Stake (“we”, “our”, “us”) is the trading name of:
Stakeshop Pty Ltd (ACN 610105505), an authorised representative (Authorised Representative No. 1241398) of Sanlam Private Wealth Pty Ltd (Australian Financial Services Licence No. 337927) (Sanlam) and an authorised representative (Authorised Representative No. 1241398) of Airwallex Pty Ltd (Australian Financial Services Licence No. 487221) (Airwallex). Stake is not authorised by Airwallex under Airwallex’s AFSL to arrange for clients to be issued with securities as Airwallex is not authorised under its AFSL for this purpose. Stake is not authorised by Sanlam under Sanlam’s AFSL to arrange for clients to be issued with a non-cash payment facility as Sanlam is not authorised under its AFSL for this purpose.
If you have any questions about this document please email us at email@example.com
We comply with the Australian Privacy Principles (APPs) when dealing with your personal information. This policy does not limit or exclude any of your rights under the APPs. If you wish to seek further information on the APPs, see www.oaic.gov.au
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
What personal information do we collect?
We may collect the following types of personal information:
- Mailing or street address;
- Email address;
- Telephone number and other contact details;
- Age or date of birth;
- Credit card information;
- Bank account details;
- Details or images of your government issued identification, such as your passport, drivers licence, or other forms of ID or reference numbers relating to you, such as your tax file number.
- 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 app or indirectly through your use of our website or app 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. We may collect this information when you:
- Onboard on our website or app;
- Communicate with us through correspondence, email, or when you share information with us from other social 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.
Collecting your information
By law, we can only collect information that is reasonably necessary to provide our services.
Our reason for collecting necessary information may be:
- We, and/or our partners, need it in order to provide our services.
- To meet our legal or regulatory responsibilities.
- To adhere to our contracts and agreements, in order to provide our services.
Where you’ve agreed to us by providing your information, you indicate you’re happy for us to use your personal information where lawful and necessary.
Why do we collect, 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 services (as set out in our Terms & Conditions).
- to operate, protect, improve and optimise our website and services, 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
- to consider your employment application.
- We may 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.
Do we use your personal information for direct marketing?
To whom do we disclose your personal information?
- Our employees and related bodies corporate;
- Our existing or potential third party suppliers and service providers in connection with providing you products or services or those existing or potential suppliers and providers improving the products and services provided to you. This may include (without limitation) payment systems operators (e.g. merchants receiving card payments or funds transfer), foreign exchange providers, brokers and dealers, and partners who facilitate the deposit and custody of funds;
- Other existing or potential third party suppliers and service providers (including providers for the operation or optimisation of our websites and/or our business or in connection with providing you, or improving our, products and services);
- Our existing or potential agents, professional advisers, 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) may be 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 (including for the purposes of AML/CTF collection and verification).
Disclosure of personal information internationally
Due to the international nature of our services, we use partners and providers that may be based overseas and we may be required to share your information with them. When you provide your personal information to us, you consent to the disclosure of your information outside of your country of residence and acknowledge that we cannot guarantee that such partners or providers will handle your personal information in compliance with the laws and practices of your local market. 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 such principles and legislation that we adhere to.
The data we collect from you may be transferred to and stored somewhere outside of your local jurisdiction if we have specific agreements and/or due diligence in place. In certain circumstances it may also be processed by staff outside of Australia and those who work for us or a select third party.
Cookies are small text files that store information on your device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. 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.
- enable us to collect data necessary for improving your Stake experience;
- keep track of how often users come to our website and see how they interact with it;
- let users chat to us and ask questions via our Portal; and to
- deliver advertising and content targeted to your interests on our services and other websites.
You can elect to disable all cookies, or to disable certain cookies, however our websites may not work as intended for you if you do so.
Security & storage of information
We may hold your personal information in either electronic or hard copy form. We store any electronic information on secure servers through Amazon Web Services.
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 encrypt all data and have it stored in secured facilities. However, we cannot guarantee the security of your personal information.
As your personal information is available inside the Stake app or website, we require you to set a strong password when creating an account and either set up multi-factor authentication or use a one-time password sent to your email upon each login. We request that you do not share your password with anyone and it remains confidential.
Length of storage
By law, we need to store information about you for 7 years.
Ordinarily, we will not hold your personal information for more than this period after our relationship with you has ceased, unless required by law or due to an ongoing claim.
Under all circumstances, you have the following rights:
- Access: You have the right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; and details about how and why it is being used.
- Correct and update your information: If any of the information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, you are entitled to request any necessary amendments be made.
- Opt-out of direct marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes.
- Make a complaint: If you have any complaints or concerns about our handling of your personal information please do get in touch with us and we will do our best to resolve these. You can contact us at firstname.lastname@example.org. Please see our consolidated “Making a complaint” section below for more detailed information.
If you would like to exercise any of these rights, you can log into your account or email us at email@example.com. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
Making a complaint
If you think we have breached any of the Australian Privacy Principles, as it applies to you, or you wish to make a complaint about the way we have handled your personal information, you can contact us at firstname.lastname@example.org
Please include your name, email address and/or telephone number and clearly describe your complaint. For security reasons, we can’t deal with your request if we are not sure of your identity, so we may ask you for proof of your ID. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.
If you think that we have failed to resolve the complaint satisfactorily, you can telephone the Office of the Australian Information Commissioner on hotline 1300 363 992.
Effective: 1 June 2021