Personal Information We Collect

Sumo Financial Services Pty Ltd (“Sumo Financial Services”, “the firm”, “we”, or “us”) collects Personal Information to help us service your accounts and to deliver an exceptional experience. Personal Information is information that uniquely identifies you, such as your name, email address, billing information, or other data that can be reasonably linked to you by the firm.

The type of information we collect depends on your interactions with us, the products and services you apply for, and what we need to open, maintain, and service your accounts. In addition, certain service providers may share your information with us for specific purposes, such as verifying your identity and helping protect your accounts and financial information.

Information You Provide to Us

You may provide Personal Information to us through our websites, applications, forms, and digital platforms. For example:

• When you register to use our services or create an account with us, you may be required to provide certain information (e.g., your name, email address, telephone number, date of birth, financial details, investment profile information).

• When you contact us through our websites, client portal, email, or by phone.

• When you subscribe to newsletters, updates, or publications.

• When you participate in surveys or feedback programs.

Information We Collect from Other Sources

We may receive Personal Information from:

• Consumer reporting agencies or credit bureaus to assess financial suitability or creditworthiness (when applicable).

• Identity verification providers for KYC/AML compliance.

• Third-party service providers assisting us with fraud prevention, authentication, or account protection.

Information We Collect Automatically When You Use Our Website

When you interact with the firm’s websites, applications, or online services, we automatically collect Personal Information and related technical information, including:

• Device identifiers

• Browser type and settings

• Operating system

• Mobile network information (carrier name, phone number, device model)

• Application version numbers

• IP address

• Device type and system activity

• Date, time, and referring URL of your request

We also collect information about your interaction with our site and digital tools to improve performance, security, and user experience.

Cookies and Similar Technologies

Our websites, mobile applications, and online services may store or retrieve information on your browser using cookies and similar technologies. These technologies help ensure that our websites function properly, allow us to personalize your experience, remember your preferences, analyze performance, and improve our digital services.

Categories of Cookies We Use

1. Necessary Cookies

These cookies are essential for our websites to function. They enable actions such as logging in, managing privacy preferences, or completing secure forms.

2. Functional Cookies

These cookies allow us to enhance website functionality and personalization. They may be set by us or third-party service providers.

3. Analytical Cookies

These cookies help us understand how visitors use our website, including page performance, traffic sources, and navigation patterns. The data is aggregated and anonymized.

4. Marketing Cookies

We partner with advertising providers to optimize digital marketing. These cookies do not capture identifiable details such as your name or email. They help us measure the effectiveness of digital advertising and may be used to show relevant ads on other websites.

Disabling Cookies

You can adjust cookie settings directly in your browser (e.g., Chrome, Safari, Firefox, Edge). Disabling cookies may affect your experience and functionality on our site.

How We Respond to Opt-Out Preference Signals

Some browsers include opt-out preferences such as “Do Not Track (DNT)” or “Global Privacy Control (GPC)”. These settings, when enabled, notify websites that you prefer not to be tracked.

If your browser communicates a valid opt-out preference signal when you visit the Sumo Financial Services website, we will honor that signal as a request to opt-out of sale/share of personal information, unless you later choose to opt in through your privacy settings.

Opting Out of Interest-Based Advertising

Sumo Financial Services may use third-party advertising partners to deliver ads that may be relevant to your interests based on your activity on Sumo Financial Services websites and other non-affiliated websites.

We support the Digital Advertising Alliance (DAA) AdChoices framework, which allows users to opt out of interest-based advertising.

You may opt out by clicking the AdChoices icon on applicable ads or through the DAA opt-out page.

Please note:

• Opting out does not prevent you from seeing Sumo Financial Services advertising; it only stops ads that are behaviorally targeted.

• Opt-out preferences are stored via cookies.

• If you delete cookies, use a different browser, or switch devices, your preferences may not be retained.

How We Use and Share Your Personal Information

Sumo Financial Services Pty Ltd (“Sumo Financial Services”, “we”, or “the firm”) uses Personal Information for several essential business functions, including:

1. Processing Transactions and Requests

We use your Personal Information to process transactions you request, provide financial services or products, and supply information relevant to your account.

2. Maintaining and Servicing Your Account

We use your information to manage, operate, and support your accounts, including updates, account verification, reporting, and ongoing service activities.

3. Improving Our Products and Services

We may use your information to enhance our services, platforms, and financial products.
We may also contact you about Sumo Financial Services products or third-party offerings that may be relevant to your financial needs, interests, or profile.

4. Facilitating Online Interactions

We use your contact information and device data to communicate with you—for example, to send emails, notifications, or text messages related to your account or our services.
We may also use your device’s IP address to transmit the data you request while navigating our website or applications.

5. Complying With Legal and Regulatory Requirements

We use your Personal Information to comply with obligations under Australian law, including the Privacy Act 1988, AML/CTF Act 2006, and any regulatory requirements imposed by ASIC, AUSTRAC, and other authorities.

6. Ensuring Security and Integrity

We use your information to maintain the safety, security, and integrity of our systems, platforms, customers, employees, and overall business operations.

How We Share Your Personal Information

We may share your information only under the circumstances described below and always in accordance with our Corporate Privacy Notice and applicable law:

1. With Affiliates of Sumo Financial Services

We may share Personal Information with our related entities and affiliates for analytics, operational support, market research, and marketing activities, where permitted by law.

2. With Trusted Service Providers

We may share your information with service providers who support or help develop our services, platforms, and financial products.
These providers include:

• Cloud hosting companies

• Identity verification services

• Fraud detection and security monitoring providers

• Technology and analytics vendors

All service providers are contractually required to comply with our privacy, confidentiality, and security standards.

3. To Protect Rights, Property, and Safety

We may disclose Personal Information when necessary to protect:

• The rights, property, or safety of Sumo Financial Services

• Our clients

• Our employees

• The public

This may include sharing information with organizations for fraud prevention and credit risk mitigation.

4. To Comply With Legal or Regulatory Obligations

We may disclose Personal Information to comply with applicable laws, regulations, or lawful requests, including:

• Law enforcement agencies

• Regulators

• Courts and tribunals

• Subpoenas

• Judicial or administrative orders

• AUSTRAC reporting obligations

• AML/CTF compliance requirements

In all cases, disclosures are limited to what is necessary and legally required.

Contact Information and Manage Preferences

If you would like to opt out or manage your preferences regarding advertising or marketing communications from us, or if you have any questions, concerns, complaints, or suggestions about any of our Privacy Notices or how we collect and use your Personal Information, we are available to assist you.

If you have requests related to your Personal Information under applicable laws, or otherwise need to contact us, please refer to your Sumo Financial Services statement, which contains the most direct contact number for your account.

In some cases, specific contact information may also be included in the Privacy Notice applicable to your region. You may also reach us through the Contact Us page on our official website.