Privacy Policy

1. Definitions

In this policy, "we", "us" and "the platform" refer to Polar Zinsmere, and "you" refers to any visitor or registered client of the site. "Processing" means anything done with personal data, including collecting, storing, using and deleting it.

2. Personal data

Personal data is any information that identifies or could reasonably identify you, such as your name, email address, phone number, date of birth, identity documents, and the content of any request you submit to us through the registration or contact forms.

3. Usage data

We also collect technical information automatically when you use the site, including your IP address (used, among other things, to determine your local currency for the investment calculator), browser type, device type, pages visited, and approximate session duration.

4. Cookies

The site uses a limited number of cookies necessary for core functionality, such as keeping you signed in and remembering your session state. We do not use third-party advertising cookies. Where analytics is enabled by our team, it is configured to avoid collecting information that directly identifies you.

5. Data controller / processor

Polar Zinsmere (Polar Zinsmere Technologies Pty Ltd) is the controller of the personal data described in this policy. Our registered contact for privacy matters is [email protected].

6. Collection and use of information

We collect personal data when you register an account, submit a contact, careers, or calculator request form, or communicate with our support team. We use this data to create and operate your account, respond to your requests, provide the services you sign up for, meet our legal and regulatory obligations (see our AML/KYC Policy), and, only where you've separately agreed, to send you service updates.

7. Legal bases

We process personal data on the basis of the contract we enter into with you when you register, our legal obligations (for example, identity verification requirements), our legitimate interest in keeping the platform secure and functioning, and, separately, your consent where marketing communication is involved.

8. Data retention

We retain account and verification data for as long as your account is active, plus the period required by applicable Australian recordkeeping obligations after account closure. Data collected only for a specific request, such as a careers application, is retained only as long as needed to process that request, unless you ask us to keep it longer or we're required to retain it by law.

9. Data transfers

Some of our service providers, such as identity-verification and cloud-hosting partners, may process data outside Australia. Where this happens, we require providers to apply protections consistent with this policy and applicable law.

10. Disclosure of data

We share personal data only where necessary, with: our identity-verification and payment-processing partners, IT and hosting providers, affiliated companies within our corporate group, and regulators or authorities where legally required. We do not sell personal data to third parties.

11. Security

Personal data is protected using encryption in transit and at rest, access controls limiting who inside our organisation can view it, and the account-level protections described on our Security page. No system is completely immune to risk, and we continually review our controls as threats evolve.

12. Your rights

You can ask us to give you access to the personal data we hold about you, correct inaccurate data, delete data we no longer have a lawful reason to keep, restrict certain processing, or object to processing based on legitimate interest. To exercise any of these rights, email [email protected]; we will respond within a reasonable timeframe and may need to verify your identity first.

13. Service providers

We rely on third-party providers for functions including identity verification, payment processing, cloud hosting and, where our team has enabled it, analytics. Each provider is used only for the specific function it performs and is bound by confidentiality and data-protection obligations appropriate to the data it handles.

14. Analytics

Where enabled, analytics tools help us understand how visitors use the site, at an aggregate level, so we can improve navigation and content. Analytics is off by default on this build and is only activated by our team pasting in an analytics ID, at which point this section governs how it's used.

15. Advertising and retargeting

We do not currently run third-party advertising or retargeting on this site. If that changes, this section will be updated before any such technology is enabled, and you will be given the appropriate choices under applicable law.

16. Links to third-party sites

Our site may link to external resources, including exchanges or educational content. We are not responsible for the privacy practices of external sites; review their own policies before sharing information with them.

17. Children's privacy

Our services are intended for adults only. We do not knowingly collect personal data from anyone under the age required to hold a trading account under Australian law. If we learn we have inadvertently done so, we will delete that data promptly.

18. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or in applicable law. Updates take effect from the date they're published on this page; continued use of the platform after an update constitutes acceptance of the revised policy.

19. Contact us

Questions about this policy or how your data is handled can be sent to [email protected].