Privacy Policy | Clime Direct

Terms and Conditions

Subscription Conditions

This website and all associated pages is operated by Stocks In Value Pty Limited A.C.N. 162 644 724 (Trading as Clime Direct). Stocks In Value is an Authorised Representative (Authorised Representative No. 436268) of Clime Asset Management Pty Limited ACN 098 420 770 (AFS Licence No. 221146) (Clime Asset Management).

Clime Direct is an interactive online service containing information supplied by Clime Investment Management Ltd, and third parties. Information is protected by copyright and is made available under license. Any unauthorised reproduction of this information is prohibited.

You must read and accept these Terms and Conditions of use in order to access the “user websites” (climedirect.com.au), their contents and other websites through links provided on this website. By accepting these Terms and Conditions of Use, you have confirmed that you have read, understood and agreed to be subject to its contents. A reference in these Terms and Conditions of Use to “the or this website” includes the user websites and websites linked to from the user websites.

Clime Direct reserves the right to change or remove any information provided on or via the user websites, including these Terms and Conditions of Use, at any time and without notice. Any change or modification to the Terms and Conditions of Use will be effective immediately upon posting an updated version of the Terms and Conditions on the Clime Direct website. It is recommended that you review the information provided on or via this website, including these Terms and Conditions of Use, periodically for changes.

Disclaimer

The information provided on Clime Direct is intended for general use only and may contain general financial services advice. The information presented does not take into account your investment objectives, financial situation and advisory needs. Because of this, before acting on any of the information provided, you should always consider its appropriateness in light of your objectives, financial situation and needs.

Your use of information on this website or materials linked from this website is at your own risk. Under no circumstances should investments be based solely on Clime Direct information and you should obtain professional financial planning advice. You can view Clime Direct’s Financial Services Guide (FSG) on our policies page on this site.

We endeavour to maintain the accuracy of data provided on the user websites, by using information prepared from a wide variety of sources, which Clime Direct, to the best of its knowledge and belief, considers accurate. However, Clime Direct makes no representations or warranties of any kind, expressed or implied, about the completeness, accuracy, reliability, suitability or availability of the information provided on the user websites.

Clime Direct has made every effort to ensure the reliability of information contained in its newsletters and the user websites. All information only represents our view on a stock at the date of publication and not beyond that date.

Our publications may include our views on the future performance of a stock. These statements involve inherent business and market risks and uncertainties that may cause actual results or performance to differ materially from our views. Our views may rely on historical data and you acknowledge that past performance is not an indicator of future results.

Nature of the Service

While parent company – Clime Asset Management – provides input into our service, our conclusions do not represent their views. It therefore offers a variety of views on stocks, including a range of valuation techniques and rationale, that will not necessarily correlate with the valuation technique and rationale adopted by the Clime Direct team.

Commentaries published on the website represents the view of Clime Direct only at the time of publication, even if they are archived on the site. The less recent an article’s publication date, the more likely that the company’s circumstances and our view on that company may have changed. While we will endeavour to publish an article whenever our view on a company has changed, this will frequently not be possible, given the broad coverage we offer.

The site may include forums containing the personal opinions and other expressions of the persons who post entries on a wide range of topics. Any comments posted on a forum do not represent the views of Clime Direct.

Payment

Clime Direct offers a 30-day money back guarantee. If you are not satisfied with the quality of the service within 30-days of signing up and you cancel your subscription within that time we will refund any subscription fees paid.

By accepting these Terms & Conditions of Use, you have authorised us to arrange for your credit card to be charged according to this agreement.

You will only be charged a fee if you enter into an agreed paid subscription.

All services are paid in advance. Clime Direct is aware of the need to ensure the security of your credit card details and to address this, our payment system is compliant with the Payment Card Industry (PCI) Data Security Standard.

Clime Direct will not disclose your details except for the purposes of conducting credit card payments, as agreed by you, or as required by law. Clime Direct will abide by our Privacy Policy.

