PRIVACY POLICY
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Changes to this policy
TERMS OF USE
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Third party links and materials
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DISCLAIMER
SECURITY
FINANCIAL SERVICES GUIDE
Security
Protecting you
This policy applies to Pearler Investments Pty Ltd ACN 625120649 (Pearler)(collectively, we, us, our or Pearler).
1. How does pearler work to stay secure as a startup
We take risk management very seriously as a fintech startup.
This is a quick guide to some of the FAQs we often get in relation to security. We are also constantly learning more about this topic and refine our systems and protections on an ongoing basis. If we don't address something that's on your mind, drop us a note at support@pearler.com .
2. What are some of the key security measures in place?
Our approach to Compliance, Governance and Risk Management covers a range of topics including security, KYC/AML, personnel and operations considerations. In conjunction with Sanlam Private Wealth, OpenMarkets, DigitalID and Macquarie Bank we have documented policies and procedures in accordance with ASIC's licensing requirements.
In relation to your specific query, some of the ways we manage security are as follows:
- We use modern AWS infrastructure and security systems to ensure that our infrastructure is industry standard.
- All financial movements require two-factor authentication (2FA) to approve or modify.
- We ensure users have appropriately complex passwords, which, when combined with 2FA is an industry best practice approach to preventing breaches.
- Phone call confirmation with any user who needs to change bank details to ensure the request is coming from the right person.
- Separation of duties across tech and financial actions including opening accounts, authorising direct debit requests, settling trades.
3. Who inside pearler has access to my data?
We are a small team of people right now (but growing), which means we can keep a very tight handle on everything happening within pearler. We take both the separation of duties between the team and the cofounders, as well as training, very seriously. Every employee is provided with training in accordance with our licensing requirements as well as background and reference checks. At the core of these procedures are pearler's co-founders, who protect every aspect of pearler personally. We have specific policies and procedures in place so that as we grow we can identify risks and gaps before they happen and can deal with them, we recognise that security is a never ending process.
4. OK, but if something bad happens you have insurance right?
Yes. In accordance with our licensing requirements as well as our relationship with Sanlam Private Wealth Pty Ltd, we have insurance in place for client claims.
5. What about cash?
Pearler interacts with users' banks via its integration with Macquarie Bank only, here is a little more info:
- Macquarie bank requests deposits and sends returns to users' banks exclusively using direct debit authorisations in accordance with the instructions pearler receives from its users from time to time.
- Macquarie and users' banks communicate within the standard direct debit honour/dishonour timeframes (usually max. 3 business days).
- Because we only use direct debit (either one-off debits or recurring) this may not be possible to use with some term deposit, credit card or high interest saver accounts.
6. If you're in beta right now, are you live or still testing?
Our platform is live, we are fully licensed via Sanlam and once your account is set up and KYC complete you will have access to the full current functionality. We are calling it beta phase because it is still early days for our platform and we are only granting access to a small number of enthusiastic long term investors to make sure we get the right type of feedback. Of course, as we are refining the platform every day, our beta users will notice iterative changes in the user experience. We encourage our beta users to provide any observation or feedback about an issue or change to help us keep improving.
7. Where is your PDS?
The key documents that provide information about how pearler operates and our relationship to users are our Financial Services Guide, Privacy Policy, T&Cs and Disclaimers. Please see these documents attached in PDF in the meantime. These documents are shortly being made available on the public site, and are available as part of the platform sign up. As we do not operate a managed investment scheme or provide personal financial advice etc, we do not have a PDS as such. If upon reading this material you have outstanding questions please let us know.
8. Do you change your policies?
We may make changes to this policy at any time, without notice. An up-to-date version of this policy will be available on our website.
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