Privacy Policy

Privacy Policy

This Privacy Policy (policy) applies to The Trustee for JMP Strategic Investment Trust (ABN 20 161 825 667) and its subsidiaries (the Group, Trade Profitably, we, us, our). The Group includes John Pontikas and JMP Strategic Investments Pty Ltd (ACN 154 187 952).

Trade Profitably abides by the Australian Privacy Principles (APPs) established under the Privacy Amendment (Enhancing Privacy Protection) Act, 2012.

Trade Profitably may, from time to time, review and update this privacy policy statement to take account of new laws and technology, and changes to Trade Profitably’s operations. All personal information held by Trade Profitably will be governed by its most recent policy, posted on the Trade Profitably website.

What kind of personal information we collect and how it is collected

Trade Profitably collects personal information from a variety of sources including from members of the public, prospective employees, contractors and business partners. In general, the personal information Trade Profitably collects includes (but is not limited to) name, address, contact details including email address, residential and mailing address and, where relevant, financial information, including credit card information, banking details and income information.

We store the personal information you enter on the Trade Profitably website or give to Trade Profitably in other ways. We obtain most personal information through Trade Profitably's membership registration process and updates to membership details. You may provide information when you request or acquire a product or service from Trade Profitably, complete a survey or questionnaire, or when you communicate with Trade Profitably by e-mail, telephone or in face to face interviews or in writing (for example if you contact customer service or provide feedback).

Failure to provide the information referred to above may result in Trade Profitably being unable to provide all its services to a Client, or may prevent Trade Profitably from complying with all legal or regulatory requirements.

Information Collected Online:

Trade Profitably's website contains links to other websites whose operators may or may not adhere to a privacy policy or be governed by the Australian Privacy Principles.

While it is not necessary for a Client to register the Client's personal details to use Trade Profitably's website, the company does offer a registration service which will enable Clients to receive market news and market research reports and access to the Client's accounts with Trade Profitably.

If the Client registers with Trade Profitably and decides, at any time, that the Client does not wish to receive any further information from Trade Profitably, the Client can send an email to john.pontikas@jmpsi.com.au requesting to be removed from Trade Profitably's online registration database. Clients should allow two weeks for such a request to be actioned.

Clients may amend or update their registration details by sending an e-mail to john.pontikas@jmpsi.com.au providing their amended details. Clients should allow two weeks for such a request to be actioned.

Cookies: Trade Profitably's website uses cookies, pixel tags, web beacons and similar technologies on this site. We use them to conduct analytics that help us understand how our site is being utilised so that we can make it better. We also allow third parties to place cookies and collect Non-Personal Information. Some of these third parties provide functionality such as social networking or sharing functionality on the site. Other third parties help us conduct site analytics. While still other third parties may help collect information to be used to target advertising as described below. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. You can also delete the cookie we set for you. This will eliminate our ability to link your past behavior with future behavior, but we will be able to monitor your future behavior based on a new cookie we supply.

Third Party Advertisers: We may use third-party advertising companies to serve ads on the site and/or on the sites on which we advertise. Please note that these companies may use information (not including Personal Information) about your visit to the applicable site in order to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements, these companies may place or recognize a unique cookie on your browser. In addition, we may use web beacons provided by third-party advertising companies to help manage our online advertising. These web beacons enable us to recognize a browser’s cookie when a browser visits this site and to learn which banner ads bring users to our Site. To learn more about our third-party advertising companies, cookies, and how to “opt-out,” please email John.pontikas@jmpsi.com.au

Indirect Collection:

Trade Profitably endeavours to collect personal information about an individual only from that individual. In some circumstances Trade Profitably may obtain personal information from a third party. If you provide personal information about another person to Trade Profitably, Trade Profitably requires that you inform that person you have done so and provide them with a copy of this policy.

Information Use and Disclosure

Trade Profitably may use information it collects from you for the primary purpose for which it is collected and for such other secondary purposes that are related to the primary purpose of collection. Trade Profitably generally uses personal information to:

• provide you with products or services you have requested;
• personalise and customise your experiences on the Trade Profitably website;
• help Trade Profitably manage and enhance its services;
• communicate with you;
• provide you with ongoing information about opportunities in which Trade Profitably believes you may be interested;
• give you the opportunity from time to time to receive e-mail and 'e-newsletters' from Trade Profitably

In most cases where Trade Profitably asks you to provide information about yourself. if you do not provide Trade Profitably with that information, Trade Profitably will not be able to provide you with the requested product or service.