An option may be provided to pay a monthly subscription, which may be priced at a higher rate.

It is your responsibility to ensure that there are sufficient clear funds available in your account to allow payment to be made. If there are insufficient funds in your account, we reserve the right to pause or cancel your subscription until payment is made. If you have insufficient clear funds in your account and your bank or credit card providers charges any dishonour or other fees these will be to your account.

You may cancel your subscription at any time. If you cancel your subscription within the first 30-days of your subscription agreement, you will receive a full refund. At any time beyond the first 30-days of your subscription agreement, no refunds will be given for the unexpired portion of the term that you agreed to on signup.

You can purchase a subscription using our payment gateway provider Stripe. We have partnered with this payment gateway provider, to accept credit cards safely and securely for our customers. They manage the complex routing of sensitive customer information through the credit card processing networks.

The payment gateway providers adhere to strict industry standards for payment processing, including:

128-bit Secure Sockets Layer (SSL) technology for secure Internet Protocol (IP) transactions.
Industry leading encryption hardware and software methods and security protocols to protect customer information.
Compliance with the Payment Card Industry Data Security Standard (PCI DSS).

Clime Direct does not retain a customer’s full credit card information on its servers, and it is not accessible to our employees.

Where a customer’s credit card information is stored, it is protected on secure, encrypted PCI DSS compliant third-party servers.

Auto-Renewal

Your subscription will automatically renew at the end of your agreed paid subscription period for the same period as your original subscription period ie monthly or annually. Your credit card will continue to be charged until you cancel your membership.

Notice will be given to your registered email address prior to auto-renewal around one-month before renewal.

You can cancel auto-renewal, at any time in advance of the renewal date, from the website or by notifying us in writing via members@climedirect.com.au.

Licence and Restrictions of Use

The subscription granted by Clime Direct is for the use of one individual or household only. If there is evidence that the subscription is being used by multiple parties, Clime Direct reserves the right to cancel your subscription and no refund will be paid for any unexpired portion of any paid subscription.

If you wish to use multiple persons to have access to Clime Direct, please contact Clime Direct to discuss a corporate subscription.

You must not:

unless otherwise permitted by law allow or cause a third party to copy any part or all of the Clime Direct website, information or outputs generated from using Clime Direct;
assign or grant sub-licences of any of its rights under these Terms and Conditions of Use or permit third parties to use this service without the consent of Clime Direct;
provide Clime Direct either directly or indirectly to any third party without the consent of Clime Direct;
exploit Clime Direct otherwise than as permitted under These Terms and Conditions of Use; or
distribute or copy any research, articles/publications or valuations provided by Clime Direct without the consent of Clime Direct;
use Clime Direct in any Web Application.

Holding and Trading Transparency

In the interests of transparency, where the author of an article holds a stock discussed in that article, Clime Direct will disclose that interest at the time of publication. Clime Direct will also require that this disclosure will also apply to third party contributors to StocksInValue, and where someone makes a significant contribution to the thinking of an article, without actually writing it (eg, via interview). This disclosure will generally be found at the end of the webpage on which the publication can be found.

Clime Direct will also supply this disclosure where a stock is held in a portfolio managed by Clime Asset Management.

Where relevant Clime Direct staff trade their securities, this will be recorded to comply with ASIC regulations.

Service Availability

Clime Direct aims to provide 100% uptime of our service, but there is always a possibility that an unforeseen outage might occur. StocksInValue is reliant on a number of third party service providers. While we have carefully selected our providers, there is a risk that their service will be interrupted, and in turn, cause an interruption to the services of Clime Direct.

Where possible, Clime Direct will give notice of any downtime, such as maintenance, and will endeavour to conduct these activities in periods of low client use.

Browser and Operating System Compatibility & Support

As with all internet sites and applications, the display and use of the service can differ between browsers and operating systems. Amongst more common browsers and operating systems, we will continually test and optimise the experience of the service.

