Privacy Policy

This Policy applies to Insider Information Pty Ltd (ABN: 28 163 276 462 ) and any holding companies, other subsidiaries or related entities of Trade Naked Now, all of which are referred to as “TNN”, “we”, “our”, or “us”. The Policy extends to and covers all operations and functions of TNN.
At TNN, we are committed to ensuring the confidentiality and security of the personal information supplied by individuals. TNN is bound by the National Privacy Principles (‘NPPs’) contained in the Privacy Act 1988 (Cth) (‘Privacy Act’). TNN has appointed a Privacy Officer, who oversees the Privacy Policy, and ensures that TNN’s management of personal information is in accordance with this Policy and with the Privacy Act.
TNN ‘s Privacy Policy Statement will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.
The word “individual” refers to a customer, client, trustee or any other person with whom we come into contact. All contractors, sub-contractors, vendors, service providers, customers, agents or any other third parties that have access to and/or utilise personal information collected and/or held by TNN must abide by this Privacy Policy.
“Personal information” is information or an opinion relating to an individual, which can be used to identify that individual. Some personal information, which we collect, is “sensitive information”. “Sensitive information” includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, which is also personal information, and also includes health information about an individual.
1. How we collect personal information
As the provider of financial services, including stock market and options trading education, we may collect sensitive information about an individual’s personal circumstances and financial details such as their bank account details, and credit history, which may potentially identify the individual and/or contains an opinion about the individual.
Our ability to provide individuals with our products and services is sometimes dependent on us obtaining certain personal information about the individual. Typically, the type of personal information we collect about the individual includes his or her name, age, date of birth, occupation, mailing address, phone numbers, email address and other information that is relevant to the products and services we provide.
The personal information may also include information about the form of identification used in relation to an individual to send or receive a transaction (required by law in some instances), and information about a transaction in relation to an individual, including details of the amounts paid in or out of an individual’s account as well as delivery instructions.
We generally collect personal and/or sensitive information from individuals by the following methods:
1.1 directly from applications, questionnaires and/or forms completed by individuals (via our websites), which include surveys or special offers, when individuals wish to use our services, purchase our products or apply for a position in our organisation;
1.2 from information disclosed to us by an individual on the phone, or by sending us correspondence (by letter, fax or email) or contact us in person; and
1.3 from a variety of third party sources, including our business contacts credit reference and credit checking agencies, and financial institutions.
The above list is not exhaustive.
In some circumstances we may be provided with personal information about an individual from somebody else, for example a referral from another person. We will take reasonable steps to inform the individual that it holds the personal information and the purpose for which it holds the personal information.
We must not collect sensitive information unless the individual has consented, or it is required by law, or in other special specified circumstances.
If the personal information we request is not provided, we may not be able to provide individuals with the benefit of our services, or meet an individual’s needs appropriately.
2. Why do we collect personal information?
We collect personal information for the following purposes:
* to conduct our business of providing our products and services to our clients;
* to enter into contracts with sub-contractors to conduct our business;
* to assess applications by individuals to provide them with our products and services;
* to comply with our legal obligations; and
* to help us manage and enhance our services.
We may also obtain information from time to time through market research, to enable us to improve our services or to consider the wider needs of our customers or potential customers.
3. About whom do we collect personal information?
The type of information we may collect and hold includes (but is not limited to) personal information about:
* individuals;
* third parties;
* prospective employees; and
* other people with whom we come into contact.
4. How might we use and disclose personal information?
When we refer to “use “of personal information, we mean use within our organisation for the purposes outlined above. When we use the word “disclose” we mean providing the information to persons outside our organisation.
We may use and disclose personal information for the primary purposes for which it is collected, and also for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (e.g., where required by law).
We may use and disclose personal information for the following purposes:
* to conduct our business of providing our products and services to clients;
* to register and handle product warranties, and product warranty claims;
* to enter into contracts with sub-contractors to conduct our business;
* to assess applications by individuals to provide them with our services;
* to communicate with individuals, by providing them from time to time with information contained in
newsletters, emails or brochures;
* to comply with our legal obligations; and
* to help us manage and enhance our services.
When you enter provide your contact details as part of a survey or market research questionnaire, we may ask for your name, address, and e-mail address so we can conduct the survey and thereby enhance our services. We may ask for other information to enable us to improve our websites or to send you special offers. In these instances we will usually provide you with an opportunity to opt out from receiving any information after providing your details.
We do not disclose personal information we collect to others for the purpose of allowing them to direct market their products and services. We do not use or disclose sensitive information for direct marketing purposes.
We may engage other people to perform services for us, this may involve those people handling personal information that we possess. In these situations, we prohibit that person from using personal information about you except for the specific purpose for which we supply it.
We may disclose personal and/or sensitive information to:
* third parties, including (but not limited to) any entities or organisations handling any claims;
* consultants we engage to assist individuals;
* consultants we engage to manage our business;
* third party service providers;
* organisations involved in a transfer or sale of all or part of our assets or business (including accounts and
trade receivables);
* our lawyers;
* our accountants;
* our compliance consultants;
* regulatory authorities, including the Australian Securities and Investment Commission (ASIC); and
* anyone else to whom the individual authorises us to disclose it.
