Privacy Policy
VEMA Trader Pty Ltd ACN 649 243 443 (“VEMA”, “we”, “our” or “us”) is committed to the protection of your personal privacy within the scope of applicable law. This Privacy Policy covers our treatment of personal information that we collect, use and disclose.
VEMA is a web-based trading solution that offers you the ability to visualise and execute trade plans and analyse data in a comprehensive trading journal so that you can identify gaps and opportunities when trading cryptocurrencies.
We can update this Privacy Policy from time to time with or without notice to you. The most current version will be located on our website and is also available by contacting our Privacy Officer by email detailed below. We recommend that you visit our website regularly to keep up to date with any changes.
By using our website, or by providing any personal information to us, you consent to the collection, use and disclosure of your personal information, as set out in this Privacy Policy.
Types of personal information collected
The types of personal information that we collect and hold will vary depending on your dealings with us. This information can include any or all of the following:
- name, username, email address(es), residential address(es), telephone number(s) and other contact details;
- electronic address(es);
- payment information (such as credit card or bank details);
- other personal information required to provide our services or benefits;
- transaction details relating to your use of our services or benefits;
- information relating to an individual’s access of our websiteincluding IP address, device type, browser information, time and date of access, location data, webpages visited, and other website related information including through the use of internet cookies; and
- any other personal information an individual provides, or authorises us to collect, as part of the individual’s interaction with us.
We will not collect sensitive information from you or any third party.
From time to time, you can provide us, and we can collect from you, personal information of a third party. Where you provide the personal information of a third party, it is your responsibility to ensure that those persons are aware of this Privacy Policy, understand it and agree to accept it.
You do not have to provide us with any personal information, however if you do not do so we can not be able to provide you with the products, services or benefits you have requested.
How we collect personal information
Generally, we collect personal information directly from you, in a variety of circumstances in the course of our business, including:
- when you submit information through our website or app including online forms;
- in person;
- by email;
- over the phone;
- on social media;
- in the course of providing you with our services or benefits;
- through the use of our website or app;
- when individuals do business with us; or
- when you have other dealings with us.
We can also collect personal information from third parties in situations including:
- where the individual has consented to that collection;
- we are permitted by law to collect that information;
- through our related bodies corporate;
- through our business partners;
- through other third parties, for example third parties who supply services to us; or
- or if it is unreasonable or impracticable to collect the information directly from the individual.
The purposes for which we collect, use and disclose personal information
We collect personal information as reasonably necessary to carry out our business, to assess and manage your needs, and to provide our services. We will use the personal information we collect for the purpose disclosed at the time of collection, or as otherwise as set out in this Privacy Policy. The purposes for which we can collect, use and disclose personal information include:
- to establish and maintain your relationship with us;
- to contact you or answer any inquiry you make;
- to provide our services including by disclosing information to third parties we engage to assist us to provide these (including service providers used for data processing, reporting features and other information technology services);
- to develop new products or service features;
- to generate data and reports on an aggregated, non-personally identifiable basis for both internal and third party use, but subject to any applicable laws (for example, we can show trends relating to the general use of our products, services or benefits);
- to improve, research, develop and expand our services or benefits;
- to procure the services;
- administrative, management, and operational purposes including billing, payments, training, security, and risk management;
- to manage relationships with those we interact with, including responding to requests for information and other general inquiries;
- to manage, plan, advertise and administer programs, events, and competitions;
- to keep individuals informed about our business including any activities, events, and services;
- to ensure a safe working environment for our personnel;
- For recruitment processes (including for volunteers, internships, and other employment opportunities);
- as required by law, order of a court, tribunal or regulator or if we reasonably believe that the use or disclosure of the information is reasonably necessary for enforcement related activities; or
- other purposes permitted or required by law, a court, tribunal, or regulator.
We can also disclose your personal information to third parties who work with us in our business to provide, promote or improve the products, services or benefits we provide or you have otherwise requested or are interested in, such as:
- third party service providers, suppliers and contractors (such as for accounting, invoicing and billing purposes or other software or service providers used in our business);
- marketing consultants and promotions companies;
- website hosts; and
- consultants and professional advisers.
Each third party that we disclose your personal information to may have their own privacy policy that governs how that third party will collect, use and disclose your personal information. Any third party privacy policy, for example TradingView Inc.’s Privacy Policy, is not related to this VEMA Privacy Policy.
We will not use your personal information for any other purpose without first seeking your consent, or where authorised or required by law.
Direct marketing
We will also use and disclose your personal information (other than sensitive information) to send direct marketing to you from:
- us;
- our related bodies corporate; and
- third parties who provide services to us.
The direct marketing can relate to:
- our products or services;
- the products and services of other parties; and
- new developments we believe can be of interest to you.
You can opt-out of receiving this direct marketing through the unsubscribe function that will be made available to you with each direct marketing communication.
How we hold, store and protect personal information
We take reasonable steps to protect all personal information that we hold from misuse, interference, loss and from unauthorised access, modification, or disclosure. We store personal information in a combination of computer storage facilities on the cloud, paper-based files and other records and we take reasonable precautions to store an individual’s personal information in reasonably secure infrastructure.
We maintain reasonable physical security over paper and electronic data. We also maintain reasonable computer and network security systems. We take reasonable steps to destroy or de-identify information that we no longer require.
The internet is not a secure method of transmitting information. Accordingly, other than where we use secure socket layer technology (SSL) to ensure information is securely transmitted and processed, we cannot and do not accept responsibility for the security of information you send to or receive from us over the internet, or for any unauthorised access or use of that information.
Do we send personal information overseas?
We will not transfer your personal information outside Australia.
How you can access your personal information
We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please contact our Privacy Officer by email detailed below.
An individual can access and seek the correction of the personal information we hold about them by contacting us using the contact details set out below. At your request, we will provide you with a copy of any personal information which we hold about you, unless an exception under the Privacy Act 1988 (Cth) applies. We can charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.
We can decline a request to access or correct an individual’s personal information in certain circumstances in accordance with the law. If we refuse a request, we will provide a reason for our decision.
Cookies
Our website use cookies to track user traffic patterns and to better serve you when you revisit a website. A cookie is a small data file that a website can write to your hard drive when you visit it. A cookie file can contain information, such as a user ID which the website uses to track the pages you have visited. You can refuse all cookies by turning them off in your browser. However, full functionality for our websites requires the use of cookies.
Information is also generated whenever a page is accessed on our website that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate our website performance.
How to contact us or make a complaint
We can be contacted at any time at the details set out below if an individual has any questions or concerns about this Privacy Policy or about the way in which we have handled their personal information, if you wish to update information we hold about you, or if you wish to make a complaint about our collection, use or disclosure of your personal information under this Privacy Policy.
We will promptly acknowledge and investigate any complaint about the way we manage personal information.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint but more complex matters can take longer.
If an individual is not satisfied with our response to a complaint, a complaint can be made to the Office of the Australian Information Commissioner by using the contact details at www.oaic.gov.au.
The Privacy Officer
Name: Richard Morwood
Email: privacy@vematrader.com
Last updated February 2022.
