SPYRE GROUP PRIVACY POLICY
Spyre Group is committed to adhering to the Privacy Act, 1988 (Cth) and other relevant Australian Privacy Policies & Principles.
This policy was updated in January 2024.
Spyre Projects Pty Ltd ACN 642 584 683, Spyre Capital Limited ACN 125 015 401 and its related companies (collectively referred to as ‘Spyre Group’, ‘Spyre’, ‘us’ or ‘we’) respect the privacy and security of your personal information.
This Privacy Policy explains in general terms how Spyre Group handles your personal information. It sets out the type of information we collect and how we collect, store, use and disclose your personal information. In order to provide investment services, we need to collect and retain various personal details. This allows us to communicate with you about various products and services whilst remaining compliant with relevant laws. We consider all information about you to be both private and confidential.
By visiting our websites, using any of our services or otherwise providing us with your personal information (or authorising it to be provided to us by someone else), you agree to your personal information being collected and handled as set out in this Privacy Policy.
COLLECTION OF PERSONAL INFORMATION
Under the Acts, Personal Information is defined as information or an opinion about an identified individual, or an individual that is reasonably identifiable, in whatever form and regardless of whether it is true or not (‘Personal Information’) The Act also defines a subset of Personal Information as sensitive information (for example health records racial or ethnic origin, religious beliefs, criminal records etc.).
The types of personal information we collect and hold will depend on the circumstances of collection and on the type of service we are providing. For example, when we market a property for sale, we may collect and hold personal information from potential buyers such as name, address, email address, telephone numbers, employment details etc.
In order to establish and administer an investment in a scheme and provide information about our products and services to investors and financial advisers, and to comply with relevant legislation, we may collect the following information;
1. Full name, date of birth, gender and contact details including telephone, address and email;
2. Copy of a driver’s licence and/or passport or other identification for the purpose or verifying identity and to ensure compliance with the Anti-Money Laundering and Counter-Terrorism Financing At and/or other legislation and regulations regarding identification verification, and tax reporting and withholding;
3. Tax File Number and Bank Account Details for the purpose of administering investor accounts and tax reporting and withholding;
4. Investor contribution details and investment choices;
5. Details regarding authorised signatories;
6. Detailed contact information about a financial adviser; and
7. Copies of any relevant trust deeds, partnership agreements or constitutions which may be relevant to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act. We may also collect and hold certain sensitive information that is reasonably necessary for the provision of our services, including health and criminal records. If you provide us with any sensitive information, you consent to us collecting that information and handling it in accordance with this Privacy Policy.
HOW WE COLLECT PERSONAL INFORMATION
Spyre Group will always endeavour to collect the information from you personally, including telephone communication, email, post, and in person.
We may collect personal information about you directly when you deal with us over the telephone, send us correspondence (whether by letter or email) have contact with us in person, visit our websites or complete hard copy or online forms. There are also circumstances where we may collect personal information abiout you from various third parties, for example;
1. Project Marketing Agencies who we contract to market and sell our properties;
2. Market research companies contract by us to obtain information so that we may improve and market our services;
3. Your empoyer;
4. Other agents and valuers who may be involved in the services we provide;
5. Publicly available information and databases;
6. Other companies within the Spyre Group;
7. A financial advisor or broker;
8. Authorisied representatives such as executors and/or administrators;
9. Identification verification services provides; and
10. Anyone you have authorised to deal with us on your behalf. We also automatically collect certain information when you visit our websites or subscribers receive promotional emails from us via cookies and other tracking technology (such as web beacons), some of which may be capable of personally identifying you. Such information includes the type of browser and operating system you are using, your IP address and how you use our websites. Depending on the type of service you or your customers have requested, we may also seek to collect information about someone else from you (for example, contact details of your solicitor, emergency contact information, etc.). However, you must not provide us with the personal information about another person unless you have clear consent from that person to do so, and informed them accordingly that their personal information will be handled in accordance with this Privacy Polciy and directed them to where they can find it.
