Privacy Policy and Consent Notice
Last updated:
September 2023
This is the Privacy Policy and Consent Notice for the Stables Group.

References in this Privacy Policy to ‘Stables’, ‘we’, ‘us’ and ‘our’ is a reference to Stables.

By using our products, services, app, viewing our website, interacting on social media, attending events, participating in surveys or user interviews, employment applications or any other means where you are sharing data with us, you agree to the terms outlined in this Privacy Policy and provide your relevant consent.

This consent can only be withdrawn by you expressly communicating this with Stables in writing via team@stables.money
Our commitment to protect your privacy
We understand how important it is to protect your personal information. This document sets out our Privacy Policy commitment in respect of personal information that you may provide to us.

We recognise that any personal information we collect about you will only be used for the purposes indicated in our policy, where we have your consent to do so, or as otherwise required or authorised by law. It is important to us that you are confident that any personal information we collect from you or is received by us will be treated with appropriate respect ensuring protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Act 1988 (Cth) and any other relevant law.
Personal information
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which the identity of the individual cannot be discerned (anonymous data).

We use different methods to collect data from and about you. Data is collected through the following:
Our website and app
When you use our website or app, we may collect, use, store and transfer the following data:
• Information you give us while using our website and app. We may ask you to provide us with personally identifiable information while you use our website.
• Automated technologies or interactions. We may use cookies, server logs and other technologies, such as web beacons, to collect information that your browser sends us when you are using our website. This includes your computer’s internet protocol, browser type, browser version, the country from which you visited our website, how you arrived at our website, length of your visit and which pages you viewed. Please refer to our Cookie Policy for further information about how we use cookies and similar technologies.

When we refer to personal information we mean information or an opinion about an individual, from which that individual is, or may reasonably be, identified.

This personal information may include the individual's name, date of birth, ID document details, phone number, email address, nationality, source of funds and other relevant information in order to be able to provide products and services.

Personal information also includes sensitive information. Sensitive information includes information about an individual’s health, race or ethnic background, their religion, trade union membership, political opinion, sexual preference or criminal record. Generally we will not collect such sensitive information about an individual, unless such information is required in order to process an application for a product or service provided by us. We will only collect sensitive information about an individual with that person’s consent.
Information about non-individual clients
If our client is an entity other than an individual, for example a company or a trust, we may collect information about that entity. This information may include that entity’s name and address, registration details, details of individuals involved with that entity and financial information about that entity.

In this policy, a reference to Information includes personal information (including sensitive information) about individuals as well as information about non-individual clients.
Why we collect your information
We collect and receive Information about you in order to conduct our business and to provide our products and services. We also collect Information about you to enable to directly market our products and services to you. If you apply for employment with us we may also collect personal information about you.
How do we collect your information
Information may be collected by us in a number of circumstances, including when you:

• apply to become a customer of Stables or apply for one of our products or services;
• use our website, interact on social media, complete user interviews or surveys;
• attend an event hosted or sponsored by us; or
• apply for employment with us or apply through a recruiter.;

Where reasonable and practical we will collect Information about you directly from you or one of your representatives or from publicly available information. However, we may also collect Information about you from third parties, such as a partner or spouse who contacts us on your behalf, from our contractors who supply services to us, through our introducers), and from advisers such as accountants or lawyers or other organisations authorised by you.

If you do not provide the Information requested by us, we may not be able to provide you with our services.

If you provide Information to us about another individual or about an entity with which you are associated, you must ensure that you are entitled to disclose that Information to us and that, without us taking any further steps required by privacy laws or by our general duty of confidentiality, we may collect, use and disclose such Information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure any individual concerned is aware of the various matters detailed in this Privacy Policy. Any such individual or entity must also provide the consents set out in this Privacy Policy in respect of how we will deal with their Information.
How do we use your information?
We use Information provided to us for the purpose for which it has been provided, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act. This may include using your Information for the following purposes:

• to provide you with the products or services you requested;
• to verify your identity;
• to assess, process and manage your application for a product or service offered by us, including to verify your details and assess our risk;
• to assess, process and manage your application for employment; or
• for complaints handling or data analytics purposes.
To whom will we disclose your information?
To enable us to maintain a relationship with you, we may disclose Information about you to:

• organisations that provide products or services used or marketed by us;
• your employer/s or referees, your professional advisors, your bank and any other organisation that may have or is considering having an interest in our business or a product provided by us;
• companies and contractors who we retain to provide services for us, such as IT contractors, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who will need to have access to your Information to provide those services;
• people considering acquiring an interest in our business or assets;
• other individuals or companies authorised by you.

