HotCopper Privacy Policy

Introduction

HotCopper is owned and operated by Report Card Pty Limited ACN 092 598 859 (“HotCopper”). HotCopper recognises that your privacy is very important and should be treated with respect. We take steps to protect any personal information received by us that can be used to identify an individual user (“you”, “your”, “User”) in accordance with the Privacy Act 1988 (Cth) (Privacy Act).

We are governed by the Australian Privacy Principles which are contained in the Privacy Act and other applicable privacy legislation. Before you provide us with any personal information, you should carefully read through this policy so that you understand and are comfortable with exactly how we will collect, use, store and disclose any personal information you share with us.

By using our website and/or the services covered by this policy and providing your personal information to us, you agree that we can communicate with you for the purposes set out in this policy, including electronically regarding security, privacy and administrative issues relating to your account information.

Who is HotCopper?

When we refer to “we” (or “our” or “us”) in this policy, that means Report Card Pty Ltd and all its owned subsidiaries. Our headquarters are in Australia and our website(s) are accessible to an international audience. We are part of a group of companies owned by The Market Ltd. A reference in this policy to the "Group" is a reference to The Market Herald Ltd and its related bodies corporate.

We provide a platform for investors to discuss investment opportunities and topics surrounding the Australian stock market. We also provide promotion and marketing services for businesses that wish to reach our audience.

Open and transparent management of personal information

We make our privacy policy available on our website located at https://hotcopper.com.au/help/privacy/ and we can also provide a hard copy version upon request. If you would like more information, a hard copy of this policy, or to contact us in relation to your rights set out below, please contact us using the following details:

• Name: Report Card Pty Ltd (ACN 092 598 859)
• Address: PO Box 5558, St Georges Terrace, Perth WA 6831
• Phone: 08 6169 3100
• Email: [email protected]

What personal information might we collect from you?

Personal Information

“Personal information” as used in this policy means information or an opinion about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion.

We may collect personal information on our websites and to perform our services such as:

• your name, title and pronouns;
• your contact details (including your contact numbers and email address);
• your age or date of birth;
• your demographics (such as your postcode);
• location data;
• your password(s);
• your interaction(s) with our website and services;
• your s. 708 sophisticated investor status;
• the sensitive information of the type referred to below; and
• other types of personal information provided by you in correspondence with us or that we collect in the course of our relationship with you.

Sensitive Information

In addition to the types of personal information set out above, we may, during the course of surveys or competitions administered by us, by our Group, or affiliated third parties, collect sensitive information from you, but only if volunteered by you and with your consent.

You can choose not to actively volunteer this personal information to us, our Group, or the relevant affiliated third parties. However, if you do provide this personal information to us when asked or prompted, including sensitive information, you provide your consent to us collecting, storing, using and disclosing that personal and/or sensitive information as necessary for the purpose of collecting it.

Anonymity and pseudonymity

In most circumstances, it is impractical for you to communicate with us anonymously. We need to identify you to assist you effectively. However, in circumstances where it is lawful and practicable to do so, we will provide you with the option of not identifying yourself, or using a pseudonym, when you communicate with us.

Collection of solicited personal information

We only collect your personal information by lawful and fair means where reasonably necessary for our functions and activities. We collect personal information which:

• you provide to us in the course of registering for an account to use our website and services, engaging with our website and services, or to apply for positions with us;
• you provide to us in physical or electronic documents or correspondence;
• you provide to us in the course of updating or changing your details;
• you provide to us during promotional signups, sweepstakes or contest entries;
• you provide to us during software downloads;
• is provided to us by third parties who have disclosed that information to us with your consent or otherwise in accordance with the Privacy Act (and only if it would be unreasonable or impracticable to collect the information directly from you); and
• you provide to us to disclose with your consent to third party service providers for an activity or service in relation to our websites and services.

We may also collect personal information about you from legitimate third party sources, including market researchers such as Nielsen and Roy Morgan, that share data and personal information in circumstances where it is lawful and/or you have given permission for them to do so.