Clime Direct commits to support the use of the service on the following recent ‘versions’ of common internet browsers

Browser	Version
Google Chrome	25 or later
Microsoft Internet Explorer	8.0 or later
Mozilla Firefox	24 or later
Safari	5.0 or later

Clime Direct commits to support the use of the service on the following operating system versions

Operating System	Version
Microsoft Windows 7	All
Microsoft Windows 8	All
Mac OSX	Snow Leopard or later

We recommend that you use one of these listed browsers and operating systems, and where possible, upgrade your service to the latest version. If you do not, we recommend that you determine the suitability of our product within your chosen browser and operating system configuration during your obligation free trial.

This website uses cookies, which allow us to identify your browser while you are using the site. Cookies do not identify you personally. They simply allow us to track usage patterns. If you prefer not to receive cookies, you can configure your browser to reject them or to notify you when they are being used. Some functionality of the website may be impacted if you restrict the use of cookies.

Privacy

You acknowledge that any personal information submitted to Clime Direct will be treated in the manner described by our Privacy Policy.

As a subscriber to Clime Direct, you consent to receiving email correspondence from Clime Direct, as well as from our parent company, Clime Asset Management and its related body corporate. You may also choose to receive selected third party offers that Clime Direct may negotiate for our customers – these emails will be sent by Clime Direct and third party companies will never receive your email address or personal details. You may opt out of receiving any category of emails at any time by visiting the User Settings page of the Clime Direct website.

Comments and Forum Usage

The user forum is only available to members of the Clime Direct Product
Clime Direct welcomes your participation in the forum, but we reserve the absolute right to moderate or delete comments made on the site
Without limiting our absolute right to moderate or delete comments, our guidelines for comments that should not be included on the site, are those that:

Are derogatory
Are, or appear to be, misleading or deceptive
Are defamatory
Make assertions about companies, stocks, individuals, or the Clime Direct product that appear to ignore or disregard comments, facts or other content presented on the site or forum
Are repetitive or unrelated to the relevant forum topic

Moderation may require comments to be approved prior to publication on the site

As a member of the website:

You are personally responsible for your comments and any of the Information on the website you contribute to. Therefore, You should not include any misleading or deceptive information in your comments and not carry out illegal or unauthorised activities using this website. Information in comments may, where appropriate, be made available to ASIC. ASIC and people acting on such information may take action against you.
If you include hyper-links to third party websites, You may be seen as endorsing the material on such websites. It may be advisable for you to warn people accessing other sites that you do not endorse or take responsibility for material in the hyper-linked sites.
If you own or have some other interest in a security, or you have any connection with a securities issuer that you might benefit from, you must disclose that fact. For example, you may be entitled to receive direct or indirect commissions, fees or other benefits from a financial product or service provider; or you may be associated with a particular securities issuer such as by being an employee or director of a securities issuer. If so, you must disclose that fact in your comment.

Support

As a subscriber of Clime Direct, you can expect to receive technical phone support concerning how to use and understand the product, from 9am – 5pm EST on weekdays (excluding public holidays and in the period between Christmas Day and News Year’s Day).

Subscribers to the service, can discuss stocks with a client adviser on a strictly limited “general advice” basis. The client adviser can be accessed once per month, or more frequently, if there is sufficient availability of client advisers.

Intellectual Property Rights

You acknowledge that you have no rights of ownership in Clime Direct.
Clime Direct retains all rights (including copyrights, trademarks, patents as well as any other intellectual property rights) in relation to all information provided on or via this website. You may not copy, download, publish, distribute or reproduce any of the information contained on this website in any form without the prior written consent of Clime Direct or the appropriate consent of the owner. However, you may print out and/or download information contained on this website for your own personal and non-commercial use.
All Intellectual Property Rights in or to Clime Direct are the property of, or vest on creation in, Clime Direct, including as an assignment of future copyright.

Unforeseen Events

Clime Direct is excused from performing its obligations to the extent it is prevented by circumstances beyond its reasonable control, including but not limited to acts of God, natural disasters, acts of war, riots and strikes.

