UNBROKER PRIVACY POLICY

This Privacy Policy explains how Fourth Point Pty Ltd (ABN 83 648 875 478) trading as Unbroker (“Unbroker”, “we”, “us”, or “our”) collects, uses, stores, and discloses your personal information. We are committed to protecting your privacy and managing your information securely and transparently.

This Policy complies with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and other applicable laws.

1. WHAT WE COLLECT

We collect personal information necessary to provide our services, comply with legal obligations, and operate efficiently. This may include:

• • • Name and contact details
    • Date of birth and nationality
    • Identification documents (e.g. driver licence, passport)
    • Tax file number (optional)
    • Bank account details
    • Details about your shareholding (e.g. SRN, issuer, quantity)
    • Information about legal authority (e.g. executor status, power of attorney)
    • Source of wealth or occupation (in some cases, to comply with AML laws)

We may also collect sensitive information where required by law or where reasonably necessary to process certain transactions.

Sensitive information may include, for example, your:

• • • Health or medical status (if acting under a power of attorney or on behalf of an estate)
    • Criminal history (in limited compliance scenarios)
    • Racial or ethnic origin (only where relevant to verification)
    • Government-related identifiers such as:
      • Medicare number
      • Driver licence number
      • Passport number
      • Centrelink reference number

2. HOW WE COLLECT INFORMATION

We collect personal information directly from you when you:

• • • Submit a form on our website (www.unbroker.com.au)
    • Provide documentation via upload or email
    • Communicate with us by phone, email, or live chat

We may also collect information from third parties where permitted or required, such as:

• • • Referrers and professional advisers (e.g. accountants, financial planners)
    • Identity verification providers
    • Public share registries

3. HOW WE USE YOUR INFORMATION

We use your personal information to:

• • • Verify your identity and assess your eligibility for our services
    • Transfer and sell your shares through our nominee account
    • Pay sale proceeds to your nominated bank account
    • Comply with legal and regulatory requirements (e.g. AML/CTF obligations)
    • Respond to enquiries and customer support requests
    • Maintain transaction records and reporting
    • Improve and secure our systems and operations

We may also use de-identified data to analyse performance, usage patterns, and customer behaviour.

4. HOW WE STORE AND SECURE YOUR INFORMATION

Your information is stored securely using a combination of:

• • • Encrypted cloud-based systems
    • Secure physical storage (where relevant)
    • Access controls and permission-based roles

We take reasonable steps to protect your information from misuse, interference, and unauthorised access. Access is restricted to staff and service providers who need it to perform their duties.

We retain your data only as long as necessary to fulfil legal, operational, and reporting requirements.

5. OFFSHORE STORAGE AND THIRD PARTY SERVICE PROVIDERS

Some of your personal information may be stored or processed using third-party providers whose infrastructure is located outside Australia. This may include providers offering:

• • • Cloud storage (e.g. Microsoft, AWS, Google)
    • Identity verification and AML compliance
    • Payment processing
    • CRM, ticketing, and operational support tools

We only use reputable providers who are contractually required to protect your data and comply with relevant privacy standards.

6. DISCLOSURE OF YOUR INFORMATION

We may share your personal information with:

• • • Our technology and service providers (as above)
    • Share registries and market participants to complete share sales
    • Financial institutions and payment intermediaries
    • Legal, regulatory, and enforcement bodies as required
    • Your authorised representatives (e.g. solicitor, executor, financial adviser)
    • Any other third party reasonably necessary to complete your transaction or to comply with our legal or operational obligations

We will not sell your data or use it for unrelated marketing without your consent.

7. ACCESS, CORRECTION AND COMPLAINTS

You can request access to the personal information we hold about you or ask for it to be corrected if it is inaccurate or outdated. To make a request or lodge a privacy complaint, contact us at:

Unbroker
Email: info@unbroker.com.au
Mail: Level 1 60 Martin Place, Sydney NSW 2000

We aim to respond within 7 days. If you are not satisfied with our response, you may escalate the matter to:

Australian Financial Complaints Authority (AFCA)
GPO Box 3, Melbourne VIC 3001
Phone: 1800 931 678
Email: info@afca.org.au
Website: www.afca.org.au

If the matter remains unresolved, you may also contact:

Office of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
Website: www.oaic.gov.au

8. POLICY CHANGES

We may update this Privacy Policy from time to time. The current version will always be available at www.unbroker.com.au/privacy. By using our services, you agree to the most recent version.