The Market Limited Corporate

The Market Limited

Privacy Policy

Introduction

Report Card Pty Limited ACN 092 598 859 (“The Market Herald”) recognises that your privacy is very important and believes that information received by us that can be used to identify an individual user (“you”, “your”, “User”) should be treated with respect. We are serious about adhering to the Australian Privacy Principals and other applicable privacy legislation. Before providing us with any information, you should read through this policy so that you understand and are comfortable with exactly how we will collect and what we will do with any information you share with Us. By using The Market Herald Sites and/or Services covered by this Policy and providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information.

Who is The Market Herald?

When we refer to “we” (or “our” or “us”), 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 population.

Our contact details are:

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

For privacy and customer service email: [email protected]

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.

How the information is being collected?

  1. Voluntarily
  2. Automatically
  3. Information from Third Party Sources

Voluntarily

We collect information you provide to us in optional, voluntary submissions, including but not limited to registration forms, posts within the forums, clicking “thumbs up” and “great analysis” buttons, adding to watchlists, subscription pages, user profiles, promotional signups, sweepstakes/contest entries, email requests for customer service, software and mobile and application downloads.

Automatically

We will create and record information automatically when you visit our Site. We use cookies (or files sent directly to your computer or device) and other similar technology to collect information such as your IP address, the site you visited immediately prior to our Site and the frequency and duration of your visit to our Site.

We may track activity relating to your interaction with our email communications and with links contained within our email communications and our Site. This information is generally non-personally identifiable.

We collect information from or about the computers, phones or other devices where you install or access our Services. We may associate the information we collect form your different devices, which helps us provide consistent Services across your devices. Here are some examples of the device information that we collect:

  • Attributes such as the operating system, hardware version, device settings, file and software names and types and device identifiers.
  • Device locations, including specific geographic locations, such as GPS, Bluetooth or wifi signals.
  • Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile number and IP address.

Some cookies may be associated with Personal Information about you and some may not. This information is generally collected, used and stored to deliver relevant messaging and enhance your experience when visiting our Site.

Information from Third Party Sources

We may also obtain information, including Personal Information, from third party sources. This may include soliciting third parties to collect Personal Information on our behalf such as various usage and user metrics when you use our Sites and/or Services. In such cases we instruct those third parties to comply with this Policy.

Our website features Nielsen and Roy Morgan proprietary measurement software, which will allow you to contribute to market research, like Digital Content Ratings and Roy Morgan Audiences. To learn more about the information that Nielsen and Roy Morgan software may collect and your choices with regard to it, please see the Nielsen Digital Measurement Privacy Policy at

http://www.nielsen.com/digitalprivacy and the Roy Morgan Privacy Policy at www.roymorgan.com/legal/privacy respectively.

What information is being collected?

Personal and Non-Personally Identifiable Information

We collect “Personal Information”, as well as non-personally identifiable information on The Market Herald Sites and/or Services. “Personal Information,” as used in this Policy, is personally identifiable information, such as your first and last name, email address, IP addresses, demographics, passwords, 708 sophisticated investor status, telephone numbers and/or other online contact information.

Sensitive Information

The Market Herald does not collect sensitive information from users for marketing purposes. “Sensitive Information” includes information about a person’s racial or ethnic origin, religious beliefs or affiliations, philosophical beliefs, health or genetic information, sexual preference or information about whether an individual is a member of a professional or trade association or union.

Sensitive information might be collected during the course of surveys or competitions administered by The Market Herald or its affiliated third parties, but only if volunteered by Users with their consent.

You can choose not to actively volunteer information to The Market Herald. However if you do provide information to The Market Herald when asked or prompted, including Sensitive Information, you are also providing consent for The Market Herald to collect, store and use that information as necessary for the purpose of collecting it.

Security and Integrity

We take reasonable measures, including 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. If we learn of a security systems breach, we will attempt to notify you electronically so that you can take appropriate protective steps.

We store information on networks in Australia and Singapore and take reasonable steps to protect your Personal Information from misuse, loss or unauthorised access. These reasonable steps include password access, VPNs, firewalls, and secure servers.

How We Use Information

Generally, we use Personal Information to establish and enhance our relationship with our Users through four main categories:

  1. Communication
  2. Optimisation
  3. Marketing & Advertising; and
  4. Sharing Features.

Below, we provide some specific examples of how we use the information we collect.

Communication and Responding to Requests

To provide you with customer support, share communications such as newsletters, respond to users’ requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and connect users to The Market Herald Sites and/or Services and to products and services of our partners and licensees.

Optimisation

To provide, improve, and maintain our Sites and Services, to develop new products and services, to prevent abuse and fraud, to personalise and display advertisements and other content for you, and for other administrative and internal business purposes.

