passport, driver’s licence, notices from utilities and property deeds) which will contain personal information.
We may also, when you visit our site, collect information about your computer (including your IP address, operating system and browser type) and the date and time of your visit.
We do not keep all of the above information for all people who contact us, or with whom we deal. In many cases, we may have only a few pieces of data relating to any particular person.
2. Why does Enable Funding collect and hold personal information?
We collect and hold personal information for a variety of purposes – and different kinds of personal information are used for different purposes.
In each case, however, the personal information we collect and hold is reasonably necessary for our functions and activities, including to provide you with services you would expect from us. These purposes are:
- to provide you with news and information, products or services that you request from us or which we believe may interest you;
- for purposes necessary or incidental to providing you with products and services that you have ordered or requested from us;
- to personalise and customise your experience when using our site (including so that our site is presented in the most effective manner for you and for your computer);
- to communicate with you (including by email, mail or telephone, and including in relation to changes and improvements to our products and services);
- to ensure the quality of services offered by Enable;
- to manage and enhance our products and services;
- for event registration and invitations;
- to facilitate any payment you have agreed to make for our products or services;
- for system administration;
- for network analysis and security;
- to allow you to participate in interactive features of our site that may be available;
- to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are, have been or may be engaged in any unlawful activity; and
- as required or permitted by any law (including privacy legislation).
3. How does Enable Funding get the personal information it collects and holds?
Enable only collects personal information by fair and lawful means, including when people:
- fill in contact, registration and order forms on our site or via our electronic marketing service provider site(s)
- order or download files or other products from us;
- respond to surveys;
- subscribe for shares using our share application form and Anti-Money Laundering and Counter-Terrorism Financing checklist;
- post material to our site or to social media that we use (such as Facebook and Twitter);
- contact us for assistance or with questions, or report problems with our site or with a product;
- contact us directly, other than through our site or social media (for example, by email); and
- are referred to us indirectly because they are likely to be interested in an offer, having regard to previous contact between the person making the offer and that person, or some professional or other connection between the person making the offer and that person (in accordance with section 708 of the Corporations Act).
We prefer to obtain any personal information we collect directly from you. In some cases, however, it may be unreasonable or impracticable to obtain personal information directly, and we may obtain that information from someone else, including our agents and service providers.
If you are concerned about what personal information we may hold about you, please see below for information on how you can access and (if necessary) correct that information.
4. Can I interact with Enable Funding anonymously or under a pseudonym?
In many cases, you will need to provide your real name when interacting with us. This will particularly be the case when you are transacting shares through the site.
You may however – wherever lawful and practicable – use a pseudonym (or simply not identify yourself) when dealing with us. For example, if you have a complaint or concern about our site, or a general question about any of our products or services, you are welcome to contact us without identifying yourself. In some cases, however, if you do not provide us with information, we may not be able to provide you with our products or services, or respond adequately to you.
For clarification on when you must identify yourself, please contact our Privacy Officer. (You may use a pseudonym – or simply not identify yourself – when making such an enquiry.)
5. Who has access to my personal information?
Generally, only our staff will access your personal information, and then only on a “need to know” basis. We may, however, also disclose your personal information:
- to people who work for or with us or for one of our suppliers, who may be engaged in, among other things, filling orders, processing payments, marketing, research and providing support services;
- to protect the rights, property, health or safety of Enable or its staff, customers or others (including exchanging information with other companies and organisations to protect against fraud and to reduce credit risk);
- to our agents, business affiliates, joint venture entities and other partners or sponsors (including any holding company or subsidiary, our ultimate holding company, and its holding companies and subsidiaries, as defined in section 50 of the Corporations Act 2001 (Cth));
- as part of a sale (or proposed sale) of all or part of our business;
- to anyone else that you specifically authorise us to receive information held by us; and/or
- as otherwise required or permitted by law (including under privacy legislation).
6. How can I access (and, if necessary, correct) personal information that Enable Funding collects and holds about me?
If you want to review (and, if necessary, correct) personal information that Enable may have collected and holds on you, please contact our Privacy Officer. We will respond to your requests to access and to correct your personal information as soon as possible (but in any case within a reasonable period).
7. How can I complain about Enable Funding if it breaches any applicable privacy principles or any registered code that binds it?
Contact our Privacy Officer if you have any complaints about breaches by Enable of any applicable privacy principles or of any registered code that binds it.
8. How will Enable Funding deal with complaints I might have about breaches of applicable privacy legislation or any relevant registered code?
We will treat any complaint about a breach of privacy legislation or any relevant registered code seriously, and will investigate any breach of which we become aware – including how it occurred and how best to prevent such a breach occurring again.
9. What steps does Enable Funding take to secure personal information?
We take all reasonable steps to ensure that your personal information is treated securely and in accordance with this Policy and is not subject to misuse, interference or loss, or unauthorised access, modification or disclosure.
For example, apart from using secure servers (with application level security and restricted logins), we implement firewalls. Where relevant, we also impose limits on who can access personal information. Please note, however, that the transmission of information (including over the Internet) is never completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information – particularly while it is being transmitted to us – so any transmission is at your own risk and we cannot accept responsibility for misuse or loss of, or unauthorised access to, your personal information where the security of information is not within our control.
If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
If we have given you (or where you have chosen) a password which enables you to access our services or parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
10. Does Enable Funding disclose personal information to people or organisations outside Australia?
Enable holds personal information securely on servers located in Australia and processes some email and newsletter communications through ActiveCampaign, which is based in the United States.
We will not transfer your personal information overseas to a country that is not subject to a comparable privacy scheme or to an organisation that does not implement privacy obligations at least comparable to the obligations that apply in Australia.
Please contact our Privacy Officer if you have any questions, comments or requests in relation to this Policy.
12. Who do I contact at Enable Funding about privacy issues?
Contact our Privacy Officer by email on firstname.lastname@example.org or at the following address:
The Privacy Officer
125 Rundle Street
Kent Town SA 5067
If you have any concerns about privacy issues, including in relation to how Enable is dealing with your personal information or how it is being held.
Please also contact our Privacy Officer if you want to review and/or correct any personal information we hold about you, or if you receive communications purporting to be connected with Enable or our services that you believe have been sent other than in accordance with this Policy or in breach of any law.
Enable Funding, “we“, “us” and “our” means Global Funding Partners Pty Ltd trading as Enable Funding ABN 84 602 324 658, together with its successors and assigns.