By providing us with your Information, you consent to us disclosing your Information to such entities without obtaining your consent on a case by case basis.

Sometimes we are required or authorised by Australian law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court, Tribunal or law enforcement agency in response to a request or in response to a subpoena or to the Australian Taxation Office or other tax authority. From time to time, we may also be required to provide Information about you to a foreign law enforcement agency or foreign regulator.

Some of our third party service providers (including our information technology service providers) may be located in countries outside of Australia, including countries in Asia, Europe, North America, South America and other parts of the Australia region. Although our contracts with third parties generally include an obligation for them to comply with Australian privacy law and our Privacy Policy, some of our related bodies corporate, branches and third party service providers are located in countries that do not have laws that provide the same level of protection as the laws of Australia.

We may also use cloud storage and IT servers that are located offshore.
Direct marketing
From time to time we may use your Information to provide you with current information about products and services, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with. By providing us with your Information, you consent to us using your Information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone.

If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our Privacy Officer on the contact details below. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
Updating your information
It is important to our relationship that the Information we hold about you is accurate and up to date. During the course of our relationship with you we will ask you to inform us if any of your Information has changed.

If you wish to make any changes to your Information that we hold about you, or if you think any such Information we hold about you is incorrect, you should contact us to have it updated. We will generally rely on you to assist us in informing us if the Information we hold about you is inaccurate or incomplete.
Access to your information (this section applies only to 'personal information' about individuals)
We will provide you with access to the personal information we hold about you, subject to limited exceptions in the Privacy Act as outlined below. You may request access to any of the personal information we hold about you, at any time.

To access personal information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
Denied access to personal information (this section applies only to 'personal information' about individuals)
There may be situations where we are not required to provide you with access to your personal information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious.

An explanation will be provided to you if we deny you access to your personal information we hold.
Business without identifying you
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where, it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with Information. Such a situation would be where you make general inquiries about interest rates or current promotional offers.
How safe and secure is your information that we hold
We will take reasonable steps to protect your Information, by storing it in a secure environment, and when the Information is no longer needed for any purpose for which the Information may be used or disclosed, it will be destroyed or permanently de-identified.

We will also take reasonable steps to protect any Information we hold about you from misuse, loss and unauthorised access, modification or disclosure.
Third party websites
The Stables website may contain links to third party websites and social media features that are hosted by a third party. A link to another website does not mean that we sponsor, endorse or approve the information found on that website. We are not responsible for the privacy policies or practices of third party websites or social media features and you use of those websites and features are governed by the privacy policies and practices of the hosting entities.
Our Data Protection Officer
Stables appointed our Chief Risk Officer as our data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy and Consent Notice. If you have any questions about this Privacy Policy and Consent Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. We try to respond to all legitimate requests as soon as possible. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Email address: team@stables.money
Attention Chief Risk Officer
Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data and we will endeavour to accomodate all of these rights where practical:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasing of your personal data. This enables you to ask us to delete or remove your personal data. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please be aware that we may have to keep some of your data to comply with the law or for AML CTF and tax purposes but we will evaluate your request within applicable data protection laws.

• Object to processing of your personal data. In certain circumstances you can object to our processing of your personal data. You have the absolute right to object where we are processing your personal data for direct marketing purposes. You can exercise this right at any time by contacting us. This may result in you not being able to be a customer of Stables.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data and we are considering whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. This right applies to information which you have provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. Please note that if you withdraw your consent, we may not be able to provide certain products or services to you.

• You have the right to object to automated individual decision-making and profiling, and the right to request human intervention where we have relied on automated decision making or profiling.

If you wish to exercise any of the rights set out above, please contact teams@stables.money.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Contact details
You can email us at team@stables.money

We will deal with the complaint by investigating the complaint, and providing a response to the complainant within 15 business days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree alternative time frames with you.
Changes in our Privacy Policy
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.

As a consequence we may change this Privacy Policy and Consent Notice from time to time or as the need arises.