Trade Profitably will not use or disclose personal information collected by it for any purpose other than:

• the purposes for which it was provided or secondary related purposes in circumstances where the Client would reasonably expect such use or disclosure; or
• where the Client has provided written consent to such disclosure; or
• where the Australian Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

Without limiting the generality of the foregoing paragraphs Trade Profitably will use and disclose personal information collected by it as foresaid as follows:

• using or disclosing the information as required by the ASX Business Rules, the Corporations Act or any other applicable law;
• using the information internally to determine future strategies and to develop services and to market those services;
• disclosing the information to issuers of financial products marketed by Trade Profitably; and
• disclosing a Client's tax file number (if supplied) to companies in which investments are made on a Client's behalf.

Trade Profitably is required under the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission.

Clients can be assured that their information will be maintained by any employee, agent or representative of Trade Profitably in accordance with this policy. If Clients have any concerns in this regard, they should contact Trade Profitably by any of the methods detailed below.

Trade Profitably may disclose a Client's personal information to external contractors or agents for the purpose of providing certain services. It is a condition of Trade Profitably's agreement with each of its external contractors and agents that they adopt and adhere to this privacy policy.

Clients can be assured that Client personal information will be maintained by any contractor or agent to whom it is disclosed in accordance with this policy. If Clients have any concerns in this regard, they should contact Trade Profitably by any of the methods detailed below.

In the event that Trade Profitably proposes to sell its business it may disclose Clients' personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence, and where appropriate, after obtaining the necessary consent from the individual, and it will be a condition of that disclosure that no personal information will be used or disclosed by them. In the event that a sale of Trade Profitably's business is affected, Trade Profitably may transfer Clients' personal information to the purchaser of the business. A Client will be advised of any such transfer.

Management and Security of Personal Information

Trade Profitably has appointed a Privacy Officer to oversee the management of personal information in accordance with this policy and the Commonwealth Privacy Act. At all times Clients' personal information will be treated as confidential and any sensitive information is treated as highly confidential. Trade Profitably protects the personal information Trade Profitably holds from misuse, loss, unauthorised access, modification or disclosure by various means including firewalls, password access, secure servers and encryption of credit card transactions.

Updating Personal Information

Trade Profitably will endeavour to ensure that, at all times, the personal information about its Clients, which it holds, is up to date and accurate. In the event that a Client becomes aware, or believes, that any personal information which Trade Profitably holds about the Client is inaccurate, incomplete or outdated, the Client may contact Trade Profitably by any of the methods detailed below and provide to Trade Profitably evidence of the inaccuracy or incompleteness or outdatedness and Trade Profitably will, if it agrees that the information requires correcting, take all reasonable steps to correct the information.

If Trade Profitably does not agree that a Client's personal information requires correcting, it must, if the Client requests, take reasonable steps to ensure that whenever the Client's personal information is accessed or handled in the future, it is made apparent that the Client is not satisfied as to the accuracy or completeness of that information.

Access to Information

Clients may contact Trade Profitably at any time, by any of the methods detailed below, to request access to their personal information and Trade Profitably will (subject to the following exceptions) provide the Client with access to that information either by providing copies of the information requested, allowing the Client to inspect the information requested or providing the Client with an accurate summary of the information held.

Trade Profitably will, prior to providing access in accordance with this policy, require Clients to provide evidence of their identity. Trade Profitably may charge a fee to cover the costs of meeting your request. Trade Profitably will not provide the Client with access to the Client's personal information if:

• providing access would pose a serious threat to the life or health of a person;
• providing access would have an unreasonable impact on the privacy of others;
• the request for access is frivolous or vexatious;
• the information related to existing or anticipated legal proceedings between Trade Profitably and the Client and would not be discoverable in those proceedings;
• providing access would reveal Trade Profitably's intentions in relation to negotiations with the Client in such a way as to prejudice those negotiations;
• providing access would be unlawful;
• denying access is required or authorised by or under law;
• providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

In the event Trade Profitably refuses a Client access to his, her or its personal information, Trade Profitably will provide the Client with an explanation for that refusal. Trade Profitably will endeavour to respond to any request for access within 14 - 45 days depending on the complexity of the information and/or the request. If the request is urgent the Client should indicate this clearly.

Privacy Complaint

If a Client wishes to complain about any breach or potential breach of this Privacy Policy or the Australian Privacy Principles, the Client should contact Trade Profitably by any of the methods detailed below and request that the complaint be directed to the Privacy Officer. Complaints will be considered within 7 days and responded to.

It is Trade Profitably's intention to use its best endeavours to resolve any complaint to a Client's satisfaction, however, if a Client is unhappy with Trade Profitably's response, the Client is entitled to contact the Office of the Privacy Commissioner, which may investigate the Client's complaint further.

How to contact Trade Profitably

John Pontikas +61 405 730 515

john.pontikas@jmpsi.com.au