Subject to certain exceptions under the Privacy Act, we only collect sensitive information about you if you consent to the collection of the personal information and the personal information is reasonably necessary for our services. The provision of sensitive information to us on a voluntary basis will be taken to be consent for this purpose.

Collection of unsolicited personal information

From time to time, we may receive unsolicited personal information about you. Unsolicited personal information is information we may receive from you which is not in response to a request by us for that information or information that we may receive from you in error.

Where we receive unsolicited personal information about you (either directly from you or from a third party), we will consider, within a reasonable period, whether we could have collected that personal information from you had the personal information been solicited.

Where we determine that we could have collected the unsolicited personal information had it been solicited, we will store, use and disclose that personal information in the manner set out in this policy.

Where we determine that we could not have collected the unsolicited personal information had it been solicited, we will destroy or de-identify that unsolicited personal information as soon as practicable, provided it is lawful and reasonable to do so.

Security and integrity

We take reasonable steps and measures to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These reasonable steps and measures include:

• the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all personal information that we collect; and
• the use of password access, VPNs, firewalls and secure servers.

We also take reasonable steps to destroy and permanently de-identify personal information which we hold and which is no longer needed for the purposes described in this policy.

How we collect, use and disclose your personal information

Generally, we collect, use and disclose your personal information and otherwise process your personal information for the primary purpose of conducting and supporting our website and the provision of our services to you, including to establish, maintain and enhance our relationship with you. Without limiting the foregoing, there are six main categories in which we may collect, store, use or disclose your personal information, being:

• Account creation;
• Communication;
• Optimisation;
• Marketing and advertising;
• Moderation; and
• Sharing features.

We provide below some specific examples of how we use the personal information we collect. These are in addition to anything that we are required or authorised by law to do or which we communicate to you in a separate privacy collection notice.

Account creation

• To provide you with an account to use our websites and services.
• To provide you with certain other content, products and services.

Communication

• To contact you should we need to
• To provide you with customer support and useful information in relation to HotCopper's website and services.
• To share communications such as newsletters, updates, special offers and advertisements, which may be of interest to you, and also to advise you of other Group or third party products, services, offers, surveys, promotional signups, sweepstakes, contests, competitions or events which may be of interest to you.
• To respond to users’ requests, enquires and complaints.
• To seek your opinions and feedback about our website and services and to conduct other market analysis and research and development.
• To connect you to our websites and services (including our online discussion forum), as well as to connect you to products and services of our partners and licensees.

Optimisation

• To provide, improve and maintain our websites and services.
• To develop new products and services.
• To personalise and display communications, advertisements and other content for you.
• For our administrative functions and internal business purposes, such as maintaining our business records and system administration.

Marketing and advertising

Unless you request otherwise, we may also use your personal information for marketing and advertising purposes to send you news, information about our activities and general promotional material which we believe may be useful or of interest to you.

We target (and measure the performance of) ads to users, visitors to our websites and others both on and off our services directly or through a variety of third party partners, using the following data, whether separately or combined:

• Data from advertising technologies on and off our services, including web beacons, pixels, ad tags, cookies, and device identifiers;
• User-provided information (e.g., profile, contact information, title and industry);
• Data from your use of our services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including information from third party sources;
• Information from advertising partners and publishers such as Google, Nielsen and Roy Morgan; and
• Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender).

We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labelled “ads” or “sponsored.” If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the LinkedIn Services, that action may be mentioned with related ads.

We do not share your personal data with any third-party advertisers or ad networks for their advertising except for:

• hashed or device identifiers (to the extent they are personal data in some countries); and
• with your separate permission (e.g., lead generation form) or data already visible to any users of the services (e.g. profile).

However, if you view or click on an ad on or off our websites or apps, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies, determine it is you. Advertising partners may be able to associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

We use data and content about users for invitations and communications promoting membership and network growth, engagement and our services.

Moderation

We provide a platform for users to discuss investment opportunities and topics surrounding the Australian stock market. In order to provide a safe platform for users, we may:

• Investigate complaints about, or made by, you;
• Investigate potential or actual breaches of our Terms of Use and our guidelines (ie. our Code of Conduct, Posting Guidelines and CyberBullying Policy);
• Examine the use of any of our products and services to pursue any unlawful or prohibited activity; and
• Assist third parties, including Government agencies or other similar entities, to investigate such matters as required or permitted by law.

