Privacy Policy

Uptrade PTY LTD and its related entities (hereinafter referred to as “UpTrade,” “we,” “us,” and “our”) understand the critical importance of your privacy and are firmly committed to safeguarding it.

This privacy policy outlines how we handle personal information on our website uptrade.au.

Unless you indicate otherwise, we assume that by registering for our services or providing your personal information, you have consented to the collection, use, and disclosure of your personal information in accordance with this privacy policy.

Should we decide to modify our privacy policy, we will post those changes on our website.

1. What personal information do we collect?

Personal Information

Our reference to personal information encompasses information or opinions about an individual, or an individual who can be reasonably identified, regardless of its accuracy or format (whether in a tangible form or not). The personal information we collect and retain about you varies based on your interactions with us. Examples of personal information we collect and retain include:

• Name
• Date of birth
• Address
• Email address
• Cryptocurrency wallet ID, address, content, and transactions
• Mobile phone number
• Copies of identification documents or pertinent details
• The purpose of your cryptocurrency transactions and the source of funds
• Financial information, such as your bank account details and statements
• Politically exposed persons (PEP) matching results, when relevant
• Qualifications and employment history if you are applying for a job or contract with us

We may also collect other personal information that we reasonably consider necessary for our functions and activities. This includes personal information you provide or that is provided by a third party, as well as information we are authorized or required by law to collect.

Sensitive Information

If you provide your consent, we may collect sensitive information if it is reasonably necessary for one or more of our functions or activities, or where required or permitted by law. Examples of sensitive information we may collect include biometric data or information on your racial or ethnic origin that is apparent from identity documents.

When we collect sensitive information, we will only process it for purposes such as performing a contract, safeguarding legitimate interests, complying with legal obligations, or with your consent.

2. How we collect your personal information?

We usually collect your personal information directly from you, through methods like phone calls, video calls, standard forms, letters, emails, or your interactions with our website.

We may also obtain your personal information from related entities, third parties, or publicly available sources when it is impractical or unreasonable to collect it directly from you or when required to fulfill our legal obligations. For instance, we may acquire your know-your-customer (KYC) or anti-money laundering (AML) information from identity verification service providers. Information such as your name, address, proof of address, and date of birth is often collected from these providers.

Additionally, we may collect personal information (e.g., name, address, date of birth, biometric information) during phone or video calls by recording or transcribing these interactions.

If you are a company director or shareholder of a trust or company using our website, we may collect your personal information (e.g., name, address, and date of birth) from the relevant corporate regulator.

If you apply for a job or contract with us, we may also collect personal information about you from the referees you nominate.

In some instances, we may receive unsolicited personal information. If it is reasonably necessary for our functions or activities and lawful and reasonable to retain, we will de-identify or dispose of this information promptly.

Failure to provide your personal information may result in our inability to provide certain services, and some website features and functionalities may not be accessible.

3. Our website

When you visit our websites, our web servers may automatically collect information, including your:

• IP address
• Visit date and time
• Website sections you access
• Interactions on our website
• Operating system and browser

While using our websites, your personal information may be collected through cookies, which are small text files stored on your mobile device or computer by our websites. These cookies automatically collect information about your usage without your direct input. Cookies are not harmful programs that can access or damage your device.

Cookies are used to understand and save your preferences for future visits, as well as compile aggregated data about site traffic and user interactions to improve the website experience and tools. Most devices automatically accept cookies, but you can change your device settings to reject them. Note that rejecting cookies may limit or disable some website functions.

Our websites may contain links to other websites. When accessing sites other than ours, their privacy practices are beyond our control. We recommend reviewing the privacy policies of each visited website.

4. How we use your personal information

To provide our services, we must collect and process your personal information, including sensitive information, to meet our Know Your Customer (KYC) obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and other applicable laws and regulations.