Severability

If anything in these Clime Direct Terms and Conditions of Use are unenforceable, illegal or void then it is severed and the rest of these Clime Direct Terms and Conditions of Use remain in force.

Liability

Governing Law and Jurisdiction

No information, advice, or offers on this website are intended for any person outside Australia. Offers from this website can only be accepted by a person who is within Australia. Unless specifically stated otherwise, currency references in this website are references to Australian dollars only.

This agreement is governed by the laws in force in New South Wales, Australia. Each party irrevocably and unconditionally submits to the non-exclusive jurisdiction of the courts of New South Wales, Australia.

We endeavour to maintain the accuracy of data provided on this website, by using information prepared from a wide variety of sources, which Clime Direct, to the best of its knowledge and belief, considers accurate. However, Clime Direct makes no representations or warranties of any kind, expressed or implied, about the completeness, accuracy, reliability, suitability or availability of the information provided.

Privacy Policy

About this Privacy Policy

Introduction And Purpose

To fulfil its obligations under the Privacy Act 1988 (Cth) (Privacy Act), Clime Investment Management Limited (CIW) has implemented this Privacy Policy and procedures to ensure that personal information is handled in accordance with the Privacy Act. This policy covers CIW and all subsidiary companies (collectively called Clime).

This policy sets out how Clime deals with your personal information that it may collect from time to time. This policy may change from time to time in line with legislative updates.

What Is Personal Information

The Privacy Act states that “Personal Information” means information or an opinion (including information or an opinion forming part of a document or other source), whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.

Personal information may include:

§ Name, gender and date of birth;

§ Contact details such as address, phone number and email address;

§ Bank account details for direct crediting of distributions and redemptions;

§ Investment information about your holding in our products;

§ Tax File Number (TFN) / Australian Business Number (ABN), if you have chosen to disclose it;

§ Any personal information necessary for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

To assist Clime in providing quality services, it is important that the information you entrust to us is complete, accurate and up-to-date. You can help us to keep your information up to date by contacting us immediately if your contact details change.

INFORMATION WE COLLECT FROM YOU

We collect information about you and your interactions with us, for example when you request or use our products or services, make a card purchase or transfer money, phone us or visit any of our websites.

We may also collect personal information if authorised or required by an Australian law or court or tribunal order to collect that information. We will tell you if collection is required or authorised by law and provide you with details of the law, court or tribunal order.

For example, when you make an application to Clime for a financial product, we are required under the Anti-Money Laundering and Counter-Terrorism Financing Act to collect certain information from you to prove your identity, such as your driver’s licence or passport details. Clime may collect your Australian Tax File Number (TFN). It is not compulsory to provide your TFN, but if you do not, Clime may deduct withholding tax from any applicable distribution payments at the highest marginal rate. Clime will collect your TFN to determine whether you are subject to withholding tax on any distribution payments you receive and for communication purposes of distribution payments to the Australian Taxation Office. If Clime collects your TFN, we will handle your TFN in accordance with the Privacy Act and Guidelines issued by the Office of the Australian Information Commissioner (OAIC).

Clime may also be required to ask about your tax residency status under taxation information sharing agreements the Australian Government has in place with other countries. For example, a tax treaty between Australia and the United States formed under US law (Foreign Account Tax Compliance Act) requires Clime to ask investors in our funds whether they are US citizens or US tax residents when they make an application. If you are a tax resident of another country, the relevant treaty or law may require us to collect your relevant foreign tax identification number.

COLLECTION OF SENSITIVE INFORMATION

Sensitive information is personal information about an individual’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, genetic information, biometric information or health information.

Clime will not collect, use or disclose sensitive information about you unless we need the information for one of our functions or activities and we have your consent (or we are legally required to do so).

COLLECTION OF INFORMATION FROM THIRD PARTIES

With your consent, Clime may collect personal information from a third party or from sources you would reasonably expect, for example, information extracted from publicly available sources such as public domain websites or telephone directories.

