1. Privacy generally
In collecting, holding, using, disclosing and otherwise managing your personal information, Angel Partners will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.
2. Kinds of personal information collected
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the receipt or provision of information about potential investments, or as a result of our other interactions or dealings with you, Angel Partners may collect your personal information.
The kinds of personal information that Angel Partners collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Angel Partners collects may include:
- contact and identification information you provide to Angel Partners through inquiries you make to us such as your name, address, telephone number, email address, date of birth or other types of verification details;
- information about your financial circumstances and objectives, including your assets and funding preferences, and general identity information including the names, addresses, citizenship and tax status of account holders; and
- your credit card information (which may include transactional histories) or information relating to other payment methods.
Angel Partners also collects internet/technology related information from visitors to our site or users of our other online services, including the referring URL, your IP address, which browser you used to come to the site, the country, state or province, the pages of our site that you viewed during your visit and any search terms entered on our site.
Angel Partners may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.
Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law.
3. How we collect personal information
Generally, Angel Partners collects your personal information directly from you. For example, Angel Partners may collect your personal information:
- when you register or apply for an account or membership with us, request information or services, or otherwise provide us with your details;
- where you use our websites or other online services or otherwise interact with us;
- when you complete an application form or survey or provide us with your investment preferences; or
- if you post information to our website or any of our social media sites.
There may be occasions when Angel Partners collects your personal information from someone other than you, for example:
- from your bank or other relevant financial institutions in order to provide our services to you;
- from third parties you authorise to disclose your information to us (including banks and other third party financial services);
- from a publicly maintained record or other publicly available sources of information including social media and similar websites;
- from our vendors or suppliers that help provide our services to you (for example, customer support information, payment information or identity validation); or
- from third parties if you connect to our services or register an account with us using an external third-party application, such as Facebook or Google.
Generally, Angel Partners will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you.
4. Purposes for which personal information is used
Generally speaking, Angel Partners collects, holds, uses or discloses personal information so that we can provide you with information about investment opportunities.
Some examples of the purposes for which Angel Partners collects, holds, uses and discloses your personal information include to:
- determine your eligibility for our services;
- enable us to supply you with information you request from us;
- facilitate the supply of services to you, including communicating with and providing investment opportunities to you;
- personalise your experience with our services;
- conduct promotions, competitions, giveaways and events;
- contact you to obtain your feedback regarding our goods or services or to conduct other market research;
- undertake direct marketing (as detailed in paragraph 5 below);
- conduct investigations in cases of fraud, credit or data security risks;
- analyse information we collect so that we can administer, support, improve and develop our business and the services we offer (including by monitoring or recording our interactions with you for training purposes); and
- comply with the obligations of Angel Partners under any applicable laws.
In addition to the purposes listed above, Angel Partners may use your personal information for purposes related to the above purposes, other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law.
Where personal information is used or disclosed, Angel Partners takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Angel Partners. However, without certain information from you, Angel Partners may not be able to provide services or information to you or may be limited in how we can interact with you.
5. Direct marketing
6. Disclosure of personal information
- start-up companies and other potential investees;
- potential investors;
- related companies of Angel Partners;
- other parties who invest in or acquire an interest in Angel Partners;
- service providers and contractors and other third parties that provide goods or services to us (including our technology service providers, our business consultants, risk, compliance and identification verification companies or other business or administration service providers);
- people or entities considering acquiring an interest in Angel Partners business or assets;
- Angel Partners professional advisors (including legal and accounting firms, auditors, consultants, insurers and other professional advisers); and
- government authorities where required by law.
Angel Partners may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or the disclosure is required or authorised by law.
If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.
7. Overseas disclosures
Some of the parties that Angel Partners discloses your personal information to may be located outside Australia, including technology service providers located in the United States of America.
We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.
8. Links to other websites
When you visit our websites or other online services, we will generally leave a ‘Cookie’ in the memory of your web browser. The website or other online service may only function properly if Cookies are enabled. Our websites and online services may use persistent Cookies to authenticate you as a user and display content that is relevant and specific to you.
Cookies are very small files that store information about your visit to and use of a website. Most major commercial Internet sites use them and they make your Internet-surfing more useful and less time-consuming because they store information that is reusable each time you visit our website, such as birthday and other preferences you have chosen to share with us.
10. Security of personal information
Angel Partners takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Angel Partners holds personal information in electronic forms in secure databases on secure premises, accessible only with the appropriate passwords by authorised staff.
The processes and systems we use to secure your personal information include:
- the use of identity and access management technologies to control access to systems on which information is processed and stored;
- requiring all employees to comply with internal information security policies and keep information secure;
- requiring all employees to complete training about information security; and
- monitoring and regularly reviewing our practise against our own policies and against industry best practice.
Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.
Angel Partners will destroy or de-identify personal information in circumstances where it is no longer required, unless Angel Partners is otherwise required or authorised by law to retain the information.
All transmissions of your credit card information are encrypted.
11. Access and correction
Angel Partners takes steps reasonable in the circumstances to ensure any personal information it holds is accurate, up-to-date, complete, relevant and not misleading.
In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Angel Partners. If at any time you would like to access or correct the personal information that Angel Partners holds about you, or you would like more information on Angel Partners’ approach to privacy, please contact Angel Partners using the details set out in paragraph 12 below. Angel Partners will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- Angel Partners requests that you be reasonably specific about the information you require; and
- Angel Partners may charge you a reasonable administration fee, which reflects and will not exceed the cost to Angel Partners for providing access in accordance with your request.
Angel Partners will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If Angel Partners refuses your request to access or correct your personal information, Angel Partners will provide you with written reasons for the refusal and details of complaint mechanisms.
If you are dissatisfied with Angel Partners refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.
12. Contacting Angel Partners
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Angel Partners using any of the following contact details:
Email: [email protected]
13. Privacy complaints
Please direct all privacy complaints to Angel Partners. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and Angel Partners.
Angel Partners will acknowledge your complaint within 14 days of receipt and endeavour to resolve it within 30 days, unless Angel Partners informs you otherwise and seeks your agreement in writing.
Angel Partners will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Angel Partners will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.