Investair Privacy Policy

1. Introduction

Investair Pty Ltd (ABN 84 672 935 205) ("Investair", "we", "us", "our") operates investair.com.au, a capital markets intelligence platform serving participants in Australian financial markets. We are committed to protecting the privacy of individuals whose personal information we handle, in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs"). This Privacy Policy explains how we collect, hold, use and disclose personal information, and how you can access or correct your information or make a complaint. By using our website, platform or services, you agree to the handling of your personal information as described in this policy. If you do not agree, please discontinue use of our services.

2. What Personal Information We Collect

2.1 Information you provide to us

We collect personal information that you provide directly when you:

• register for an account or trial access
• subscribe to our platform or products
• contact us via email, phone or our website
• respond to surveys, research or feedback requests
• attend events, webinars or demonstrations we host

This may include your name, job title, employer or organisation, email address, phone number, postal address, and billing and payment details.

2.2 Information collected automatically

When you access our website or platform, we may automatically collect certain technical information, including:

• IP address and device identifiers
• browser type and version
• pages visited, time spent, and clickstream data
• referring URLs
• session and authentication tokens

We use cookies and similar technologies to collect this information. You may configure your browser to refuse cookies, although this may limit some functionality of our platform.

2.3 Publicly available and aggregated market data

As a capital markets intelligence platform, Investair aggregates, analyses and distributes data sourced from publicly available sources including Australian Securities Exchange (ASX) regulatory announcements, market disclosures, and other information made publicly available in accordance with applicable laws and ASX Listing Rules. Where this publicly available information includes the names or other identifiers of individuals acting in their professional capacity (such as company directors, executives or other officers), we may hold, process and publish such information as part of our data products and analytics. We rely on the public interest and legitimate purposes exception under APP 3.4 for the collection of such information, consistent with the basis on which it was originally disclosed.

3. How We Use Personal Information

We use personal information we collect for the following purposes:

• to provide, operate and improve our platform and services
• to verify your identity and manage your account
• to process payments and manage billing
• to communicate with you about your subscription, updates, or service matters
• to send you market intelligence, product updates or promotional materials (where you have consented or where permitted by law)
• to conduct analytics and research to improve our products
• to detect, prevent and investigate fraud, security incidents or violations of our terms
• to comply with our legal and regulatory obligations

We will only use your personal information for purposes for which it was collected, or where a secondary use is related to the primary purpose and you would reasonably expect such use, or where otherwise permitted by the Privacy Act.

4. Disclosure of Personal Information

4.1 Service providers

We may disclose personal information to third-party service providers engaged to assist us in operating our business and delivering our services, including:

• cloud hosting and infrastructure providers
• payment processing providers
• customer relationship management (CRM) platforms
• email and communications platforms
• analytics and business intelligence tools

These providers are contractually required to handle personal information only in accordance with our instructions and in compliance with applicable privacy laws.

4.2 Business transfers

If Investair is involved in a merger, acquisition, asset sale or restructure, personal information may be disclosed to the relevant counterparties as part of that transaction, subject to appropriate confidentiality protections.

4.3 Legal and regulatory requirements

We may disclose personal information where required or authorised by law, including to regulators, law enforcement, courts, or government agencies, or to enforce our legal rights or protect the safety of individuals.

4.4 No sale of personal information

We do not sell personal information to third parties for their own marketing or commercial purposes.

5. Overseas Disclosure

Some of our service providers may be located or may store data outside Australia, including in the United States and other jurisdictions. Where we disclose personal information to overseas recipients, we take reasonable steps to ensure that those recipients handle the information in a manner consistent with the APPs, including through contractual obligations.

By using our services, you acknowledge that overseas disclosure may occur in these limited circumstances.

6. Data Security

We implement industry-standard technical and organisational measures to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure. These include:

• encrypted data transmission (TLS/HTTPS)
• access controls and role-based permissions
• secure cloud infrastructure with regular security assessments
• staff training on privacy and data handling obligations

Despite these measures, no transmission over the internet or electronic storage system is completely secure. If you believe your account has been compromised, please contact us immediately.

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. When personal information is no longer required, we take reasonable steps to destroy or de-identify it securely.

7. Your Rights and Choices

7.1 Access and correction

You have the right to request access to personal information we hold about you and to request correction of any inaccurate or outdated information. To make a request, please contact us using the details in section 10. We will respond within a reasonable timeframe and in accordance with APP 12 and APP 13.

We may decline an access request where permitted by the Privacy Act, such as where providing access would pose a serious threat to health or safety, or unreasonably affect the privacy of another person. If we decline a request, we will provide written reasons.

7.2 Marketing opt-out

If you have previously consented to receive marketing communications from us, you may opt out at any time by using the unsubscribe link in any communication we send or by contacting us directly. We will action opt-out requests promptly.

7.3 Cookies

You may configure your browser to refuse cookies or to alert you when cookies are being set. Note that disabling cookies may affect the functionality of our platform.

8. Sensitive Information

Investair does not intentionally collect sensitive information (as defined by the Privacy Act, including health, racial or ethnic origin, political opinions, religious beliefs, or biometric data) as part of its services. If you voluntarily provide sensitive information to us, we will handle it with the additional protections required under APP 3.

9. Privacy Complaints

If you have a complaint about how we have handled your personal information, please contact our Privacy Officer (see section 10). We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. If we are unable to resolve your complaint to your satisfaction, you may escalate it to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

10. Contact Us

For any privacy-related enquiries, access requests, correction requests or complaints, please contact:

11. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. We will publish the updated policy on our website with a revised "Last updated" date. We encourage you to review this policy periodically. Continued use of our services after any update constitutes acceptance of the revised policy.