Clime may also collect information about how you use our or other websites to help us better tailor our services to you. For example, Clime may do this when you click on a link from the Clime website or visit a website which displays a Clime advertisement. Usually, the information we collect in this way is general information only derived from cookies – such as the number of visitors to a site or statistics about how a site is browsed – and does not identify you. If Clime does identify you with this information (for example, if you have been logged onto an online Clime service), any use or disclosure of that information will be in accordance with this Privacy Policy.

HOW WE MAY USE AND DISCLOSE YOUR INFORMATION

Clime may use and disclose personal information we collect about you for several purposes including:

§ to consider your request for a product or service;

§ to enable Clime to provide a product or service;

§ to tell you about other products and services that may be of interest to you;

§ to assist in arrangements with other organisations (such as loyalty partners) in relation to the promotion or provision of a product or service;

§ to manage accounts and perform other administrative and operational tasks (including risk management, systems development and testing, staff training and market or customer satisfaction research);

§ to consider any concerns or complaints you raise against Clime and/or to manage any legal action between you and Clime;

§ to prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;

§ to identify you or establish your tax status under any Australian or foreign legislation, regulation or treaty pursuant to an agreement with any tax authority; and

§ as required by relevant laws, regulations, codes of practice and external payment systems.

If Clime uses your personal information for direct marketing of its products or services, it will provide you with the opportunity, at the point of our first contact and at any time afterwards at your request to decline receipt of any further marketing information. Otherwise, Clime will neither use nor disclose your Personal Information that is not related to the purpose for which we collected your information in the first place without your consent, unless:

1. It is required for public health or public safety or other emergency reasons; or

2. It is required to investigate or report suspected fraud or unlawful activity; or

3. It is required or authorised by law; or

4. Clime believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body:

a. the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;

b. the enforcement of laws relating to the confiscation of the proceeds of crime;

c. the protection of the public revenue;

d. the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;

e. the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.

If you would like to restrict how your personal information is handled beyond what is outlined in this policy, please contact our Privacy Officer.

DISCLOSURE OF PERSONAL INFORMATION

We will not disclose personal information collected by us for any purpose other than where you have consented to the disclosure; or where the Australian Privacy Principles authorise use or disclosure where required or authorised by law, in circumstances relating to public health and safety, social security and taxation in connection with certain operations by or on behalf of an enforcement body.

In relation to our role as a financial service provider we are required pursuant to the Corporations Act 2001 (Cth) to maintain certain transaction records with regards to your investment in our products and make those records available for inspection to the Australian Securities and Investments Commission.

We may disclose personal information to external service providers such as fund managers, custodians, mailing houses and auditors for the purpose of giving effect to the service provided by us. These external parties are only authorised to use personal information for the purpose for which Clime supplied it. Those organisations are not authorised to use that information for their own purposes.

SENDING YOUR INFORMATION OVERSEAS

During the course of business, we may send your information overseas, including to overseas Group members and to service providers or other third parties who operate or hold data outside Australia.

Where we do this, we make sure that appropriate data handling and security arrangements are in place. Please note that Australian law may not apply to some of these entities.

We may also send information overseas to complete a particular transaction, such as an International Money Transfer, or where this is required by laws and regulations of Australia or another country.

Clime will not transfer personal information outside Australia unless Clime reasonably believes that the recipient of the information is subject to a law, binding scheme or contract providing the same standards of protection of personal information as provided for under the Australian Privacy Principles.

INTEGRITY OF PERSONAL INFORMATION

We are committed to ensuring that personal information collected and kept by us is kept secure and protected from misuse, loss, unauthorised access, inaccuracy, modification or disclosure.

Should your details change, we ask that you advise us of the change as soon as possible so that we may maintain accurate records.

