1. Introduction

Laverne Securities Pty Ltd (t/as) Investor Desk NRI (Investor Desk NRI, “we”, or “us”) recognizes and appreciates the importance of protecting your privacy and securing your personal information. We abide by the Australian Privacy Principles (APPs), a part of the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988.

Laverne Securities Pty Ltd (t/as) Investor Desk NRI will, from time to time, review and update this Policy in accordance with product and service updates and incorporating regulatory, legislative, and technology changes. The Site’s Terms of Use govern your use of our services and by using the Site you consent to the collection, transfer, processing, storage, disclosure, and other uses described herein.

2. Collection of personal information

As a financial planning organization, we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“personal information”). In addition, our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you.

Laverne Securities Pty Ltd as a CAR of Laverne Capital Pty Ltd (t/as) Investor Desk NRI collects Personal Information as required by law to verify your identity (in accordance with the AML/CTF Legislation), to allow us to conduct our business functions, and to market our products. Information we may collect includes (but is not limited to):

Your name, date of birth, and contact details (including personal or work email and postal addresses)

• Credit card
• Bank account
• Tax File Number (TFN) and Holder Identification Number (HIN) details

We will not collect any personal information about you except when you have knowingly provided that information to us or authorized a third party to provide that information to us. Generally, the collection of your personal information will be affected in either a face-to-face interview, over the telephone, or by way of an online client engagement form.

3. Collecting Information from third parties

We may also collect Personal Information about you via third parties, such as those that facilitate the use or communication of our products, services, program, or activities (as the case may be) Services. However, we will only collect your personal information from third parties if it is not reasonable or practical to collect this information directly from you.

When you visit and browse our website, solution, or app, our website host and other third parties engaged by us may collect personal information for statistical, reporting, and maintenance purposes.

Subject to this Privacy Policy, the personal information collected by our website host will not be used to identify you. The information may include:

• The number of users visiting our website, solution, or app and the number of pages viewed.
• The date, time, and duration of a visit.
• The IP address of your computer.
• Location of the user.
• The path is taken through our website, solution, or app.

Our website host uses this information to administer and improve the performance of our website.

4. Third Party Sites

Our site may timingly have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that investor desk is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information. If you provide personal data through any other site your transaction will occur on that website (not the investor desk) and the personal data you provide will be collected by and controlled by the privacy policy of that website operator. Links on the Site to other websites are provided only as a convenience and the inclusion of such links does not imply endorsement of the linked website. We encourage you to read the legal notices/ policies posted on those websites, including their privacy policies. We have no responsibility or liability for your visitation to, and the data collection and use practices of, other websites

5. How we use the Personal Information

Where we collect Personal information about you, we may use this information for our organization’s primary functions and services which may include, but are not limited to:

Provide you with information or services you have requested.

• Promote and market our Services to you;
• Personalize and customize your experiences on our website, solution, or app;
• Communicate with you;
• Provide you with ongoing information about us in which you may be interested;
• Research to improve our existing services or create new services; and
• Allow you to receive emails and other advertising material

If we collect and use your personal information for purposes not listed above, we will make it known to you at the time we collect and/or use your personal information.

If you choose not to provide your personal information to us for the purposes set out in this privacy policy, we may not be able to undertake certain activities for you.

6. Disclosing your Personal Information

Personal data about you may be reviewed by Investor Desk NRI employees or agents who have a business need to access such personal data and may include among others recruiters, human resources personnel, communications personnel, legal personnel, technical services personnel and managers or their designees. Investor Desk NRI will remain responsible for personal data that is jointly used with affiliates.

We may share personal data about you with selected service providers or consultants acting on our behalf, such as third parties assisting Investor Desk NRI with the operation of the Site. Those third parties will be required to use appropriate measures to protect the confidentiality and security of personal data.

Investor Desk NRI also may use or disclose personal data about you in order to:

• Protect the legal rights, privacy or safety of Investor Desk NRI or its employees, agents and contractors.
• Protect the safety and security of visitors to our web sites or other properties.
• Protect against fraud or other illegal activity or for risk management purposes.
• Respond to inquiries or requests from government or public authorities, including authorities outside your country of residence.
• Permit us to pursue available remedies or limit the damages that we may sustain.
• Comply with the law or legal process, including laws outside your country of residence.

