Diverger Limited (Diverger)
Diverger believe that privacy is an important individual right and are committed to ensuring the privacy of personal information. We are bound to comply with the Australian Privacy Principles (APPs) subject to the Privacy Act 1988 (Cth) (the Act).
When will we collect your personal data?
Diverger only collects personal information if it is necessary or incidental to our business purposes. We note that Diverger has out-sourced the share registry function and, as such, Diverger does not collect or maintain share registry information, although it does have access to that information in the normal course of business.
The types of personal data that we collect from you
The information we collect may be limited to contact details where we interact with the public over the telephone or in person, or when you send us correspondence (whether by letter, fax, website facility or e-mail). In general, the type of personal information we collect and hold includes, but is not limited to: names, addresses, contact details, occupations and other information which assist us in conducting our business.
Diverger receives personal information from our website www.diverger.com.au through it being accessed and through use of the ‘make an enquiry’ facility. Your use of our website will determine the extent and type of information collected. In general, you can visit our website without revealing any personal information about yourself. Your name, contact number and email address will only be recorded if you send us a message, and will only be used for the purpose for which you have provided it. It will not be added to a mailing list or used for any other purpose without your consent, after which it may subsequently be removed at your request.
Use of Personal Information
We use personal information for the primary purpose for which it is collected or received. That may include responding to an individual’s request. We may also use and disclose personal information for purposes related or ancillary to the main reasons we collect it. We will not use your personal information for any purpose which is not related to the functions or activities of Diverger, or for any purpose for which you would not reasonably expect us to use the information. Reasonable steps are taken to ensure that personal information is accurate, complete and up-to-date whenever Diverger receives or uses it.
Disclosure of your personal data
Diverger only shares personal information where we are required to do so in order to comply with our legal and statutory obligations. As noted above, Diverger has access to share registry information, but does not share such information unless required to do so in compliance with its regulatory disclosure obligations.
Storage and Security of Information
Diverger takes all reasonable measures to ensure the security of data supplied, and to protect it from misuse, unauthorised access, modification or disclosure.
In relation to security on the Diverger website at www.diverger.com.au, mechanisms are in place to protect the security and integrity of your personal information. However, no data transmission over the internet can be guaranteed as completely secure so any information that you provide to us over the internet is at your own risk.
Access to and Correction of Personal Information
We will provide access to personal information upon request by an individual, unless a request is unreasonable and the APPs would permit us to decline that access. We will require you to verify your identity and to specify what information you require.
Persons who wish to gain access to their personal information should contact Diverger by writing to:
The Privacy Officer
Level 7, 115 Pitt Street, Sydney
Attention: Company Secretary
In some cases, we may request an administrative fee to cover the cost of access. If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exemptions relied upon under the Act.
You should notify Diverger of a change to personal information or if you believe that the information held is incorrect or incomplete.
Your Computer and the Diverger website including links to other websites
“Cookies” are pieces of information that may be transferred to your computer’s memory when you visit a website for record keeping purposes. Any website server (including Diverger’s) may:
- store one or more cookies in your browser; or
- request your browser to transmit the data to the Web server.
Our website may store cookies on your computer in order to better serve you upon your subsequent visits to the Diverger website. We may track usage patterns on our website on an anonymous aggregate basis, however your identity cannot be reasonably ascertained from this information.
The data that may be recorded may likely include your:
- Internet Service Provider
- The type of browser you are using
- Date and time of your visit
- Pages accessed and documents downloaded
- Referring URL’s
Please note that most web browsers can also be configured to notify the user when a cookie is received, allowing you to either accept or reject it. If you are not sure whether your browser has this capability, you should check with the software manufacturer or your Internet Service Provider.
You have the option of using a pseudonym when dealing with us so as not to identify yourself fully to us. Please bear in mind, however, that we will be unable to provide certain services to you unless you disclose your correct identity.
Direct marketing and opting out
We want to communicate with you only if you want to hear from us. If you prefer not to receive customer focused marketing event information from us, please let us know by clicking on the “unsubscribe link”/”update preferences” at the bottom of any of our communications, or by sending us an email.
Enquiries and making a privacy complaint
If you have any questions or complaints about privacy-related issues please contact our office:
Level 7, 115 Pitt Street, Sydney NSW 2000
Ph: +61 2 9221 6666
Date of publication – November 2021