DATA SECURITY

Clime may store your personal information in hardcopy documents or electronically. Clime maintains physical security, such as locks and security systems, over our paper and electronic data stores and premises. Clime also maintains computer and network security. For example, Clime uses firewalls (security measures for the internet) and other security measures such as identification codes and passwords to control access to computer systems. Clime continually maintains and monitors its online security systems to ensure that Clime’s online services are secure and that your personal information is appropriately protected when you use these services.

We require you to keep your personal identification number (PIN), passwords and access codes confidential and secure at all times. This means that you should not disclose your PIN, passwords or access codes to any other person. You should contact Clime immediately if you believe that your PIN, passwords or access codes may have been disclosed to another person or if you would like to change your PIN or password.

ONLINE SERVICES

Clime’s Privacy Policy is posted to www.clime.com.au (the company’s website) from where an electronic copy (.pdf format) can be downloaded. A paper copy of the policy can be made available on request.

ACCESS TO PERSONAL INFORMATION

If you have concerns about the completeness or accuracy of the personal information Clime holds about you, or would like to access or amend the information, please contact our Privacy Officer at:

Clime Investment Management Limited

PO Box H90

Royal Exchange NSW 1225

Ph: 1300 788 568

Email: info@clime.com.au

Clime will take reasonable steps to confirm the identity of the person making the request and will endeavour to respond within 14 business days of receiving the request. However, where the request is more complex or time consuming to comply with, Clime will endeavour to provide access to the information requested within 28 business days.

Clime reserves the right to deny access to personal information if:

a. providing access could pose a possible threat to life or health; or

b. providing access could cause an unreasonable impact on the privacy of others; or

c. the request is frivolous or vexatious; or

d. the request or the requested information relates to existing or anticipated legal proceedings which could be prejudiced as a result; or

e. the request or the requested information relates to existing or anticipated commercial negotiations involving Clime, and Clime legitimate commercial interests could be prejudiced as a result; or

f. providing access is in any way unlawful; or

g. providing access would be likely to prejudice an investigation of possible unlawful activity; or

h. providing access would contravene a direction to Clime by an enforcement body performing a lawful security function to not provide access to the information because providing access would jeopardise national security; or

i. providing access would likely prejudice:

(i) the prevention, detection, investigation, prosecution of criminal offences, breaches of the law imposing a penalty or sanction or breaches of prescribed law; or

(ii) the enforcement of laws relating to the confiscation of the proceeds of crime; or

(iii) the protection of public revenue; or

(iv) the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or

(v) the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders by or on behalf of an enforcement body.

Where providing access would reveal evaluative information generated within the company in connection with a commercially sensitive decision-making process, Clime may give the individual an explanation for the commercially sensitive decision rather than direct access to the information.

Where there is disagreement about direct access or where direct access to personal information is impractical or inappropriate, Clime will discuss the possible use of a mutually acceptable intermediary.

If you advise Clime that the personal information we hold on you is inaccurate, incomplete or not up-to- date, Clime will take reasonable steps to update the information accordingly. Should there be a disagreement between Clime and you about whether the personal information is complete or up-to-date then at your request, Clime will take reasonable steps to associate a statement from you that the information is not correct with the relevant record(s) held by Clime.

Clime reserves the right to levy a reasonable charge to meet the costs of providing access to personal information, although there will be no charge for lodging a request for access.

IDENTIFIERS

Clime will not use an identifier assigned to an individual by a Government Agency (Agency) or related body as its own identifier; nor will it provide such an identifier to a third party without the individuals consent, unless:

a. the use or disclosure is necessary for Clime to fulfil its obligations to the Agency or related body; or

b. one or more of Use and Disclosure section numbered items 1-4 (inclusive) apply to the use or disclosure; or

c. the use or disclosure is by a prescribed organisation of a prescribed identifier in prescribed circumstances.

ANONYMITY

Wherever lawful and practical, Clime will give you the option of not identifying yourself when dealing with the company.

COMPLAINTS

Clime is committed to providing high quality services to its clients. The protection of your information is of the utmost importance. Clime takes complaints seriously and is committed to a robust, fair and respectful complaints management process.

