HORNE CAPITAL PTY LTD PRIVACY POLICY

IMPORTANT LEGAL NOTICE

We are committed to protecting your privacy. This policy outlines the information we collect from you, how we use this information and your rights in relation to it.

We are committed to managing personal information in accordance with:

and in accordance with other applicable privacy laws.

By accepting this Privacy Policy, you consent to us collecting, using and disclosing your Personal Information in accordance with the terms of this policy.

Effective Date: February 2024

Who is Horne Capital Pty Ltd?

When we refer to ‘Horne Capital Pty Ltd’, ‘we’ and ‘us’, we refer to Horne Capital Pty Ltd (ACN 650 380 608) and its related bodies corporate. We are registered in Victoria, Australia.

What personal information do we collect?

When you use our application or create an account, we collect information necessary to provide you with services. This may include the following information from you:

We may also collect information automatically when you use our application, for example what type of device you are using, as well as your approximate location. We use cookies in our application, which will be explained in further detail below.

Why do we store your personal information?

We collect information primarily to allow you to receive our services and use our application.

Some of the reasons we store your information include to:

We also use the information we have about you to populate voting results on each poll posted as part of our services. In particular, your age, gender and vote (i.e. yes or no) is used to give a graph of the results for each poll. All voting is anonymous and results are anonymised so that no one else ever sees how anyone else (individually) has voted.

When do we collect your personal information?

We collect your personal information when you use our application and when you interact with us.

Examples of when we collect your personal information include:

What happens when we’re unable to collect your personal information?

If we are unable to collect your personal information, we may not be able to fulfil our obligations to you. Your experience when interacting with us may be delayed or not as efficient as you would like.

How do we store your personal information?

We take every effort to store your personal information safely. We may hold your personal information either in electronic or hard copy form. When we store information electronically, this may be on our computer systems, databases, software programs, internet servers and hosted internet solutions. We use Amazon Web Services located in the United States of America and Australia to store your personal information.

We take every effort to keep your information safe in accordance with relevant government regulation and requirements.

How we use your data

We do not sell your personal information to third parties. However, your personal data may be shared to the following partners:

Your personal information may be disclosed to third parties if disclosure is required by law. If we sell our business, or we have a change in control, your personal information will be disclosed and transferred to the new owner/controller for that purpose.

We may use your personal information for marketing purposes if you have specifically consented to such marketing.

We are not liable for any loss, damage or claim arising out of a third party’s use of your personal information where we were authorised by you or law to provide that third party with your personal information.

How you can access your personal information

You have the right to access your personal information stored by us at any time. Please email neil@yoorsay.com to make this request. Please note that it may take us a few days to collate all the personal information we have stored.

You have the right to be informed about how your personal information is being used and we will strive to update you when our privacy policy changes. You may also contact us at any time to ask questions about your personal information, or to update your details at neil@yoorsay.com.

How long do we store your personal information?

We retain your personal information for as long as is needed for us to fulfil our obligations to you, for example to provide services. We may also need to store your personal information to comply with any tax or governing bodies. When we no longer need to store your data for these reasons, we will either delete or sufficiently anonymise this. Please note that we may have a legal obligation to retain copies of your information in certain circumstances for a particular period of time.

Do we disclose your personal information overseas?

We are based in Australia so the majority of our service providers are Australian based. However, we may from time to time collaborate with overseas partners. We only ever disclose your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. This means that we have taken all necessary steps to keep your information safe as per the relevant privacy regulations.

Changes to our policies

We may make changes to this policy from time to time. Our current policy will be available on our website or a hard copy may be provided to you upon request. If you continue to use our services after any update to this policy, you agree to the terms of the updated policy and consent to the use of personal information in accordance with the updated policy.

Residents in the European Economic Area and the United Kingdom

The same privacy policy also pertains to residents of the United Kingdom and European Economic Area in compliance with the GDPR and the UK GDPR.

If you are a resident of the United Kingdom or European Economic Area you are protected by specific regulations set out in the GDPR and the UK GDPR which includes the following:

We will respond in the same way as we will for residents of any other country as set out in this privacy policy.

Residents in California

The same privacy policy also pertains to residents of California in compliance with the CCPA.

If you are a resident of California you are protected by specific regulations set out in the CCPA which includes the following:

Cookies and Web Browsing

Like many applications, we may use cookies to personalise and streamline your experience with us. This is because we want to provide you with the best and easiest experience possible when you’re using our application.

What types of cookies do we use?

  1. Performance cookies
    We require certain types of cookies in order for our application to operate.
  2. Analytical cookies
    We like to know how many users are on our site at any time, as well as where they are visiting from and which pages they visit. This allows us to create content that best suits your needs.
  3. Targeting cookies
    These cookies allow us to see your user journey, so we can make this simple and easy for you. This allows us to customise your experience and our marketing activities, so they are relevant for you.

Privacy Complaints

If you believe we have breached our privacy rights at any time, please send us an email so our privacy officer can investigate and respond to you. All such enquiries or complaints will be taken seriously and handled with impartiality and discretion. If you wish to submit a complaint, please provide us with all relevant details such as the date and time of the incident or communication, the circumstances surrounding the event and your concerns about what was said or done.

If you have complained about something that is not covered in the relevant privacy laws, we will explain why we are unable to take further action. Please allow a few days for us to investigate and respond to any privacy complaints.

If you have any questions or concerns please feel free to contact us at:

Email: support@yoorsay.com