Privacy policy

Last updated June 2026

This is a draft policy for the Proxi.Vote prototype, indicative of how the platform is built to handle your information. It will be finalised with legal advice before any public launch. It is written to align with the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs).

Who we are

Proxi.Vote operates a platform that lets ASX shareholders register their holdings, receive notice of company meetings, and direct their proxy votes. We are the entity responsible for the personal information described here.

What we collect

  • Identity and contact details, verified through our KYC provider.
  • Your shareholding details, including your SRN or HIN. These are treated as secrets: encrypted at rest and never displayed in full.
  • Your engagement with campaign material and your voting directions.
  • Payment details needed to pay your engagement earnings.

How we use it, and your consent

We use your information to operate the platform: verify your holdings, notify you of meetings, lodge your proxies, and pay you. Two further uses are entirely optional and controlled by separate, unbundled consents you can turn on or off at any time:

  • Aggregated insights. If you consent, your activity is included in anonymous, cohort-level insights shared with companies. These never identify you: any figure covering fewer than a minimum cohort size is suppressed.
  • Campaign material. If you consent, we show you paid campaign material from companies you hold.

You can use the full platform without granting either. We do not bundle these into the terms, and revoking them is one click in your privacy preferences.

What we never do

  • We never sell or disclose information that identifies you as an individual to companies. They receive aggregated cohorts only.
  • We never link your payments to how you vote — payment and voting direction are kept separate by design.

Automated analysis (transparency)

We use automated and statistical methods to group shareholders into anonymous cohorts and to estimate which messages resonate with which cohorts. These operate at the cohort level and inform insights shown to companies; they are not used to make decisions that produce legal or similarly significant effects about you as an individual. This section will be expanded to meet the automated-decision-making transparency requirements taking effect in December 2026.

Security and storage

Sensitive identifiers are encrypted at rest. Personal information is held in Australian data regions. Access is restricted and audited.

Your rights

You can access and correct your information, withdraw optional consents, and ask us to delete your account. Contact details for privacy requests, and our complaints process (including escalation to the OAIC), will be published here before launch.