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:

• • • Enter or provide information through our website, including through online forms, applications and enquiry processes;
    • Provide documentation via upload or email; or
    • Communicate with us by phone, email or live chat.

Information entered or provided through our website may be collected and retained as it is provided, even if you do not complete or submit the relevant form, application, enquiry or request.

We may also collect personal information from third parties where permitted or required by law, including identity verification providers, share registries, financial institutions, professional advisers, service providers and other parties involved in providing our services.

3. HOW WE USE YOUR INFORMATION

We may use your personal information to:

• • • Provide, administer and process our services, including share sale applications and related transactions;
    • Verify your identity and undertake compliance, fraud prevention, anti-money laundering and other regulatory checks;
    • Communicate with you about our services and respond to enquiries and customer support requests;
    • Follow up an enquiry, application or request that you have commenced, including where you have entered or provided information through our website but have not completed or submitted the relevant form or application;
    • Contact you to offer assistance, request further information, or determine whether you wish to proceed with an enquiry, application or request;
    • Process payments and facilitate settlement of transactions;
    • Maintain our business records and administer our relationship with you;
    • Improve our website, services, systems and customer experience;
    • Comply with our legal and regulatory obligations; and
    • Protect against fraud, misuse, security threats and other unlawful activity.

Where you provide contact details in connection with an enquiry, application or request for our services, we may use those details to contact you directly in relation to that enquiry, application or request, even if you do not complete or submit it.

We will only use your personal information for the purposes for which it was collected, related purposes that you would reasonably expect, or otherwise as permitted or required by law.

4. MARKETING COMMUNICATIONS

We may, from time to time, use your contact details to provide you with information about our services, updates, or promotional offers that we believe may be of interest to you.

Receiving marketing communications from Unbroker is optional. You can opt-out at any time by following the unsubscribe instructions included in our emails or by contacting us directly at info@unbroker.com.au.

Your decision to opt-out of marketing communications will not affect your access to, or use of, our core services.

5. 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.

6. 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.

7. 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.

8. 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

9. 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.