The purpose of this policy is to outline Next Generation Operations Pty Ltd (trading as Brickraise) policy in relation to the collection, storage, use, maintenance, disclosure and other administration of personal information.
3.1 Rights to Privacy
NGO recognizes the seriousness of protecting an individuals’ right to privacy. NGO has prepared this policy statement to help you understand how we handle personal information and how we aim to care for the privacy of your personal information. While administering personal information, NGO is subject to the Privacy Act and complies with the Australian Privacy Principles in the Privacy Act. This policy details the way NGO collects, uses, discloses or otherwise manages your personal information and your rights in relation to our administering of your personal information. This policy may be updated as needs so that NGO can provide current best practice procedures.
3.2 What type of personal information does NGO gather?
For the purposes of the Privacy Act, personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individualwhose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Typically, NGO will collect personal information, like your name and contact details including home address and e-mail address and/or any other information, which is necessary to provide our services to you or to provide you with information about NGO and/or our products and services.
The specific kinds of personal information we compile will depend on the level of our business dealing with you. For example, you might choose to register on to our site so that you can access more information about possible investment opportunities – in this case NGO only requires name, email & phone contact details. Should you decide to invest in any of the opportunities, NGO may collect information such as your name, residential and business address, date of birth, contact details (such as email and phone numbers), income details, asset and liabilities information, tax and financial statements, employment details and details regarding your financial or accounting advisors.
If you attend seminars, meetings or other events conducted by NGO or register for updates, newsletters or other information services of NGO, we may collect information such as your name, email and phone numbers and details regarding any product or services you have expressed an interest in.
NGO will not usually collect or hold sensitive information about you, unless NGO is required to do so by law. Sensitive information may include information about yourrace, political or religious beliefs, sexual preferences, criminal convictions, membership of professional or trade associations or unions or health information.
3.3 Gathering of personal information
NGO collects personal information in a number of circumstances including where you apply to invest, request information regarding NGO or its products or services, attend seminars or other events held by NGO, register for newsletters, updates or other similar information services of NGO or otherwise engage with NGO. Where you are an investor in any opportunity listed by NGO, NGO will collect personal information from you to process and establish that investment and also in the course of administering that investment.
NGO gathers your personal information directly from you, usually by requesting that you complete an application form.
There may be times when NGO will collect your personal information from a third party. For example NGO may collect your personal information from a publicly maintained record, a third party broker, a person authorised by you (such as your accountant or financial advisor) or our agents or service providers (e.g. registry service providers).
If NGO Group collects your personal information from a third party, NGO will take reasonable steps to inform you of certain matters, such as NGO’s identity and contact details.
3.4 So why does NGO need personal information?
NGO collects, holds, maintains, uses and discloses personal information for the purposes of operating its business and providing its services, including to:
* provide you with information regarding the products or services of NGO;
* progress your application for investments in the products or services of NGO;
* establish your investment in a product or service of NGO; and
* manage your investment in a product or service of NGO.
Where you invest in a product of NGO, NGO will collect, hold, maintain, use and disclose your personal information as required to fulfill its legal obligations under the relevant laws applying to that product.
NGO may also collect, hold, maintain, use and disclose personal information to conduct identification and verification processes in accordance with the Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Act or any other relevant laws.
For some investors, NGO might be required to collect and disclose personal information to the Australian Taxation Office in order to comply with theForeign Account Tax Compliance Act (FATCA).
Not providing your personal information will affect NGO’s ability to provide our range of products and services to you and may result in NGO not being able to progress your application for investment in our products or otherwise provide servicesto you.
3.5 Direct marketing
NGO may collect, hold, maintain, use and disclose your personal information to inform you of products, services or offers of NGO which may be of interest to you. Where you are an investor in a product of NGO, this may include providing you with direct marketing information regarding the other products of NGO.
NGO may contact and communicate with you for the purpose of direct marketing via the telephone, post, facsimile, email or SMS.
If you do not want to receive this information or do not want NGO to use or disclose your personal information for direct marketing purposes, you can opt out by contacting our Privacy Officer or otherwise letting us know that you wish to opt out of receiving this information and/or NGO using or disclosing your personal information for direct marketing purposes.