If you have a complaint about our handling of your personal information, you may either:

· email info@clime.com or

· apply in writing to:

Privacy Officer

Clime Investment Management Limited

Level 12, 20 Hunter Street

Sydney NSW 2000

In both instances you must set out full details of the complaint. To help Clime complete a quick and effective investigation, the complainant should include as much detail as they have available to assist the Clime Privacy Officer to identify the nature and scope of the complaint.

Wherever lawful and practical, Clime will give you the option of submitting a complaint anonymously. However, if you decline to provide your name and contact details Clime may only be able to undertake a limited investigation and limited resolution of the complaint.

The Privacy Officer will maintain a record of all complaints received, including but not limited to:

· name and contact details of the complainant

· date the complaint was received

· nature of the complaint

· details of the person(s) investigating the complaint

· outcome of the investigations

· dates and details of all contacts made with the complainant

These records will be held in a secure manner by the Privacy Officer and will only be accessible to Clime personnel who reasonably require access to those records to investigate and resolve the complaint. Otherwise, they will only be made available, if required or authorised by law or to assist with any investigations carried out by the Office of the Australian Information Commissioner.

The Privacy Officer will also be responsible for investigating privacy complaints.

All complaints in relation to the handling of personal information will be acknowledged within five working days and a full response given within thirty days. Where it is not possible to complete the investigation of a complaint within thirty days, the complainant will be contacted once thirty days have elapsed with an estimate of when the investigation will be completed.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:

Director of Privacy Case Management

Office of the Australian Information Commissioner

GPO Box 5288

Sydney NSW 2001

DISCLAIMER

This policy represents Clime’s policy as at 31 January 2024. Clime may revise this policy as it sees fit or at its discretion.

Although Clime intends to observe this policy at all times, neither Clime nor any of its entities nor its associated companies is legally bound in any respect by this policy. From time to time, Clime reserves the right to act outside the policy and may do so, subject only to any statutory rights you have under the Act or other applicable legislation.

Financial Services Guide 21 June 2024

Stocks In Value Pty Ltd, trading as Clime Direct (ABN 43 162 644 724) (Clime Direct, we, us, our) is a Corporate Authorised Representative (No. 436268) of Clime Asset

Management Pty Limited (Licensee or Clime), an Australian Financial Services Licence (AFSL) holder (AFSL No.221146, ABN 72 098 420 770).

Clime Asset Management Pty Limited

Principal Place of Business

Level 12, 20 Hunter Street Sydney NSW 2000

Postal Address:

PO Box H90, Australia Square, NSW 1215

Tel No: 1300 788 568

Email: info@clime.com.au

This FSG is designed to provide you with important information prior to receiving financial services from us.

The FSG includes information about:

The financial services and products we provide;
your privacy and how we collect your personal information;
what to do if you have a complaint;
the significant relationships and associations we have;
the remuneration and other benefits that may be received by us or other relevant persons in connection to the financial services we provide to you; and
fees and charges for our services.

If you need further information or are unsure about any part of this document, we encourage you to contact us with any questions you may have.

WHO WILL BE PROVIDING THE FINANCIAL SERVICES?

The Licensee authorises Clime Direct to provide financial services to you. These financial services are provided via its website, via phone or email.

FINANCIAL SERVICES WE PROVIDE

The Licensee authorises us to provide general financial product advice in securities to retail and wholesale clients.

We provide clients with online access to a stock valuation and research service through our website. The website provides information on a number of companies

listed on the Australian Stock Exchange (ASX). The content of our website, as well as correspondence we send via email and may include general financial product advice.

Please note that all information provided by Clime Direct, including by its team members, is either factual information or general advice only it is not personal

financial product advice. This means that the advice or information provided has not been prepared by taking into account your objectives, financial situation or needs.

Before acting on any of the information or advice provided, you should assess whether it is appropriate considering your own objectives, financial situation or

needs. You should carefully read and consider any Product Disclosure Statement (PDS) that is relevant to any financial product that has been discussed before making

any decision about whether to acquire the financial product.