Regardless of how it is collected, we handle all personal information in accordance with this Privacy Policy.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to third parties as may be necessary as per the purposes disclosed to you in this Privacy Policy. Such third parties generally include:
1. Our third party providers, contractors, consultants, agents and/or representatives (such as law firms, banks, financial institutions, insurers, IT providers, mortgage referral service providers and/or wealth management service providers) who provide services to us or on our behalf, including for the purposes of;
2. Potential buyers, tenants, conjunctional real estate agents and brokers for the purpose of which the information was collected or for related purposes (for example to complete a transaction on your behalf or provide you with a service that you requested);
3. Anyone you have authorised to deal with us on your behalf;
4. Any of the companies within Spyre Group and their related companies;
5. Government authorities, regulatory bodies, law enforcement agencies, courts, tribunals and/or parties to the legal proceedings where you have consented to this or we are required or authorised to do so by law such as the Australian Government regulators, including but not limited to the Australian Securities and Investments Commission (ASIC), Australian Tax Office (ATO), Australian Transaction Reports and Analysis Centre (AUSTRAC) and to other regulatory or government entities;
In order to meet our investors’ needs and provide some investor services, such as administration of accounts and mailing of investor distribution statements, it may be necessary to release information or provide access to external service provides, for instance:
1. Any organisations involved in providing, managing or administering our products, systems or services such as custodians, registries, administrators, mail houses and software and information technology providers;
2. Auditors, consultants and other professional advisers;
3. Authorised financial advisers;
4. A legal personal representative, attorney or any other person who may be entitled to receive the proceeds from a deceased investor’s account balance and any person contacted to assist us in that process;
5. Other financial institutions who hold an account in an investor’s name, for example, where amounts have been transferred to or from that account;
6. Authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to an investor’s account.
ACCESS, UPDATES AND CORRECTION OF PERSONAL INFORMATION
Spyre Group take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up to date. However, we also rely on you to advise us of any changes to your personal information. If you are able to access your personal information by contacting us, it is your responsibility to ensure your information is accurate, complete relevant and up to date.
On request we will provide you with access to the personal information we hold about you, including for the purpose of correcting or updating that information, unless otherwise required or permitted by law.
There is no charge for making the request or giving the access to your personal information. We will deal with your request within a reasonable period after the request is made.
If we refuse to provide you with access we will provide you with a written notice that, at a minimum, outlines reasons for the refusal and the complaints mechanisms available to you.
If you wish to access the personal information we hold about you or to update or correct it, you can do so by contacting us using the contact details provided. We will require you to verify your identity and specify what information you require.
SECURITY AND RETENTION
Spyre Group will take reasonable steps to protect client personal data against loss or theft, as well as from unauthorised access, disclosure, copying, use or modification, regardless of the format in which it is held. We will keep client personal data for as long as required to keep such data for the applicable purpose it is being used or may be legally required.
USE AND DISCLOSURE OF PERSONAL INFORMATION
Spyre Group may use the personal information we have collected or the purpose of responding to your enquires, to advise you of an offering or service you have requested and to help carry out our obligations arising from any contracts entered in to between you and us.
We may disclose your personal information to recipients located outside Australia. These recipients may include:
1. Group companies
2. Group service providers
3. Partner organisations; and
4. Government organisations or statutory authorities
If we disclose personal information to another party, we will ensure that the party is aware of this policy.
DIRECT MARKETING MATERIALS
When you register as a member on our website, you will be given a choice as to whether you want to receive email messages from us, including newsletters, announcements and email communications about our latest news, products or services. To the extent the relevant law requires us to seek your consent, we will only send such messages to you if you opt-in. Further, as a registered member with us, you can modify your choice at any time by contacting us on the contact details provided.
These communications may be sent in various forms, including email, post, or SMS, in accordance with applicable laws, such as the Spam Act 2004 (Cth).
In addition, at any time, you may opt-out of receiving marketing communications from us by using the unsubscribe facility embedded at the bottom of all Spyre Group marketing communications or by contacting us on the contact details below.
PRIVACY ON OUR WEBSITES
Our websites may contain links to the websites of other entities. If you click on such links, you will transferred to the websites of these entities. We have no control over, and are not responsible for, the privacy practices of these entities. You should read the privacy policy of these entities to find out how they handle your personal information when you visit their websites.
STORAGE AND ACCESS TO PERSONAL INFORMATION
The personal information we hold will be stored electrotonically. Spyre Group have implemented policies and procedures to safeguard the secure storage and processing of data. When you provide us with personal information you thereby give us your consent to store your personal information for the purposes described above.
PRIVACY & SITE CHANGES
Spyre Group may update this Privacy Policy from time to time so please review it periodically for changes. If the changes are significant or substantive, they will either be advised to you in writing or posted on our website at www.spyregroup.com.au
Your continued use of our websites or services, requesting our assistance or provision of further personal information to us (either directly or via an authorised person) after this policy has been revised, indicates your acceptance of the revised Privacy Policy.
OUR CONTACT DETAILS
Spyre Group
47 Prospect Street
Fortitude Valley QLD 4006
Australia
MORE INFORMATION
For more information about the Privacy Act in Australia and protecting your privacy, visit the website below;