1. Introduction

HALO Technologies Pty Ltd ACN 623 830 866 (HALO, we, us or our) is committed to protecting your privacy and handling your personal information in an open, transparent and secure manner.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy applies to:

• the HALO Investment Research platform and software (Platform)
• the website located at www.halo-technologies.com (Website)
• our products, services and related business activities.

HALO Technologies Pty Ltd is a Corporate Authorised Representative (CAR No. 001261916) of Macrovue Pty Limited ACN 600 022 679 AFSL 484264. These entities are wholly owned subsidiaries of HALO Technologies Holdings Ltd ACN 645 531 219.

2. The personal information we collect

We collect personal information that is reasonably necessary for us to provide our products and services, operate our business, and comply with legal and regulatory obligations.

The personal information we collect may include:

• name
• residential or business address
• date of birth
• telephone number and email address
• occupation and employment information
• tax residency and taxation information
• government identification details (such as passport or driver licence details)
• bank account and payment details
• account, transaction and investment information
• company, trust and beneficial ownership information
• communications and correspondence with us
• technical and usage information relating to use of our Platform or Website.

In some circumstances, we may collect sensitive information where permitted or required by law, including:

• politically exposed person (PEP) information
• sanctions screening results
• biometric or identity verification information where electronic verification services are used
• information relevant to fraud prevention, AML/CTF compliance or risk assessments.

3. Why we collect your personal information

We collect and use personal information to:

• establish and manage customer accounts
• provide access to our products and services
• verify your identity
• comply with legal and regulatory obligations, including obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
• conduct customer due diligence and ongoing monitoring
• assess and manage fraud, cybersecurity, sanctions and compliance risks
• communicate with you regarding our products and services
• improve our Website, Platform and customer experience
• provide customer support
• conduct analytics, reporting and business administration
• market products or services that may be relevant to you where permitted by law.

If you do not provide requested personal information, we may be unable to provide you with some or all of our products or services.

4. How we collect personal information

We generally collect personal information directly from you when you:

• apply for or use our products or services
• create an account
• complete onboarding or verification processes
• use our Website or Platform
• contact us by phone, email or online
• participate in surveys, promotions or events
• provide documents or other information to us.

We may also collect personal information from third parties, including:

• electronic identity verification providers
• government agencies and public registers
• credit reporting bodies
• financial institutions
• your authorised representatives or advisers
• related entities
• service providers and contractors
• publicly available sources.

5. Cookies, analytics and website tracking

Cookies

Our Website and Platform use cookies and similar technologies to improve functionality, performance and user experience.

Cookies are small data files stored on your device that help websites recognise users and remember preferences.

How we use cookies

We use cookies and related technologies to:

• operate and maintain our Website and Platform
• improve functionality and user experience
• analyse usage and performance
• identify technical issues and security risks
• understand user interactions and preferences
• support marketing and advertising activities.

Analytics and third-party technologies

We may use third-party analytics and tracking providers to collect information such as:

• pages visited
• time spent on pages
• browser type and device information
• IP address and general location information
• referral sources and interactions with content.

This information is generally aggregated and used to improve our products and services.

Managing cookies

You can control or disable cookies through your browser settings. However, disabling cookies may affect Website or Platform functionality.

6. Disclosure of personal information

We may disclose personal information to:

• related entities within the HALO group
• financial services licensees and authorised representatives
• technology, cloud hosting and software providers
• identity verification and AML/CTF service providers
• payment processors and financial institutions
• professional advisers, auditors and consultants
• customer support providers
• regulators, courts, tribunals, law enforcement agencies and government authorities
• other parties where disclosure is authorised or required by law.

We may disclose personal information to AUSTRAC where required under the AML/CTF Act.

From time to time, your adviser or authorised representative within our licensed group may change. Where this occurs, your personal information may be disclosed to your new adviser or authorised representative to ensure continuity in the provision of products, services and support. We will notify you of any such change where required or appropriate.

7. Overseas disclosure

Some service providers we use may store or process personal information outside Australia.

Where personal information is disclosed overseas, we take reasonable steps to ensure that recipients handle the information in accordance with applicable privacy and data protection laws.

8. Data security and storage

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure.

These measures may include:

• secure systems and infrastructure
• access controls and authentication
• encryption and cybersecurity protections
• monitoring and incident response processes
• staff training and confidentiality obligations.

No method of electronic transmission or storage is completely secure. However, we take reasonable steps to safeguard your information.

9. Retention of personal information

We retain personal information only for as long as necessary to:

• provide our products and services
• comply with legal, regulatory and record-keeping obligations
• resolve disputes and enforce agreements.

Where information is no longer required, we will take reasonable steps to destroy or de-identify it.

10. Direct marketing

We may send you information about products, services or updates that may be relevant to you where permitted by law.

You may opt out of receiving marketing communications at any time by:

• using the unsubscribe function in communications, or
• contacting us using the details below.

11. Accessing and correcting your information

You may request access to the personal information we hold about you and request correction of inaccurate, incomplete or outdated information.

Requests may be made using the contact details below.

We will respond within a reasonable timeframe and may require verification of identity before processing requests.

12. Anonymity and pseudonymity

Where lawful and practicable, you may interact with us anonymously or using a pseudonym.

However, this may not be possible where we are required by law to identify you, including under AML/CTF obligations.

13. Complaints

If you have a complaint about how we handle your personal information, please contact us using the details below.

We will investigate complaints and respond within a reasonable timeframe.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

Website: www.oaic.gov.au
Phone: 1300 363 992

14. Contact us

Privacy Officer

HALO Technologies Pty Ltd
Suite 203, Level 2, 1 York Street
Sydney NSW 2000

Email: compliance@halo-technologies.com
Phone: 1300 348 007

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, legal obligations or privacy practices.

The updated version will be published on our Website with the revised "Last updated" date.