Investor Desk NRI also may transfer any and all information that we collect about you to third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Investor Desk NRI assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).

7. Marketing

We may use your personal information to provide you with promotional material that may benefit you or other services offered by us. If you do not wish to receive such material, we provide you with the ability to unsubscribe from these communications.

Unless otherwise specified in this privacy policy, we will not disclose any of your personal information to any other organization unless the disclosure is required by law or is otherwise permitted by the National Privacy Principles.

8. Access to your Personal Information?

Subject to some exceptions, you are entitled to access personal information that we hold about you. If you request access to your personal information, we must verify your identity before granting your request. Where your request for personal information would unreasonably impact the privacy of others or is not otherwise permitted under the National Privacy Principles, Investor Desk NRI has the right to refuse this request. If we refuse your request to access your personal information, we will provide you with reasons for the refusal. An access request can be made by contacting our privacy office as specified in section 9.

9. Digital Privacy

Privacy, security, and service in Investor Desk's NRI online operations are critical to our business, controlled measures are taken, to maintain the security of your online session when you interact with our Site.

When you interact with our Site, Investor Desk NRI manages personal data in accordance with the practices and safeguards described in this policy. Unfortunately, no method of transmitting or storing data can be guaranteed to be 100% secure. Do not send sensitive information via normal email. It is your sole responsibility to use the appropriate level of care whenever communicating with us.

Investor Desk NRI hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliated companies, service providers and contractors for any of your information sent to our Site which is lost, misused, illegally accessed, disclosed, altered or destroyed or not integrally or timely delivered to our Site.

When you use our Site, we may collect technical, statistical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our Site. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving Site design and functionality, and personalizing your experience.

10. Updating, storage, and security of Personal Information

Additional detailed information regarding the safeguarding of personal information is generally held in your client file. However, we also take reasonable steps to ensure the personal information we collect, use, or disclose is:

• Accurate, completed, and up to date.
• protected from misuse and loss.
• Protected from unauthorized access, modification, or disclosure; and
• Deleted if it is no longer required by Law, for our business purpose or functions.

Updating your Personal Information

Investor Desk NRI provides the facility to update some of your details via your account. However, in some instances, we will request the update of your details in writing and may also require you to verify your identity. This is to ensure all requests for updates to personal information is received by the account owner and to assist in the protection of your personal information. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Please also note that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.

11. Managing your Complaint

If you make a complaint, Laverne Securities Pty Ltd (t/as) Investor Desk NRI will confirm receipt of your complaint within 48 hours and will resolve your complaint within 10 working days. However, where this is not possible, we will contact you within this time frame to provide you with an update and an expected time frame for the issue to be resolved.

If you are not satisfied with our final response, or if you have not received a response after 45 days, you may complain with The Australian Financial Complaints Authority if lodged on or after 1 November 2018 via:

Laverne Securities Pty Ltd Member Number: 74676

Online: www.afca.org.au

Email: info@afca.org.au

Phone: 1800 931 678 (free call)

Mail: Australian Financial Complaints Authority GPO Box 3, Melbourne VIC 3001

Time limits may apply to complain to AFCA and so you should act promptly or otherwise consult the AFCA websites to find out if or when the time limit relevant to your circumstances expires.

12. Amendments

We may, at any time at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.

13. Further information

If you have any questionsor concerns, you should contact us at vijay.rajnri@investordesk.com.au

If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this privacy policy in respect of your personal information, or for any other queries, or communication about this privacy policy, please attention your concerns to our Compliance Officer via:

Email: supportnri@investordesk.com.au

Write to: Compliance Officer

Suite 6/96 Wigram Street, Harris Park NSW 2150

14. Contact

Laverne Securities Pty Ltd (t/as) INVESTOR DESK NRI ABN: 34 629 216 477 AFSL: 482937

Business Address: Suite 6/96 Wigram Street, Harris Park NSW 2150

Email: vijay.rajnri@investordesk.com.au

Phone: 1300 528 376

Web: www.investordesknri.com.au