NGO will never share your personal information with any other external companies for any purpose other than what is required for you to invest in NGO products or that required under the relevant law.
3.6 Sharing information with other organisations
NGO may disclose your personal information to third parties for the purposes outlined in paragraphs 3.4 and 3.5 above.
The types of organisations to which NGO may disclose the personal information NGO has about you include:
* your adviser, or dealer group or accountant;
* the other entities within NGO or other related companies of NGO (such as subsidiaries or holding companies);
* any third party service provider NGO may employ to provide custody, administration, technology, auditing, mailing, printing or other services;
* Government authorities when and to the extent required by law; and
* NGO’s professional advisers (including legal and accounting firms, auditors, consultants and other advisers). Such disclosure will only be done on a confidential basis.
3.7 Preservation of your personal information
NGO may hold personal information in both hard copy and electronic forms.
NGO undertakes to take all reasonable steps to protect the personal information it holds is secured against misuse, loss, unauthorised access, modification or disclosure. Personal information is held on secured servers or in storage located in controlled, access restricted environments. NGO’s employees are required to preserve the privacy of any personal information held by NGO.
In some cases personal information may also be held on behalf of NGO in hard copy or electronic forms by NGO’s service providers (such as offsite document storage providers or electronic data storage providers). Where required, NGO will enter into agreements with such service providers which impose confidentiality and privacy obligations on the service provider.
3.8 Can you access the personal information NGO has about you?
NGO will take all reasonable steps to ensure that the personal information NGO gathers, holds, maintains, uses and discloses is correct, complete, current and relevant.
You have the right to request access to the personal information NGO gathers and holds about you. You have the right to ask for correction of the personal information NGO collects and holds about you.
If you would like access to or correction of the personal information held about you by NGO you can contact our Privacy Officer per the below contact details:
Next Generation Operations Pty Ltd
Level 2 Riverside Quay
1 Southbank Boulevard, Southgate
Phone: (+61) 1300 845 565
NGO will endeavour to respond to requests for access to or correction of personal information within 30 days of the date of the request.
Should NGO refuse any request for access to or correction of personal information held by NGO, reasons for that refusal will be provided in writing as soon as practicable by NGO.
3.9 What can you do if you have complaint about your privacy?
Please direct all privacy complaints in writing to our Privacy Officer.
A privacy complaint relates to any concern or disagreement you may have with NGO’s privacy practices as they relate to your personal information. This may include things such as:
(a) if you think NGO has contravened the APP’s, a binding registered APP code or any other applicable obligations under the Privacy Act regarding your personal information;
(b) how your personal information is collected;
(c) how your personal information is held;
(d) how your personal information is maintained;
(e) how your personal information is used or disclosed; or
(f) how access to your personal information is given.
Privacy complaints will always:
(a) be treated seriously and handled promptly;
(b) be dealt with confidentially; and
(c) not affect your existing responsibilities to any business agreements that may exist between NGO and you.
The Privacy Officer will initiate an inquiry into your complaint and will answer the complaint within a reasonable period of time. You will be informed of the result of your complaint following the conclusion of the inquiry. Should you be unhappy with the outcome of your complaint, it is your right to refer the complaint to the Office of the Australian Information Commissioner.
4 Questions or concerns
5 How does NGO conduct reviews of this policy?
6 Legal and regulatory framework
The Privacy Act outlays 13 Australian Privacy Principles, which are mandatory principles which NGO is required to satisfy in relation to NGO's collection, storage, use, maintenance, disclosure or other administration of personal information.
The Office of the Australian Information Commissioner is the statutory body responsible for a number of functions in relation to the Privacy Act, including conducting investigations and handling complaints in relation to the Privacy Act and the Australian PrivacyPrinciples.
In this policy, unless the context otherwise requires:
NGO Entity means any member of the NGO Group and any of the NGO Funds.
NGO means NGO and any of its controlled or related entities.
Corporations Act means the Corporations Act 2001 (Cth).
Privacy Act means the Privacy Act 1988 (Cth).
Privacy Officer means the NGO team member responsible for administering privacy compliance within NGO.