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”, “us” or “we”) respect the privacy and security of your Personal Information, as defined below, and comply with the requirements of the Australian Privacy Principles (“APP”) under the Privacy Act 1988 (Cth) and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (“the Acts”).

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 some personal information. This allows us to process applications, administer accounts and provide you with information. We may also use your personal details to communicate with you about products and services and comply with relevant laws. We consider all information about you to be private and confidential.

This Privacy Policy does not apply to Spyre Groups’ employee records to the extent they are handled by any of our companies that is or was the employer of that employee in relation to the employee’s current or former employment. Such employee records are generally exempt from the Act and will be dealt with as permitted by law. 

You may be able to deal with us without identifying yourself (i.e. anonymously or by using a pseudonym) in certain circumstances. If you wish to do so, please contact us to find out if this is practicable in your circumstances. However, if you do not provide us with the Personal Information we have requested, we may not be able to complete or fulfill the purpose for which we collect the information, including providing our services. 

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.

WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?

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). 

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 and details about their business.

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:

Full name, date of birth, gender and contact details including telephone, address and e-mail;

Copy of a driver’s licence and /or passport or other identification documentation for the purpose of verifying identity and to ensure compliance with the Anti-Money Laundering and Counter- Terrorism Financing Act and/or other legislation and regulations regarding identification verification, and tax reporting and withholding;

Tax file number and bank account details for the purpose of administering investor accounts and tax reporting and withholding;

Investor contribution details and investment choices;

Details about authorised signatories;

Detailed contact information about a financial adviser; and

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

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 about you from someone else. For example, from;

Project Marketing Agencies who we contract to market and sell our properties

Market research companies contracted by us to obtain information so that we may improve and market our services;

Your employer;

Other agents and valuers who may be involved in the services we provide;

Publicly available information and databases;

Other companies within the Spyre Group;

A financial adviser or broker;

Authorised representatives, such as executors or administrators;

Identification verification service providers; and

Anyone you have authorised to deal with us on your behalf. We also automatically collect certain information when you visit our websites or our 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 our customers have requested, we may also seek to collect information about someone else from you (for example, contact details of your solicitor, emergency contact person or tenant). However, you must not provide us with Personal Information about another person unless you have clear consent from that person to do so, told them that their Personal Information will be handled in accordance with this Privacy Policy and directed them to where they can find it. 

Regardless of how it is collected, we handle Personal Information in accordance with this Privacy Policy. 

WHY WE COLLECT, HOLD AND USE PERSONAL INFORMATION

We generally collect, hold and use your Personal Information for the purposes for which it is provided to us (which will usually be obvious at the time of collection), related purposes or as permitted or required by law. Such purposes may include:

Relevant actions appropriated to the sale and marketing of a property

Project management services;

Structured advisory services;

Town planning services;

Capital allowances services and other consulting services in relation to the property market;

Administration of our business, such as collection of overdue accounts or other outstanding fees;

Responding to client enquiries and communicating with you from time to time to maintain contact and keep you updated on the services you have requested; 

Forecasting future needs of our services and general quality assurance and training purposes;

Engaging in legal proceedings and/or enforcing judgments and/or orders; 

Complying with the applicable legal or regulatory requirements and/or orders of competent authorities;

To establish and administer an investor’s investment account and their relationship with us;

Providing you with promotional and marketing information, including market research reports, newsletters, event invitations and/or property market information relating to our products and services which we think may be of interest to you; and

Any other purpose identified at the time of collecting your Personal Information. We generally use information automatically collected by cookies and other tracking technology to identify you as a valid user, ensure that no one else can sign on simultaneously with your account from another computer and help us serve you better based on your registration preferences. We may also use cookies to help us facilitate any promotions or surveys that we provide. Third parties whose products or services are accessible on our websites may also use cookies, and we advise you to check their privacy policies for information about their cookies and other privacy practices.

DISCLOSURE OF PERSONAL INFORMATION 

We may disclose your Personal Information to third parties as may be necessary for any of the purposes stated in the above section. Such third parties generally include:

Our third party providers, contractors, consultants, agents and/or representatives (such as law firms, banks, financial institutions, insurers, IT providers, mortgage referral services providers and/or wealth management services providers) who provide services to us or on our behalf, including to:

a.  Conduct valuations;

b.  Assist with obtaining payment from creditors;

c.  Operate data centres;

d.  Conduct market research;

e.  Provide advice;

Potential buyers, tenants, conjunctional real estate agents and brokers for the purpose for 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);

Anyone you have authorised to deal with us on your behalf; 

Any of the companies within Spyre Group and their related companies; 

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 Australian Government regulators such as 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; 

Australian Financial Complaints Authority (AFCA)

Debt collection agencies; and/or

Any other third parties identified at the time of collection of your Personal Information. 

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 providers, for instance:

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;

Auditors, consultants and other professional advisers;

Authorised financial advisers;

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;

Other financial institutions who hold an account in an investor’s name, for example, where amounts have been transferred to or from that account;

Authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to an investor’s account

ACCESS, UPDATE AND CORRECTION OF PERSONAL INFORMATION

We 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 either do so by contacting us using the contact details provided below. We will require you to verify your identity and specify what information you require.

SECURITY OF PERSONAL INFORMATION

We take reasonable steps to protect any Personal Information that we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure. For example, we implement IT security procedures including password protection, firewalls and site monitoring. and we store your Personal Information on a secure server. 

However, data protection measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your Personal Information. You must take care to protect your Personal Information (for example, by protecting any usernames and passwords). You should notify us as soon as possible if you become aware of any security breaches.

DIRECT MARKETING 

When you register as a member on our websites, you will be given a choice as to whether you want to receive e-mail messages from us, including newsletters, announcements and e-mail communications about our latest news, products or services. To the extent the relevant local law requires us to seek your consent, we will only send such messages to you if you opt-in.  If you do not wish to receive direct marketing calls or materials, you may use the unsubscribe facility in the marketing communication Further, as a registered member with us, you can modify your choice at any time by contacting us on the details below. We will stop using your Personal Information for direct marketing if you so request.

PRIVACY ON OUR WEBSITES

Our websites may contain links to the websites of other entities. If you click on such links, you will be 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.

WHAT IF YOU HAVE A COMPLAINT?

If you wish to make a complaint about a breach of this Privacy Policy or the Australian Privacy Principles of the Act you can contact us using the contact details below. You will need to provide us with sufficient details regarding your complaint together with any supporting evidence. 

We will investigate the issue and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation. 

If you are not satisfied with our determination, you can contact us to discuss your concerns or contact the Australian Privacy Commissioner via www.oaic.gov.au

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 websites at www.spyregroup.com.au.

Your continued use of our websites or services, requesting our assistance or the provision of further Personal Information to us (directly or via an authorised person) after this Privacy Policy has been revised, indicates your acceptance of the revised Privacy Policy.

OUR CONTACT DETAILS

If you have a query relating to this Privacy Policy or wish to make a complaint, please contact us using the following contact details: 

Spyre Group
PO Box 209
Fortitude Valley QLD 4006

MORE INFORMATION
For more information about the Privacy Act in Australia and protecting your privacy, visit the (external link) website below:
www.privacy.gov.au