Virgo Australia Privacy Policy

Last updated: September 18, 2022

Virgo Australia Pty Ltd. and its subsidiaries and related entities (“we”, “us” or “our”) are committed to protecting and respecting your privacy.

This policy together with our Terms of Use (https://virgo.co/au/public_front/au/termsOofService.html) and any other documents referred to in them set out the basis on which any personal data we collect about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By registering for an account with us, you accept and consent to the practices described in this policy.

1. Information We May Collect About You

 The types of personal data we collect include as follows:

a) Contact information, such as your name, mailing address, telephone number, and email address;

b) Financial information, such as bank account numbers, credit or debit card numbers and digital asset account information;

c) Government identification numbers, such as your government-issued identification number;

d) Biographic or demographic information, such as your date of birth, gender, occupation, employment status and any other information you choose to provide about yourself;

e) Information about your interests, preferences and opinions relevant to our business and operations;

f) Information about transactions you complete using our services, including the amount of funds associated with a digital asset transaction, the type of transaction executed, and other related information;

g) Information about your communications, interactions and other dealings with us or relevant to our business, including any inquiry, request, complaint or application, and any contact by email, telephone or online.

h) technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, your device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

i) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

2.How We Collect The Information

We collect and retain personal data you provide directly to us. For example, we collect information about you when you create an online account, complete a transaction, fill out a form, respond to surveys, post messages to our forums or otherwise communicate with us.

We also collect personal data by other means including from:

a) third parties such as those listed under ‘Disclosure Of Your Information’ below;

b) public sources;

c) records of your interactions with us and activity relating to our operations, premises and facilities (for example records from CCTV, building access, telephone recordings and use of our site and IT resources); and

d) conducting analysis of information we already hold and generating new reports, commentary and insights.

3.Cookies

Our site uses cookies to remember your preferences and settings when you navigate through our site, to collect information about your device (such as your IP address or device identifier) and how you use our site (such as the pages you visit and the time spent on those pages as well as the website you visit before and after you visit our site) and to identify unique visitors to our site. We use this information to help improve our site and the services and information we offer. We also use this information to understand the effectiveness of our advertising.

We use both session cookies and persistent cookies on our site. A “session” cookie lasts for a single browser session only and is deleted when the user closes the web browser. A “persistent” cookie remains on the user’s device (even while powered off) until it expires or is deleted.

You may be able to control cookies using your browser settings. For example, you may be able to set your browser to block or delete cookies, or to notify you before a cookie is set. If you block cookies you may not be able to use all of the features of our site. By continuing to use our site without changing your browser settings, you consent to our use of cookies as described above.

4.Uses Made Of The Information

We collect, store, use and disclose your personal data for purposes including the following:

a) to carry out our obligations arising from any contracts entered into between you and us, and to provide you with information, products and services that you request from us;

b) to provide you with information about other products and services that may be of interest to you. This information may be provided on an ongoing basis by telephone, email, online and other means. You can opt out at any time on request, see ‘Contact Us’ below;

c) to notify you about changes to our service;

d) to administer our site and for internal operations including troubleshooting, data analysis, testing, research, service development, statistical, records management and survey purposes;

e) to improve our site and services and ensure that content is presented in the most effective manner for you and for your computer;

f) to allow you to participate in interactive features of our service, when you choose to do so;

g) to protect and maintain the safety, security and rights of our site, business, staff, customers and other stakeholders;

h) to measure or understand the effectiveness of advertising we serve to you and others, to deliver relevant advertising to you and to better understand your needs, preferences and interests;

i) to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;

j) to verify your identity and information;

k) to facilitate any business purchase or potential business purchase of or by our business, including any related transitional and business integration activities;

l) to comply with our legal obligations, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth); and

m) as otherwise required or permitted by law.

We may not be able to do these things without your personal data. For example, we may not be able to provide our services or deal with your request.

5.Disclosure Of Your Information

For any of the purposes set out above, we may share your personal data with:

a) any member of our corporate group, which means our subsidiaries, our ultimate holding company and subsidiaries, e.g. to provide a product or service that you have requested or where the member group company is acting as our service provider.

b) AUSTRAC and other relevant authorities, including for purposes relating to anti-money laundering and terrorist financing legislation, securities regulation and guidance provided by relevant regulatory bodies.

c) Refinitiv which provides us with sanctions, politically exposed persons and negative media data which we use to remain in compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and similar laws;

d) analytics and search engine providers that assist us in the improvement and optimisation of our site;

e) Jumio Corporation (“Jumio”), who we have engaged to provide identity verification services for us. To verify your identity, your name, address, date of birth and any other relevant identifiers will be matched with the data from the government issued photo ID submitted to us through Jumio. Jumio will also collect, on our behalf, pictures or videos of yourself taken as part of Jumio’s proprietary liveness and similarity checks. As part of Jumio’s identification services, Jumio may utilize machine learning and face-based algorithms to verify you are the same person as the individual shown in the provided government issued photo ID. By clicking "Complete Automatic Verification" and submitting your information, you confirm your consent to Jumio collecting, using, disclosing, and storing your personal data for the purpose of this verification;

f) your and our representatives and professional advisers;

g) our other service providers including IT, HR, data, marketing, risk management and financial service providers; and

h) other parties as required or permitted by law.

We may disclose personal data in other circumstances where permitted or required by law.

6.How We Protect The Data We Collect

Personal data is maintained on our servers or those of our service providers. We implement reasonable security practices and procedures to help protect the confidentiality and security of your information, including any personal data, whether stored in physical or electronic form. We protect your information using reasonable physical, technical and administrative security measures, including by limiting access to your information to employees with a need to know such information. We and our service providers and business partners may be located outside of your country of residence.

Please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7.Access to Information

You have the right to request access to, or correction of, the information held about you. We will respond to your request for access to or correction of information we collect about you within the time frame required by applicable law.

8.Changes to Our Privacy Policy

If we make material changes, we will do so in accordance with applicable legal requirements, and we will post a notice on our website alerting you to the material changes prior to such changes becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

9.Contact Us

To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personal data in our possession that you have previously submitted using our services. If you have any questions or concerns regarding this Privacy Policy, please contact our Privacy Officer by submitting your communication via email to [email protected].