REMUNERATION, COMMISSION, FEES OR OTHER BENEFITS

Access to the stock valuation and research service through our website is on a subscription basis. The annual membership fee is $719.99 (including GST) per year or

alternatively $71.99 (including GST) per month for a monthly membership. We reserve the right to vary these charges from time to time and will notify subscribers

accordingly.

To become a subscriber, you must agree to the terms of use that accompany a subscription application or renewal.

Other than the fee stated above, we do not receive remuneration, commission, fees or other benefits in relation to providing the financial services to you.

CLIME DIRECT’S RELATED PARTIES

Clime Direct is a wholly owned subsidiary of Clime Investment Management Ltd, ABN 37 067 185 899. Clime Investment Management Ltd (ASX: CIW) is a publicly listed

financial services group. Clime Direct’s parent company, Clime Investment Management Ltd has an interest or shareholding in the following:

Proactive Portfolios Pty Ltd
Ralton Asset Management Pty Ltd
WealthPortal Pty Limited
AdviceNet Pty Limited
Clime Capital Limited (ASX: CAM)
CBG Asset Management Pty Limited
Madison Financial Group Pty Ltd
Clime Investors Education Pty Ltd
Clime Asset Management Pty Limited
CBG Capital Limited
Clime Investors Education Pty Limited
Clime Private Limited
Clime Private Wealth Pty Limited
Optimise Advise Services Pty Limited
MTIS Wealth Management Pty Ltd
Investment Strategists Accounting Services Pty Ltd

YOUR PRIVACY

The privacy of your personal information is important to us. We must ensure privacy and security of your personal information in accordance with our privacy policy. You

can obtain a copy of the policy on request or it is available on our website (www.climedirect.com.au).

We keep name, phone, and e-mail details for the purpose of fulfilling requested products and services. If you register online to receive our products you may indicate

whether you wish to receive additional information and marketing on other products of Clime. At any time you may change, remove or alter the records held by Clime

Direct or elect not to receive any materials from us, Clime or any of the related bodies corporate. Personal details held may include name, contact details (address,

phone/fax, email) and payment information (credit card and/or bank details). We can assist with any questions concerning your records.

PROFESSIONAL INDEMNITY INSURANCE

The Licensee has in place professional indemnity insurance cover in accordance with its obligations under section 912B of the Corporations Act.

COMPLAINTS

We are committed to providing quality financial services. If you believe we have failed to achieve this, we would like you to tell us. We are committed to resolving any client concerns and aim to deal with any complaints quickly and fairly.

You may contact Clime’s Compliance team to make a complaint by:

Telephone: 1300 788 568

Email: compliance@clime.com.au

In writing: Complaints Officer

Clime Asset Management Pty Ltd

PO Box H90,

Australia Square NSW 1215

Clime will then investigate your complaint with the intention to provide a resolution within 30 days. Some complex matters may require an extension to investigate thoroughly. Clime will notify you if we require more time to investigate your complaint. If a complaint is not resolved to your satisfaction or you are not satisfied with the way Clime have handled your complaint, you have the right to make a complaint, free of charge, to the Australian Financial Complaints Authority (AFCA).

AFCA is an external dispute resolution scheme that provides a free service to clients and is an independent and impartial body that will deal with your complaint.

You can contact AFCA on:

Telephone: 1800 931 678

Email: info@afca.org.au

In writing: Australian Financial Complaints Authority Limited

GPO Box 3

Melbourne Victoria 3001

Website: www.afca.org.au

Links to other Websites

Although this Website may be linked to other websites, we are not, directly or indirectly, implying any approval, association, sponsorship, endorsement, or affiliation with any linked website, unless specifically stated herein.

You should carefully review the legal statements and other conditions of use of any website which you access through a link from this Website. Your linking to any other off-site pages or other websites is at your own risk.

Use of Cookies

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Clime Direct Policies