We may also collect personal and/or sensitive information from these organisations and individuals, and deal with that information in accordance with this Policy.
TNN trains its employees and advisers who handle personal information to respect the confidentiality of customer information and the privacy of individuals. TNN regards breaches of your privacy very seriously and will impose appropriate penalties for breach of this Policy, which may, in certain circumstances, include dismissal.
5. Sending information overseas?
We will not send personal or sensitive information to recipients outside of Australia other than to a related company without:
* obtaining the individual’s consent (in some cases this consent will be implied); or
* otherwise complying with the NPPs.
We will not send personal or sensitive information to recipients in a foreign country that is not subject to an information privacy scheme similar to the Privacy Act, without the consent of the individual.
6. Management of personal information
The Privacy Act requires us to take all reasonable steps to protect the security of personal information. Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium. We hold personal information in a combination of secure computer storage facilities and paperbased files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.
We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
7. Identifiers
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes.
8. How do we keep personal information accurate and up-to-date?
We take reasonable steps to ensure that the personal information it holds is accurate, complete and up-to-date. We encourage individuals to contact us in order to update any personal information we hold about them. Our contact details are set out at the end of this document.
9. Access to personal information
Under the Commonwealth Privacy Act, you have the right to obtain a copy of any personal information which TNN holds about you and to advise TNN of any perceived inaccuracy.
To make a request, you will need to complete an application form verifying your identity and specifying what information you require. We will acknowledge your request within 14 days and respond promptly to it. If we refuse to provide the information, we will provide reasons for the refusal and inform the individual of any exceptions relied upon under the Privacy Act.
If you want to make a general enquiry about TNN ‘s privacy policy, change your personal information, lodge a complaint or obtain an application form for access to your personal information, please contact us using the details at the end of this document.
We will require identity verification and to specify what information is required. An administrative fee for search and photocopying costs may be charged for providing access. We will advise of the likely cost in advance.
10. Updates to this Policy
TNN ‘s Privacy Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.
11. Responsibilities
It is the responsibility of management to inform employees and other relevant parties that this Privacy Policy is maintained and enforced. Management must ensure that they periodically advise TNN ’s employees and other relevant parties of any changes to the Privacy Policy in a timely manner. It is the responsibility of all employees and other relevant parties to ensure that they understand and adhere to this Privacy Policy. Ignorance of the existence of the Privacy Policy will not be an acceptable excuse for non-compliance.
12. Privacy Training
All new employees must be provided with timely and appropriate access to TNN ’s Privacy Policy. All employees must be provided with opportunities to attend appropriate and periodic Privacy awareness training and must ensure that they understand the Privacy related issues that could adversely affect TNN ’s position if not properly adhered to.
13. Non-compliance and disciplinary actions
Any TNN employee or relevant third party that identifies, knows about, or suspects a Privacy breach must immediately report the matter to the Privacy Officer. Employees or other relevant parties that contravene or do not comply with TNN ‘s Privacy Policy may be subject to disciplinary action.
14. Incidents/Complaints Handling
If an individual has a privacy complaint, he or she is required to send it in writing to the Privacy Officer.
TNN has an effective incidents/complaints handling process in place to manage privacy risks and issues. The incidents/complaints handling process involves:
* identifying (and addressing) any systemic/ongoing compliance problems;
* increasing consumer confidence in TNN ’s privacy procedures; and
* helping to build and preserve TNN ’s reputation and business.
15. Contractual arrangements with third parties
We must ensure that all contractual arrangements with third parties adequately address privacy issues.
Each third party is aware of this Privacy Policy, and has informed us that they have implemented policies in relation to the management of personal information in accordance with the Privacy Act, including:
* regulating the collection, use and disclosure of personal information;
* de-identifying personal information wherever possible;
* ensuring that personal information is kept securely, protected from loss or misuse, with access to it only by
authorised employees or agents of the related organisations; and
* ensuring that personal information is only disclosed to organisations which are approved by TNN .
The third parties specifically agree only to use personal information for the purposes consented to by TNN or by the individual concerned.
16. Websites
TNN ’s websites ( contain links to other websites whose operator may or may not adhere to a privacy policy or be governed by the NPPs. TNN has no control over the privacy practices of sites that are linked to its sites via hyperlinks or banner advertising. Please take care at all times to check whose site you are visiting.
When an individual accesses our websites, our websites uses cookies which allow us to identify the individual’s browser. Cookies do not identify the individual – they simply allow us to track usage patterns so that we can measure the level of interest in various areas of its site. All browsers allow individuals to be notified when they receive a cookie and elect whether to accept it.
We may also use third parties to analyse traffic at our web sites, which may involve the use of cookies. Information collected through such analysis is anonymous. Our websites’ privacy policy can be accessed by clicking on the privacy link located on the homepage of each of our websites.
17. Enquiries
If you have any questions about privacy-related issues please contact the TNN Privacy Officer:
The Privacy Officer
Insider Information Pty Ltd
PO Box 859
ManlyNSW 1655
Tel/Cell (+61 ) 0421 930 773