About this policy


PRIVACY POLICY

This Privacy Policy explains how Red C Investments Pty Ltd ABN 60 628 942 825 trading as JM INVESTMENTS & ADVISORY (we, us, our) collects, uses, holds and discloses personal information. We are a Corporate Authorised Representative (No. 1295954) of BR Securities Pty Ltd AFSL # 456663.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles. We treat your personal information as confidential and take reasonable steps to protect it.

What we collect
Depending on the services you use, we may collect:
  • your name, date of birth, address, email address and phone number;
  • identification documents such as a driver licence or passport;
  • your tax file number (TFN), tax residency and bank account details;
  • details of your shareholdings, HIN or SRN, trading accounts and transactions;
  • for companies, trusts and super funds: trust deeds, company extracts and details of directors, trustees and beneficial owners;
  • for deceased estates: wills, death certificates, grants of probate or letters of administration, and details of executors and beneficiaries;
  • records of our communications with you; and
  • information about how you use our website (see below).
We only collect sensitive information with your consent or where the law requires or authorises it. You are not required to give us your TFN, but if you do not, tax may be withheld from your investment income at the highest marginal rate.

How we collect it
We usually collect personal information directly from you, through forms, email, phone calls, meetings and the enquiry and sign-up forms on our website. We may also collect it from third parties such as your solicitor, accountant, executor or attorney, share registries, other brokers and investment platforms, identity verification services and public registers. If you give us information about another person (for example a beneficiary), please make sure they are aware of this policy.

Why we collect it
We collect, hold and use personal information to:
  • provide our services, including opening and administering accounts, acting on your instructions, transferring and selling holdings and administering deceased estates;
  • verify your identity and meet our obligations under laws including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, the Corporations Act 2001 and taxation laws;
  • manage our relationship with you, including invoicing and payments;
  • respond to enquiries and complaints;
  • maintain and improve our website and services; and
  • send you market updates, newsletters and information about our services, unless you opt out.

Marketing
Every marketing email we send includes an unsubscribe link. You can also opt out at any time by contacting us. We do not sell your personal information.

Our website, cookies and analytics
Our website uses cookies and similar technologies, including Google Analytics, Google Ads and the Meta (Facebook) Pixel. These help us understand how the website is used and measure and deliver advertising, including to people who have previously visited our website. They collect information such as your IP address, device and browser type and the pages you view. When you send us an enquiry or upload documents through our website, we may also share your email address and phone number with Google in a hashed (scrambled) form, so that an enquiry or completed share sale can be matched to an advertisement you clicked. We use this only to measure how well our advertising works. You can block or delete cookies in your browser settings and manage advertising preferences in your Google and Facebook accounts. Our website is hosted by Showit, and our enquiry and sign-up forms are processed using SendFox and monday.com.

Disclosure to third parties
We may disclose personal information to:
  • BR Securities, our authorising licensee, including for compliance and supervision;
  • Morrison Securities Pty Ltd (AFSL 241737), the ASX participant that executes, clears and settles trades and holds accounts for our clients;
  • share registries, other brokers, investment platforms and product issuers;
  • your solicitor, accountant, executor, attorney or any other person you authorise;
  • service providers who help us run our business, such as IT, cloud storage, email, client management, payment and identity verification providers, and our professional advisers, auditors and insurers; and
  • regulators and government bodies such as ASIC, AUSTRAC and the ATO, dispute resolution bodies such as AFCA, and anyone else where the law requires or authorises it.
We require our service providers to protect the personal information we give them.

Overseas disclosure
Some of our service providers, including Google, monday.com, SendFox, Showit and Stripe, store or process information outside Australia, mainly in the United States. We take reasonable steps to make sure overseas recipients handle personal information in a way that is consistent with the Australian Privacy Principles.

Use of technology and AI-assisted tools
We use software, including AI-assisted tools, to help us read and prepare documents and correspondence and to keep our records. This work is reviewed by a person. We do not use these tools to make decisions about you without human involvement.

If you do not provide information
You can deal with us anonymously or under a pseudonym for general enquiries. For most of our services, however, the law requires us to identify you. If you do not provide the information we ask for, we may not be able to act for you or carry out your instructions.

Security and retention
We hold personal information in secure, access-controlled electronic systems and take reasonable steps to protect it from misuse, interference, loss and unauthorised access, modification or disclosure. No method of transmitting or storing information is completely secure, so please take care when sending us sensitive documents. We are generally required to keep client records for at least seven years after our relationship ends. When information is no longer needed, we destroy or de-identify it.

If a data breach occurs that is likely to result in serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme.

Access and correction
You can ask to access or correct the personal information we hold about you by contacting our Privacy Officer. We will need to verify your identity and will respond within 30 days. We do not charge for making a request, but may charge a reasonable fee for providing access. If we refuse your request, we will tell you why in writing.

Complaints
If you have a concern about how we have handled your personal information, please contact our Privacy Officer. We will acknowledge your complaint promptly and respond within 30 days. If you are not satisfied with our response, you can contact the OAIC at www.oaic.gov.au or on 1300 363 992. You may also contact BR Securities (details are in our Financial Services Guide) or the Australian Financial Complaints Authority at www.afca.org.au or on 1800 931 678.

Changes to this policy
We may update this policy from time to time. The current version is always available on our website. This policy was last updated in September 2026.

Contact us
Privacy Officer
JM Investments & Advisory
info@jminvest.com.au
0466 574 394
104/88 Jefferson Lane, Palm Beach, QLD, 4221