Sharing features

We may disclose your personal information to:

• other members of our Group;
• other third parties where you have given your consent (express or implied);
• our professional advisors, contractors or other service provides whom we may engage from time to time to carry out, advise or assist with the carrying out of our functions and activities; and
• government agencies or other similar entities as required or permitted by law.

We also may disclose your personal information to organisations or persons located overseas. For example:

• various administrative functions are undertaken by other members of the Group on our behalf, including our moderation function, which is undertaken by employees and contractors of Stockhouse Publishing Ltd (a member of our Group) located in Canada, Nigeria and the Philippines; and
• indirect overseas disclosure of your personal information to third parties overseas may occur as we use storage providers using cloud-based servers and various third party service providers located in countries including Singapore, the Philippines, Argentina, India and Pakistan.

If we disclose personal information to a third party in a country which does not have equivalent privacy laws to Australia (including with respect to access and enforcement), we will take reasonable steps in the circumstances to ensure that the overseas recipient does not breach the Privacy Act in respect of that personal information.

HotCopper will not sell, license or otherwise disclose your personal information to third parties unless such disclosure is for the purposes set out in this policy.

The use and disclosure of your personal information for a secondary purpose

We will not use or disclose your personal information for a secondary purpose (i.e., for a purpose other than the purposes identified above) unless:

• you consent to the use or disclosure for that purpose or you would reasonably expect us to use it for a secondary purpose which is related to the primary purpose;
• the use or disclosure is required or authorised by law; or
• the use or disclosure is otherwise permitted by the Privacy Act (for example, as a necessary part of an investigation of suspected unlawful activity).

We may also aggregate data for the purposes of market research and analysis. Where this occurs, your information is de-identified by removing data that can identify you, such as your name and contact details.

Interactive features

Any personal information that you submit, display, or publish on a forum, blog, channel, bulletin board, chat room, user commenting feature or other interactive sharing or social feature offered through our websites and services, is considered publicly available and can be read, collected, used, and disclosed by other users of those features and other third parties without restriction, except to the extent limited access features are available.

Your choices

Submitting personal information

If you wish to access or participate in certain of our websites and services that require your personal information you will be required to submit that personal information. For example, to register for an account with us, participate in certain contests or promotions, or access and/or use certain HotCopper product features or online services. If you do not submit the relevant personal information, then that may limit our ability to respond to your customer support inquiry in a timely fashion or enable access to the service or competition.

Unsubscribing

You can opt out of receiving HotCopper communications at any time by clicking the “unsubscribe” link in communications you receive from us. By opting out of our advertising communication emails received from us, you will be removed from the subscriber list. However, you will also lose your ability to post messages on our forum once you have unsubscribed from our mailing list. Please note that if you unsubscribe from HotCopper communications, we may still send you relevant administrative or security notices from time to time.

Cookies and similar technology

To assist us to provide our services to you, we directly collect, or another third party authorised by us and on our behalf collect, information from our website using "IP files". We utilise these IP files to automatically record information certain information when you visit our website, monitor our website's traffic patterns and to serve you more efficiently when you visit (or revisit) our website across your devices. We may also track your activity relating to your interactions with our email communications and links contained in those emails.

When you visit this website, our system will record your IP address (the address which identifies your computer or mobile device on the internet), the date, time and duration of your visit, the site from which you linked to our site, the pages viewed and any information downloaded. This information may be considered anonymous information or personal information under the Privacy Act in certain circumstances. For example, while this information is generally not linked to the identity of users, it may be linked to you:

• where our website is accessed via links in an email we send you;
• where we are able to uniquely identify your device(s);
• where we are able to identify the User accessing our website or using our services; or
• in combination with the types of personal information that we may collect from you and which are set out above.

You can change your browser’s privacy settings to delete or control cookies or other similar technology as you wish. Please note that updating these settings may prevent you from using various functionality features, products or services of our website.

