Dina Management Pty Ltd
Effective Date: 3 July 2025
1. Introduction
At Dina Management Pty Ltd (“we”, “our”, “us”), we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our services, including purchasing corporate bonds through our platform.
We comply with data protection laws, including the Privacy Act 1988 (Cth) in Australia and other applicable privacy regulations. By using our services, you consent to the collection and use of your personal information as described in this policy.
2. Information We Collect
We may collect personal information from you when you interact with our platform or services. The types of personal information we may collect include:
- Identification Information: Full name, date of birth, nationality, tax identification number.
- Contact Information: Address, email address, phone number.
- Financial Information: Bank account details, payment information, investment preferences.
- Transactional Information: Purchase history, bond transactions, account activity.
- Identification and Verification Information (for KYC): Government-issued identification documents, proof of address, employment details.
3. How We Use Your Information
We use the personal information we collect for the following purposes:
- To provide financial services: To facilitate the purchase and sale of corporate bonds, manage your investments, and execute transactions.
- To comply with legal obligations: Including Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements.
- To communicate with you: For account management, service updates, transaction confirmations, and promotional materials (if you have opted in).
- To improve our services: Analysing trends, improving customer experience, and providing tailored services.
- To safeguard your account: Detecting fraudulent activity and ensuring the security of your account.
4. How We Share Your Information
We may share your personal information with the following parties for the purposes outlined in this policy:
- Third-party service providers: To perform functions on our behalf, such as processing payments, providing custodial services, and managing technical infrastructure.
- Regulatory authorities: As required by law or regulation, including Australian Securities and Investments Commission (ASIC), tax authorities, or law enforcement agencies.
- Business partners: If we offer joint services with another organisation (such as a custodian or broker), we may share information necessary to provide those services.
We will not sell, rent, or trade your personal information to third parties for marketing purposes without your explicit consent.
5. Data Security
We take the security of your personal information seriously. We implement reasonable technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction. These measures include:
- Encryption of sensitive data.
- Secure access controls.
- Regular security audits.
Despite our efforts to protect your personal information, no data transmission over the internet is 100% secure. Therefore, we cannot guarantee the security of your data while it is being transmitted to our platform.
6. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Right to access: You can request a copy of the personal information we hold about you.
- Right to correct: You can request corrections to any inaccuracies in the personal information we hold about you.
- Right to erase: In some circumstances, you may request the deletion of your personal data.
- Right to object: You may object to the processing of your data for certain purposes (e.g., marketing).
- Right to withdraw consent: You may withdraw any consent you have provided regarding the use of your data at any time.
To exercise any of these rights, please contact us at the details provided below.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal obligations, resolving disputes, and enforcing agreements.
When we no longer need your personal information, we will securely delete or anonymise it in accordance with applicable laws.
8. Cookies and Tracking Technologies
We use cookies and other tracking technologies to collect information about how you use our website and services. These technologies help us:
- Improve user experience: By remembering preferences and settings.
- Analyse traffic: To measure the effectiveness of our marketing and services.
You can adjust your browser settings to block cookies or notify you when cookies are being used. However, disabling cookies may affect your ability to use certain features of our platform.
9. International Transfers
If you are located outside of Australia, please note that your personal information may be transferred to, stored, and processed in countries that may not have data protection laws equivalent to those in your jurisdiction. By using our services, you consent to the transfer of your personal information to such countries.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. We will notify you of significant changes by posting the updated policy on our website and/or sending you a notification. We encourage you to review this policy periodically to stay informed about how we protect your personal information.
11. Contact Us
If you have any questions or concerns about this Privacy Policy or how we handle your personal information, please contact our team.