Wholesale Investor & CapitalHQ Privacy Policy


Your privacy is important to Wholesale Investor Pty Ltd (WI). WI is bound by the Privacy Act 1988 (Cth) (Act) which adopts a number of principles known as the Australian Privacy Principles (APP). The APPs govern the way we collect, use, disclose, store, secure and dispose of your personal information. You can view the APPs at

In the process of registering your interest in the provision of services by WI, WI will collect personal information about you. Our primary purpose in collecting personal information from you is to enable us to provide services to you. We need this information for the purposes listed below and if you choose not to provide the information requested, we may not be able to provide services to you or notify you of events or activities.

This information may be used for related purposes, such as:

(1) to assist in providing services to you;
(2) to assist with any calls you make to us;
(3) for any purpose made known to you at the time of collection of your personal information;
(4) for our internal administrative, marketing and planning requirements; and
(5) in connection with any applicable laws.

We usually disclose information of this kind to:

– Corporate Advisors handling matters;
– third parties such as Share issuers; or
– anyone you have authorised.

1. Collecting personal information

Personal information is information or an opinion of an individual whose identity is apparent or can be reasonably ascertained. We usually collect personal information about an individual from that individual and from the following sources:

(a) through our website;
(b) from other interactions with us, whether by telephone, email, ordinary mail or any other electronic or online means; and/or
(c) through any of our other business activities or events.

Personal information collected by us typically includes an individual’s:

(a) full name;
(b) contact details such as mobile number, telephone number and email address;
(c) physical or residential address;
(d) qualifications and education;
(e) occupation and employer;
(f) all logs, which may include information such as your internet protocol (IP) address, browser type, browser version, clickstream data, referring URLs, the pages of our websites that you visit, the time spent on any pages of our websites and other log related information relating to your use of any of our websites, (Personal Information)

Collection from third party operators

To facilitate the operation of the Site, Platform Operator performs automated information collection when integrating with third party services such as Google Accounts, LinkedIn, Google Drive and Dropbox.

When logging in with Google Accounts or LinkedIn, Platform Operator will access your full name, email address and avatar image as provided with the account synchronisation process.

When synchronising files from Dropbox or Google Drive, Platform Operator will request read only access to your nominated account in order to facilitate the serving of files to contacts you nominate.

Additionally, Google Drive synchronisation will request full read, write and edit permissions to facilitate the export of native Google Documents (Sheets, Docs, Slides and Drawings) to contacts you nominate.

2. Use and disclosure of Personal Information

We automatically gather information to monitor your use of our websites and the provision of our services to you. In general we use Personal Information for evaluating, improving, personalising and developing our business. More specifically we use Personal Information:

(a) for maintaining our relationships with those that we provide our services to;
(b) for administering, managing and delivering the services we provide;
(c) for improving our services;
(d) for our own internal research and statistical purposes;
(e) for hosting events in conjunction with our services;
(f) to promote and market products and/or services provided by us or our associated entities and parties that we believe will be of interest and/or benefit to you; and
(g) to disclose to other entities and parties so that they may promote and market products and/or services to you that we believe will be of interest and/or benefit to you.

WI takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.

Other than for purposes referred to above, unless we are legally required or compelled by a law enforcement or government agency, we will not disclose your Personal Information to any third party without your consent.

When using your Personal Information for the purposes contemplated above, we use our best endeavours to anonymize that information such that any personally identifiable information is removed from the data where possible

3. Storage and Security

Although no method of transmission and storage of private information on the internet can be guaranteed to be completely secure, the security and protection of your Personal Information is important to us. We store your Personal Information in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information.

4. Accessing and updating your Personal Information

4.1 Access to Personal Information

We will provide you with access to your Personal Information held by us unless:

(a) giving access would be unlawful; or
(b) denying access is required under the Privacy Act or any other applicable law.

4.2 Request for Access

If you would like access to your Personal Information aside from your account information, you must contact us in writing making such a request. You may contact us via email at [email protected]. Following receipt of your request, we will contact you and either provide you with the information you have sought, or return to you with an explanation detailing why we will not provide you with the information.

4.3 Amending your Personal Information

If you wish to amend Personal Information that we hold, please contact us to request the amendment. You may contact us by emailing [email protected]. If we elect not to correct your information, we will notify you, within a reasonable time, of the reason for our refusal, the mechanisms available for you to complain about our refusal and such other matters required by the Privacy Act.

If you wish to have your Personal Information deleted, please let us know and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.

5. Marketing

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing or by following the unsubscribe link or instructions provided in any email we send.

6. Your data

We collect information that your browser sends whenever you visit our website (Data).
This Data may include information such as your computer’s IP address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and examine this type of information in order to increase our websites functionality. These third party service providers have their own privacy policies addressing how they use such information.

7. Cookies

WI may collect aggregated information by using cookies or similar electronic tools. Cookies are files with a small amount of data that are placed on the browser of a website user. The cookies are used to retain login and location information in order to make your experience more convenient and personal.

We use cookies; however, you can instruct your computer to refuse all cookies or to indicate when a cookie is being sent. If you do not accept cookies, you may not be able to access some portions of our website. WI does not use cookies to track your internet activity before or after you leave our website. No other business has access to WI’s cookies.

8. Complaints

We strive to ensure our compliance with this Policy and to regularly review our practices against it.

If at any time you have a complaint against us regarding our Policy, including a breach of the Privacy Act, we invite you to make a complaint at [email protected]. All complaints made will be dealt with in confidence. We endeavour to respond within 30 days of receipt of a complaint with a resolution or proposed resolution to the issue raised.

If you are dissatisfied with our response to your compliant you may make a further complaint to the Office of the Australian Information Commissioner about the handling of your Personal Information. Information on making a privacy complaint can be found on their website at

The WI Privacy Policy Statement sets out WI’s policies on management of Personal Information. A copy may be obtained from WI in the following ways:

Web site:
Email: [email protected]
Phone: 1300 597 595

Under the National Privacy Principles, you may access personal information about you held by WI and you may contact us as above if you think any of it is inaccurate, incomplete or out of date. There are some limited situations, which are set out in the National Privacy Principles, where you will not have this right.

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