For more information about cookies and how you can opt out, you can visit http://www.youronlinechoices.com.au.

Third party links services and links

We do not control the content or links that may appear on third party websites and are not responsible for the practices employed by third party websites and websites linked to or from our website or in communications from us.

Whenever you choose to click these links, you should be aware that this policy and our other policies no longer applies and that each third party website and services may have their own privacy policy and customer service policies. Those third party policies will govern their collection, storage and use of any of your personal information that you may supply to these third parties.

Opting out of marketing and advertising

If you do not wish to have your browsing activity tracked or your information used for the purpose of delivering you targeted marketing and advertisements, you may opt-out of the services currently used by us. Please note, you will still continue to receive non-personalised advertisements. Click on the relevant “Opt Out” links provided below for information on how you may opt out of interest based advertising that any of them deliver:

• Google's AdX and Double Click for publishers - https://www.google.com/settings/u/0/ads/authenticated?hl=en
• Google AdSense - https://support.google.com/adsense/answer/142293?hl=en
• Rubicon Project - https://www.sizmek.com/privacy-policy/p
• Criteo - https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/

Your rights

Accessing your personal information

Subject to any exceptions in the Privacy Act, if you have provided us with personal information, you may request access to your personal information by contacting us using the contact details provided above. We may ask you to provide proof of your identity if you request access to, or correction of, your personal information.

In the event that a request for access is made, we will review our records to determine what personal information relating to you we hold and endeavour to respond to your request within a reasonable period after the request is made, but in any event, within 30 days.

Once we have notified you of the nature of the personal information relating to you which we hold, we will give you access to your personal information in the manner requested by you, if it is reasonable and practicable to do so.

We do not levy a charge in respect of the making of a request for access to personal information held by us. However, we may charge you for the reasonable costs incurred by us in providing you with access to the personal information held by us.

The Privacy Act provides instances where a holder of personal information may refuse to provide an individual with access to their personal information. If we refuse to give you access to your personal information, we will give you a written notice that sets out our reasons for the refusal and the mechanisms available to complain about our refusal. Whenever you are entitled to access such information, we will provide such information to you via email without charging you for such access.

Correcting your personal information

HotCopper takes reasonable steps to keep your personal information as accurate, complete and up-to-date as possible. We make an effort to ensure this data is of high quality, but this relies on the accuracy and frequency of data provided by you.

You can assist us by notifying us if your circumstances change, such as if your name changes.

If we hold personal information about you and you request that we correct the information, we will take reasonable steps to rectify the situation free of charge if we are satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. If we refuse to correct your personal information, we will give you a written notice setting out our reasons for the refusal and the mechanisms available to complain about the refusal.

Deleting your account

The Australian Securities and Investments Commissioner requires that we retain your personal information and all other account related information accessible on our systems and backup systems for up to six (6) months. If you wish to have your account deleted you may do so using the contact details provided above, however your pseudonym username along with your submitted posts will remain on the website.

Subject to the above and our other legal obligations to retain certain business records, if you delete your account, your personal information may be permanently deleted. The deletion of your data may take up to 30 days from accessible systems and up to 90 days from backup systems.

If you choose to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.

Complaints, questions or further information

If you wish to make a complaint about a breach of your privacy by HotCopper, you may contact us using the contact details provided above. All complaints will be investigated by an appropriately qualified representative of HotCopper. We will endeavour to resolve your complaint as quickly as possible and, in any event, within 30 days. We will notify you of the outcome of the investigation, including how we propose to resolve your complaint and what, if any, corrective measures we will implement.

If you are not satisfied with our handling of your complaint, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). For more information about doing so, visit https://www.oaic.gov.au/privacy/privacy-complaints/.

Changes and updates to this policy

HotCopper regularly reviews this policy and may update the policy from time to time, in our sole discretion. We will notify you of any such changes by providing the current version of this policy on our website.

We encourage you to review this policy periodically to stay informed about our collection, use and disclosure of personal information. Your continued use of our websites and services or any other content, products or services covered by this policy constitutes your agreement to this policy and any updates.