Marketing & Advertising

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

  • Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • Member-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 as described in Section 1.3;
  • 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: (i) hashed or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., lead generation form) or (iii) 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 site 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 can 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 Members for invitations and communications promoting membership and network growth, engagement and our Services.

Sharing Features

Sharing features relates to the use of third party services made available to you on the The Market Herald site. These features provide you with various ways to connect and share content with third parties, such as subscription research services or by posting sharing a post on your personal email, facebook or twitter services.

By using any third party service to share links to our content, you permit us to access, use and disclose information relating to your account on each such third party service (such as your user name and profile information) if available to us through the third party service. This information is used in accordance with this privacy policy and for the delivery of the third party service requested.

When We Disclose Personal Information

The Market Herald will not sell, license or otherwise disclose your Personal Information to third parties unless such disclosure is for the purposes set out in this Privacy Policy.

We may disclose your information if we are legally bound to do so or if, in our reasonable opinion, such disclosure is necessary to prevent harm to ourselves, other users or a third party. We will notify you of such disclosure in all such instances.

Division 3 Part 3 of the ASIC Act outlines ASIC’s power to seek these records. Most often the notice will be addressed directly to the company or to an eligible addressee, usually a director, and will order the delivery of specified books and documents. The term ‘books’, as outlined in the ASIC Act is a broad term that can be defined as any form of stored information which include personal data covered by this Privacy Policy. The Market Herald is obliged to disclose all information requested by ASIC to ASIC on receiving an appropriate notice under the ASIC Act.

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 Sites and/or Services, is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us 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 The Market Herald Sites and/or 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 The Market Herald 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 The Market Herald 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 The Market Herald communications, we may still send you relevant administrative or security notices from time to time.

Your rights

Accessing Personal Information

You may request access to any Personal Information we hold about you by contacting us as per the details under the Enforcement section in this Policy. Whenever you are entitled to access such information, we will provide such information to you via email without charging you for such access.

If you wish to receive the personal information we have collected from you then you can do so by contacting us at [email protected].

Editing Personal Information

You may, at any time, update, correct, or delete certain Personal Information that you have provided to us by updating your preferences on the Edit Profile or by contacting us as per the details provided in this Policy. You are entitled to request that your Personal Information is dealt with by us either anonymously or under a pseudonym.

Cookies and Similar Technology

We collect information from our website using “IP files”. When you visit this site our system will record your IP address (the address which identifies your computer or mobile device on the internet), the date and time of your visit, the site from which you linked to our site, the pages viewed and any information downloaded.

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 Site.

Marketing & Advertising

If you do not wish to have your browsing activity tracked or your information used for the purpose of delivering you targeted advertisements as explained under Marketing & Advertising, you may opt-out of the services currently used by The Market Herald. Please note, you will still continue to receive non-personalised advertisements. Click on the relevant “Opt Out” links provided below if you would like to 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

Rubicon Project:

Criteo:

http://tremorvideodsp.com/privacy-policy.html

Google AdSense:

A. Opt out of Ads Personalisation by signing into your Google Account

  1. Go to Ads Settings
  2. Click or tap the slider next to ‘Ads Personalisation’
  3. Click or tap TURN OFF

This opt-out will work across all of your signed-in devices when we recognise you as being signed in.

B. Or, for further guidance refer to this article on managing personalised advertisements on your specific device

https://www.howtogeek.com/285835/how-to-opt-out-of-personalized-ads-from-google/

Index Exchange:

http://optout.networkadvertising.org/?c=1#!/

Account Deletion

It is a requirement by ASIC that The Market Herald retain your Personal Information and all other account related information accessible on our systems and backup systems for up to 6 months. If you wish to have your account deleted you may do so by emailing [email protected], however your pseudonym username along with your submitted posts will remain on the site.

If you delete your account, your Personal Information be permanently deleted. 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.

Occasionally we will include links to third party websites on our Site or Communications with you. Whenever you choose to follow such links to any other websites you should be aware that our privacy policy no longer applies and that each third party website’s privacy policy will govern their collection, storage and use of any of your Personal Information from the moment you leave our Site.

Changes and Updates to This Policy

The Market Herald regularly reviews its compliance with this Privacy Policy. This Privacy Policy was last updated on 18 July 2018 and may be updated by us, from time to time, in our sole discretion. We will notify you of any such changes by providing the current version of the Privacy Policy on our Site.

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 Sites and/or Services or any other content, products or services covered by this Policy constitutes your agreement to this Policy and any updates.

Further information can be found at the Government Privacy web site: www.privacy.gov.au