The personal information we collect may also serve the following purposes:

• To communicate with you: This includes facilitating and processing your orders and transactions, delivering requested information, operational updates, notifications related to your orders and transactions, and seeking feedback or participation in research or surveys.
• To market to you: We may send marketing communications through various channels, such as email, SMS, telephone, or other media, about uptrade.au or other products, services, or information we believe may interest you. You always have the option to unsubscribe from marketing or promotional communications.
• To protect you: We use your personal information to detect and prevent fraudulent or malicious activities, ensuring all users adhere to our terms and conditions.
• To support you: This includes helping you resolve technical support issues or other matters concerning our websites or services, either through email or other means.
• To hire you: When you apply for a position or contract with us, we use your personal information to evaluate your application.
• To enhance our websites and services: We monitor and track your use of our websites and services to improve your experience, develop efficient tools, and carry out technical analyses.
• To resolve disputes: Transcripts or call recordings, which contain personal information, may be used to investigate and address disputes or complaints you may have.
• To analyze, aggregate, and report: We may use your personal information, whether directly obtained or from third parties, to produce aggregated and anonymized analytics and reports, which may be shared publicly or with third parties.
• To make decisions concerning your use of our website and services: We may use your IP address to determine your location and decide whether to grant you access to our website or services based on that location. We may also use automated decision-making processes to identify fraudulent emails or data.
• To comply with legal obligations: When necessary to meet our legal obligations, including Anti-Money Laundering and Counter Terrorism Financing laws, or to investigate, prevent, or take action regarding suspected illegal activities, potential threats to safety, or violations of our terms and conditions or this privacy policy.

5. How we hold your personal information

We generally store your personal information in computer systems, including those operated by our service providers. We take reasonable measures to protect personal information from misuse, interference, loss, unauthorized access, modification, or disclosure. This includes implementing appropriate security measures to safeguard electronic records.

Our electronic records are secured within our network databases and by third-party data storage providers. This entails protecting personal information with password access and monitoring access appropriately. Our service providers, including third-party data storage providers, are bound by laws to safeguard personal information and employ suitable technical and organizational measures to prevent unauthorized or unlawful use of personal information, as well as its accidental loss, destruction, or damage.

6. How we share your personal information

Disclosure to Third Parties

We may, on occasion, share your personal information with trusted third parties to provide the services available through our website. These third parties may include:

• Our related entities
• Third-party suppliers who assist us in various functions and activities, including identity verification, customer service ticketing, IT services, and electronic marketing
• Financial institutions for payment services
• Parties to whom you have requested we disclose personal information
• Government, regulatory, or law enforcement agencies

When sharing information with these third parties, we take reasonable steps to ensure they maintain the confidentiality of this information and prohibit its use beyond what is necessary to assist us.

Overseas Disclosure

Personal information may be transferred to and processed in countries other than your country of residence, as some of our service providers and related companies are located outside Australia. When we disclose personal information to an overseas third party, we establish safeguards, such as contractual obligations, to ensure the recipient complies with applicable laws (such as the Australian Privacy Principles) regarding personal information handling.

Disclosure to Law Enforcement or Government Agencies

We may disclose your personal information to law enforcement or government agencies when required by law or court order. Where allowed by law, we will attempt to provide prior notice to customers whose data is requested by such agencies. If prior notice is infeasible, we will notify customers as soon as possible.

We may not notify you if the law prohibits it or in certain exceptional circumstances at our discretion. For instance, when notice might endanger personal safety, compromise the law, or be counterproductive, such as in the case of a hacked account.

Disclosure of De-identified Information

We may share aggregated or de-identified information with third parties for research, marketing, analytics, and other purposes, provided such information does not identify specific individuals.

7. Accessing and correcting your personal information

In certain jurisdictions, you have rights concerning your personal information. To stop receiving marketing communications, you may follow the unsubscribe instructions in marketing materials or request to opt out by contacting support@uptrade.au.

Depending on your country of residence, you may have additional rights, including the right to:

• Withdraw consent or object to processing
• Access the personal data we hold about you
• Correct or update your personal information
• Request the restriction of processing or deletion of your personal data

You can exercise these rights at any time by emailing support@uptrade.au.

8. Complaints

If you believe we have mishandled your personal information in violation of privacy laws or this privacy policy, please contact us at support@uptrade.au to address and resolve your concerns. We treat privacy complaints with utmost seriousness and will review, investigate, and respond to your complaint promptly and efficiently.

If you are unsatisfied with our response, you have the option to file a complaint with the Office of the Australian Information Commissioner at 1300 363 992 or via email at enquiries@oaic.gov.au.

9. Our Contact Details

For additional information about our privacy policy, please direct your inquiries to our Data Protection Officer at L2, 306 Collins St. Melbourne VIC 3000, Australia or contact us by email at support@uptrade.au.

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