PRIVACY POLICY
Collection and use of personal information
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Security
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Changes to this policy
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Your money held by our partners
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DISCLAIMER
SECURITY
FINANCIAL SERVICES GUIDE
UPDATES
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
We take risk management very seriously at Pearler.
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 Pty Ltd (Sanlam), OpenMarkets, FrankieOne and Zepto, we have documented policies and procedures in accordance with ASIC's licensing requirements.
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.
- Verification of identity through photographic evidence of ID documents and video of the ID holder is required when changing a bank account.
- We maintain separation of duties across tech and financial actions including opening accounts, authorising direct debit requests and settling trades.
- We utilise a separate client trust account to transfer unutilised funds away from Zepto to add another layer of security for client monies.
3. Who inside Pearler has access to my data?
The short answer is that only those people who absolutely need to. Sensitive information (Date of Birth and addresses for example) can only be accessed by certain personnel on an as needed basis. Even when discussing issues with an account, if we don’t need to use Personally Identifiable Information (PII), we won’t.
Some other steps we’ve taken include:
- working with specialist partners like Frankie One which enables us to retain as little customer data as possible; and,
- regular monitoring to identify unusual behaviour on customer accounts that may be consistent with fraudulent activity.
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. Sanlam Private Wealth as the authorising licensee for Pearler holds Professional Indemnity Insurance cover for the activities conducted under its AFS licence and continues to maintain Professional Indemnity Insurance that generally satisfies the requirements of s912B of the Corporations Act Regulatory Guide RG126. Pearler holds its own Professional Indemnity Insurance as well.
5. What about cash?
Pearler interacts with payments specialist, Zepto, who facilitates payments in accordance with your instructions or relevant banking system requirements and laws.Here is a little more info. Based on your instructions:
- Zepto may request deposits or send returns to user bank accounts using direct debit authorisations. Zepto and users' banks communicate within the standard direct debit honour/dishonour timeframes (usually max. 3 business days).
- Where you instruct deposits via 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.
- Zepto also supports money to be transferred into your Pearler account via PayID if your bank supports that functionality.
- Instant transfers that are required to settle same-day trades or investments are distributed via Zepto to the relevant settlement account (for example OpenMarkets or Drivewealth) in accordance with your instructions. Any funds required to be held overnight are held by our appointed third-parties with National Australia Bank in accordance with Subdivision A of Division 2 of Part 7.8 of the Corporations Act, on terms contemplated under section 981A of the Corporations Act, on behalf of you. See Section 4. of our Terms of Use for full details.
6. 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. These documents are on the public site, and are available as part of the platform sign up. On sign-up for specific products, you may also be given a PDS and TMD so that you can assess if the product offered is suitable for your needs. 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.
7. Do you change your policies?
We may occasionally make changes to this policy at any time. An up-to-date version of this policy will be available on our website. We will inform you about when we make changes that materially impact how our technology works or how you are charged.
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