Privacy Policy — MiningBull

1. Privacy generally

This privacy policy applies to the handling of personal information by Mining Data Solutions Pty. Ltd. ACN 663 817 945 as trustee for Mining Data Solutions Trust ABN 92 203 183 462 trading as MiningBull (MiningBull, we us, our).

In operating our online platform for providing information and market data to investors, traders and others and undertaking our other related activities and operations, MiningBull may collect personal information about you.

MiningBull understands the importance of protecting the privacy of an individual’s personal information. This privacy policy sets out how MiningBull aims to protect the privacy of your personal information, your rights in relation to your personal information managed by MiningBull and how MiningBull collects, holds, uses, discloses, and otherwise manages, your personal information.

MiningBull will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time. Any updated privacy policy will be made available on our website at www.miningbull.com.au or can otherwise be obtained by contacting us and requesting a copy.

2. Kinds of personal information collected

Personal information includes information or an opinion about an identified, or reasonably identifiable, individual.

As a result of providing our online platform or our other interactions or dealings with you, MiningBull may collect your personal information.

The kinds of personal information that MiningBull collects will vary depending on our particular interactions or dealings with you. However, generally speaking, the kinds of personal information MiningBull collects may include:

(a) contact information such as your name and email address;

(b) information we may require to verify your identity such as your current address, mobile phone number, and other personal information that we may require for identity verification purposes;

(c) credit card or other payment facility details regarding you to process any subscription or other payments you make to us;

(d) information relating to your use of our products or services or information relating to your correspondence or dealings with us; and

(e) information you disclose to our customer support team.

MiningBull may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.

Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law (for example, information about whether you are a politically exposed person or subject to other sanctions).

3. How we collect personal information

Generally, MiningBull collects your personal information directly from you. For example, MiningBull may collect your personal information:

• when you register for an account to use our online platform;
• when you use our online platform or other products or services;
• when you request information or services from us or otherwise provide us with your details;
• where you use our website or other services or otherwise interact with us;
• when you complete a survey; or
• if you post information to any of our social media sites.

There may be occasions when MiningBull collects your personal information from someone other than you, for example:

• from third parties you authorise to disclose your information to us;
• from a publicly maintained record or other publicly available sources of information including social media and similar websites; or
• from our vendors, suppliers or contractors that help us provide our products or services to you.

Generally, MiningBull will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you.

4. Purposes for which personal information is used

Generally speaking, MiningBull collects and uses personal information so that we can operate our platform for providing information and market data to investors, traders and others and undertaking our other related activities and operations.

Some examples of the purposes for which MiningBull collects, holds, uses and discloses your personal information include to:

• open an account for you to be able to access our platform;
• provide you with access to our platform and manage and administer your access to our platform;
• supply our other products or services to you;
• enable us to supply you with information you request from us;
• personalise and customise your experience and interaction with our platform;
• communicate with you regarding your use of our platform or other products or services
• conduct promotions and events;
• inform you of news, features or other developments that may be of interest to you;
• contact you to obtain your feedback regarding our services or to conduct other market research;
• undertake direct marketing (as detailed in paragraph 5 below);
• analyse information we collect so that we can administer, support, improve and develop our business and the services we offer; and
• comply with the obligations of MiningBull under any applicable laws.

In addition to the purposes listed above, MiningBull may use your personal information for other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law.

Where personal information is used or disclosed, MiningBull takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to MiningBull. However, without certain information from you, MiningBull may not be able to provide services or information to you or may be limited in how we can interact with you.

5. Direct marketing

In addition to the purposes outlined in paragraph 4 above, MiningBull may use your personal information in order to inform you of promotions, competitions, giveaways, events, products or services that may be of interest to you. This may include MiningBull using your personal information for the purpose of promoting products and services of MiningBull or the third party commercial partners of MiningBull, however MiningBull will not provide your information to such third party commercial partners for direct marketing purposes without your consent. If you do not wish to receive such communications, you can opt-out by contacting MiningBull via the contact details set out in paragraph 11 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you.

6. Disclosure of personal information

MiningBull discloses your personal information for the purpose for which MiningBull collects it. As a result, generally, MiningBull will only disclose your personal information for a purpose set out in paragraphs 4 and 5 of this privacy policy. This may include disclosing your personal information to:

• related companies of MiningBull;
• our service providers, contractors and other third parties that provide products or services to us (including our technology service providers, payment processors, verification services and administration service providers);
• other third parties that are integral to the provision of our services;
• people or entities considering acquiring an interest in MiningBull’s business or assets;
• other parties who invest in or acquire an interest in MiningBull;
• MiningBull’s professional advisors (including legal and accounting firms, auditors, consultants, insurers and other professional advisers); and
• Government authorities where required by law.

MiningBull may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or the disclosure is required or authorised by law.

If you post information or other content to public sections of our website or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

7. Overseas disclosures

MiningBull works with selected overseas technology and other vendors who may process or have access to your personal information. Where possible MiningBull will require that these vendors store any data and personal information they collect from MiningBull in Australia. However some of these vendors may be located outside Australia, such as our software development vendors located in Bangladesh.

8. Links to other websites

When you access our website, platform or other online services, we may provide as a convenience to you links to other websites, including sites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you. Each website has its own privacy practices, as described in that site’s privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that site. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot and are not responsible for any information that you may submit to that site.

9. Security of personal information

MiningBull takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.

Your personal information that MiningBull holds will be kept on secured physical and technological environments, with measures in place to seek to limit access only to authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises. 

We have in place procedures for training our employees about their obligations under this privacy policy, disciplining them for failure to follow this privacy policy. We also have in place internal procedures to confirm general company compliance with this privacy policy.

MiningBull will destroy or de-identify personal information in circumstances where it is no longer required, unless MiningBull is otherwise required or authorised by law to retain the information.

Where you have an account with us, you are responsible for maintaining the confidentiality of your user name and password. You will be responsible for all uses of your account, whether or not authorised by you. You agree to immediately notify MiningBull of any unauthorised use of your user name or password.

10. Access and correction

MiningBull takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.

You have the right to seek access to and correction of your personal information that is collected and held by MiningBull. If at any time you would like to access or correct the personal information that MiningBull holds about you, or you would like more information on MiningBull’s approach to privacy, please contact the MiningBull Privacy Officer using the details set out in paragraph 11 below. MiningBull will grant access to the extent required or authorised by law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.

To obtain access to your personal information:

• you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
• MiningBull requests that you be reasonably specific about the information you require; and
• MiningBull may charge you a reasonable administration fee, which reflects and will not exceed the cost to MiningBull for providing access in accordance with your request.

MiningBull will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If MiningBull refuses your request to access or correct your personal information, MiningBull will provide you with written reasons for the refusal and details of complaint mechanisms.

If you are dissatisfied with MiningBull’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

11. Contacting MiningBull

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact MiningBull’s Privacy Officer using any of the following contact details:

Email: info@miningbull.com.au

Website: https://www.miningbull.com.au/contact-us/

Post: 805, 220 Collins Street Melbourne, VIC 3000

12. Privacy complaints

Please direct all privacy complaints to MiningBull’s Privacy Officer. At all times, privacy complaints:

• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations or affect the commercial arrangements between you and MiningBull.

MiningBull will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless MiningBull informs you otherwise and seeks your agreement in writing.

MiningBull’s Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which MiningBull will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.

The OAIC contact details are below: