Privacy Policy

Definitions

In this policy, "personal information" means information or an opinion about an identified or reasonably identifiable individual; "personal data" is used in the same sense where European-style terminology reads more naturally. "We", "us" and "Worthamence" mean the operator of this platform; "you" means the visitor, registrant or client the information is about. "Processing" covers everything done with information: collecting, holding, using, disclosing and destroying it. "Account data" means information connected to your use of the platform once registered.

Personal data we collect

When you register we ask for your first and last name, email address, telephone number and a password, and the account itself accumulates the content of requests you send us. These are the categories the service minimally requires: without a name we cannot identify you, without contact details we cannot reach you, and without a record of your requests we cannot answer them. Verification under our AML and KYC policy adds identity document details and, where applicable, a liveness capture, each collected for that specific purpose.

If you become a client, further categories follow from the service: transaction records, payment method details, strategy settings and communications with support. We do not collect special categories of information beyond what verification lawfully requires, and we do not buy profiles about you from data brokers.

Usage data

When you use the site, standard technical information is recorded: pages requested, approximate timing, referring pages, browser and device characteristics, and an abbreviated network address. This usage data keeps the service running and secure: it diagnoses faults, detects abuse, and shows which pages confuse visitors so they can be fixed. Usage data is aggregated for analysis and is not used to build a profile of you as an individual beyond what the service requires.

Cookies

Cookies and equivalent browser storage are used for three purposes: keeping you signed in during a session, remembering interface preferences, and aggregate measurement of how the site is used. Strictly necessary cookies, those that carry authentication and security functions, are placed without separate consent because the service cannot operate without them. Preference and measurement cookies are placed only where you accept them in the consent banner, and your choice can be changed at any time from the banner's link. We do not use cookies to sell your attention to advertising networks.

Operator and processors

Worthamence is the operator of this platform and the primary handler of the personal information described here. Where another entity processes information on our instructions, such as a hosting provider, an identity-verification service or an email-delivery provider, it acts as a processor: bound by contract to handle information only as instructed, with security obligations and use restrictions, and without rights to use it for its own purposes. The categories of such providers are described in the service-providers section below.

Collection and use of information

Information is used to answer your enquiries, to provide and administer the service you asked for, to verify identity where the law and the service require it, to process deposits and withdrawals, to communicate operational matters to you, to keep the platform secure, and to meet legal obligations that apply to our activities. Marketing use, where you have opted in, is limited to the topics you accepted and is withdrawable at any time. We do not use personal information for purposes incompatible with the ones it was collected for, and we do not require more information than the purpose needs.

Legal bases for processing

Processing rests on recognised legal bases, applied by purpose. Performance of a contract or taking steps at your request covers registration, service delivery and payment processing. Compliance with a legal obligation covers identity verification, record keeping and disclosures required by law. Legitimate interests, balanced against your rights, cover service security, fault diagnosis and aggregate improvement of the platform. Consent, where Australian privacy principles or comparable rules call for it, covers optional cookies and optional marketing, in each case specific, informed and withdrawable. Where verification is required by law, refusing it is not an option we can waive; where consent is the basis, refusing costs you only the optional feature it enabled.

Data storage and retention

Personal information is stored on systems with access controls and encryption as described in the security section below, retained no longer than the purposes and legal obligations require. Registration and enquiry data is kept while an enquiry is open and for a reasonable period after, then removed or anonymised. Client account data is retained for the life of the relationship and for the period the law prescribes after it ends, particularly records that verification and tax rules require us to keep, which generally means several years after closure. Verification records follow the retention schedule in the AML and KYC policy. When a retention period ends, information is securely destroyed or irreversibly anonymised; backups age out on fixed cycles rather than being mined for expired records.

Transfer of data

Our operations and providers are arranged so that personal information is handled within jurisdictions that provide appropriate protection for the information of Australians. Where a provider or process involves handling in another country, the arrangement is made only where the handling is protected by contractual safeguards or comparable mechanisms, and the countries involved are recorded so we can answer where your information is, rather than guess.

Disclosure of information

Personal information is disclosed only within defined categories: processors acting on our instructions under the service-provider arrangements; executing venues and payment providers that need specific details to perform the transactions you request; professional advisers where advice requires relevant facts; and regulators, authorities or courts where a lawful requirement to disclose exists. We do not sell personal information, do not trade it for value, and do not disclose it for third parties' own marketing. Disclosures are recorded so that questions about a specific disclosure can be answered from the record.

Security of information

Information is protected by the layered measures described on our security page: encryption in transit and at rest, strict access rights limited to roles that need the information, two-factor authentication for accounts, audit trails over security-relevant events, and incident procedures that put locking and client notification before reputation management. No system is perfectly secure, and we do not pretend otherwise, but the measures are maintained, reviewed and improved rather than installed once and trusted forever.

Your rights over your information

You have the right to access the personal information we hold about you, and to have it corrected where it is inaccurate, incomplete or out of date. You have the right to request deletion of information we no longer have a lawful reason to keep, noting that obligations like verification record-keeping can lawfully outlive your interest in deletion. You have the right to restrict or object to particular processing, most relevantly to marketing, and to withdraw consent where consent is the basis, without affecting the lawfulness of earlier processing. Where the rules applicable in Australia or comparable frameworks give you additional rights, such as data portability in defined circumstances, we honour them on the same footing.

To exercise any right, write to [email protected]. We respond within a reasonable period, typically well inside thirty days, and where we cannot do what you ask because an obligation prevents it, we tell you which one and what we can do instead.

Service providers

The categories of provider that process information on our instructions are: hosting and cloud infrastructure that runs the platform; identity-verification services that check documents; email-delivery services that carry operational and optional messages; analytics tooling that measures aggregate site use; payment providers that execute the methods described on the methods page; and customer-support tooling that manages your enquiries. Each receives only the information its function requires, and none is entitled to use it for its own purposes.

Analytics

We measure how the site is used with aggregate analytics: which pages are visited, where visitors arrive from, what fails to load, and where friction appears. Analytics output is used to repair and improve the service. Where an analytics tool uses cookies that are not strictly necessary, it runs only with the consent recorded in the banner, and withdrawing consent switches it off. Analytics is not used to make automated decisions about you with legal or similarly significant effect; nothing about your access to the site is decided by a profile.

Advertising and retargeting

We do not run third-party advertising networks on this site, and we do not retarget you across other websites with trackers placed here. Where we advertise the service on third-party platforms, those platforms apply their own measurement under their own policies; the site itself places no cross-site advertising cookies. If that position ever changes in a way that affects you, this policy and the consent banner will say so before it does.

Links to third-party sites

The site links to third-party resources for information and convenience, such as payment providers' help pages. Once you follow a link, this policy no longer governs: the destination's own terms and practices apply. We choose links carefully but do not control other sites, and the absence of a link is not a judgement; the presence of one is not an endorsement of everything behind it.

Children's privacy

The service is directed to adults and is not intended for individuals under 18. We do not knowingly collect personal information from children. Where we learn that information about a child has been provided, we delete it as soon as the verification and legal machinery around that fact permits. If you believe a child's information has reached us, contact the address below so the deletion can begin.

Changes to this policy

This policy can be updated to reflect changes in our practices, providers or legal obligations. Material changes are announced on the platform before they take effect, and where a change concerns consent, your existing choices carry over until you change them. The version in force is always the one on this page, and using the service after a change takes effect means accepting the current version. Past versions are available on request so that what applied at a given time can be checked rather than argued about.

Contacting us

Questions, requests and complaints about privacy go to [email protected], during support hours Monday to Friday, 9:00-17:30 AEST, or by post to Level 11, 385 Collins Street, Melbourne VIC 3000, Australia. Written requests receive written answers, so there is always a record of what was asked and done.