The Policy covers Gleneagle Securities (Aust) Pty Ltd ABN 58 136 930 526, Gleneagle Asset Management Limited ACN 103 162 278, Blossomapp Pty Ltd ABN 74 644 216 151 and all of their respective related companies (referred to as The Group, We, Ours or Us).
This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website. Any information collected after an amended privacy statement has been posted on the site will be subject to that amended privacy statement.
What this Policy deals with
We only collect personal information that is reasonably necessary for one or more of Our functions or activities. The types of personal information that We collect and hold about you could include:
We must collect personal information only by lawful and fair means. We must collect your personal information from you unless it is unreasonable or impracticable to do so. For example, if We are unable to contact you and We then rely on publicly available information to update your contact details or if, at your request, We exchange information with your legal or financial advisers or other representatives.
We might collect your information when you fill out a form with us (either in hard copy or via our website), when We speak with you on the telephone, use Our website or face to face. We may also verify your information via electronic means, such as email.
If We receive personal information that We did not solicit, then within a reasonable period after receiving the information, We must determine whether or not We could have collected the information under Australian Privacy Principle 3 (collection of solicited personal information) if We had solicited the information and We may use or disclose the personal information to make this determination.
Then, if We determine that We could not have collected the personal information and the information is not contained in a Commonwealth record, We must, as soon as practicable but only if it is lawful and reasonable to do so, destroy the information or ensure that the information is de-identified. If however this does not apply in relation to the personal information, the Australian Privacy Principles 5 to 13 apply in relation to the information as if We had collected the information by solicitation.
We will do all that We can to ensure that the personal information that We collect, use and disclose is accurate, up-to-date, complete and relevant.
When We receive personal information from you directly, We will take reasonable steps to notify you how and why we collected your information, who We may disclose it to and outline how you can access it, seek correction of it or make a complaint.
Sometimes We collect your personal information from third parties. You may not be aware that We have done so. If We collect information that can be used to identify you, We will take reasonable steps to notify you of that collection.
We may collect information about you because We are required or authorised by law to collect it. There are laws that affect Us, including company and tax law, which require Us to collect personal information. For example, We require personal information to verify your identity under the Anti-Money Laundering and Counter-Terrorism Commonwealth law.
If We collect and hold your personal information for a primary purpose, We will not use or disclose the information for a secondary purpose unless:
If We collect personal information from any of our related bodies corporate, this principle applies as if Our primary purpose for the collection of the information were the primary purpose for any of our related bodies corporate collected the information. This principle does not apply to the use or disclosure by Us of personal information for the purpose of direct marketing or government related identifiers.
If We hold personal information about an individual, We must not use or disclose the information for the purpose of direct marketing, unless We collected the information from the individual and the individual would reasonably expect Us to use or disclose the information for that purpose, and We provide a simple means by which the individual may easily request not to receive direct marketing communications from Us and the individual has not made such a request to Us.
We may also use or disclose personal information about an individual for the purpose of direct marketing if We collected the information from the individual and the individual would not reasonably expect Us to use or disclose the information for that purpose or someone other than the individual and either the individual has consented to the use or disclosure of the information for that purpose, or it is impracticable to obtain that consent, and We provide a simple means by which the individual may easily request not to receive direct marketing communications from Us, and in each direct marketing communication with the individual, We include a prominent statement that the individual may make such a request, or We otherwise draw the individual’s attention to the fact that the individual may make such a request and the individual has not made such a request from Us.
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way however as we are often governed by strict regulations that require us to know who We are dealing with. In general, We will not be able to deal with you anonymously or where you are using a pseudonym when it is impracticable or we are required or authorised by law or a court/tribunal order to deal with you personally.
We will always give you access to your personal information unless there are certain legal reasons why We cannot do so. We do not have to provide you with access to your personal information if:
If we cannot provide your information in the way you have requested, we will tell you why in writing. If you have concerns, you can complain by sending us an email to email@example.com.
If you believe there is something wrong with the information, for example if you think that the information We hold is inaccurate, out of date, incomplete, irrelevant or misleading, please change your information through the website, iOS or Android App or send us an email to firstname.lastname@example.org.
If you are worried that We have given incorrect information to others, you can ask us to tell them about the correction. We will correct this if We can or We will notify you if We are unable to change the details.
You can ask us to access your personal information that We hold by sending us an email to email@example.com.
We will give you access to your information in the form you want it where it is reasonable and practical to do so. We may charge you a small fee to cover our costs when giving you access, but We will always notify you of this first and this fee will not relate to you making a request for your information, only to give you access to the information.
We are required to help you ask for the information to be corrected if We cannot correct this for you. Accordingly, We may need to talk to third parties. However, the most efficient way for you to make a correction request is to send it to the organisation which you believe made the mistake.
If We are able to correct the information, We will notify you within five business days of deciding to do this. We will also notify the relevant third parties as well as any others you notify Us about. If there are any instances where We cannot do this, then We will notify you in writing.
If We are unable to correct your information, We will explain why in writing within five business days of making this decision. If We cannot resolve this with you internally, you are able to make a complaint via our external dispute resolution scheme, by contacting the Australian Financial Complaints Authority (AFCA) or the Office of the Australian Information Commissioner (OAIC).
If We agree to correct your information, we will do so within 30 days from when you asked us, or a longer period as agreed between Us and you.
If We are unable to make corrections within a 30 day time frame or the agreed time frame, We must notify you of the delay, the reasons for it and when we expect to resolve the matter, ask you to agree in writing to give us more time and let you know you can complain to AFCA or OAIC.
The complaints handling process is as follows:
The individual should make the complaint including as much detail about the issue as possible, in writing to Us:
The Blossom Support Team, Blossomapp Pty Limited Level 27, 25 Bligh Street, Sydney NSW 2000
We will investigate the circumstances included in the complaint and respond to the individual as soon as possible (and within 30 calendar days) regarding Our findings and actions following this investigation. After considering this response, if the individual is still not satisfied they may escalate their complaint directly to the Information Commissioner for investigation:
Office of the Australian Information Commissioner www.oaic.gov.au Phone: 1300 363 992
When investigating a complaint, the OAIC will initially attempt to conciliate the complaint, before considering the exercise of other complaint resolution powers.
Alternatively, if the complaint relates to a non-privacy matter, or should individuals choose to do so, a complaint may also be lodged with AFCA:
Australian Financial Complaints Authority www.afca.org.au Phone: 1800 931 678
We may need to share some of your information with organisations outside Australia. For example, when We open an account for you we will generally need to share your details with one or more of the entities in CIMB Group, which is based in Asia and operates in Malaysia, Indonesia, Singapore and Thailand.
We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.
Overseas organisations may be required to disclose information We share with them under a foreign law. In those instances, We will not be responsible for that disclosure.
Sometimes We may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless We are authorised or required to do so by law or the use or disclosure of the identifier is reasonably necessary for Us to verify your identity for the purposes of Our business activities or functions.
This policy covers electronic communications between you and Us (and our directors, employees and agents) before you become a customer, while you are a customer and for any later correspondence. When you are a customer, We and you are bound by this policy and each may rely on it.
Electronic communications covers any type of communications(inducing notifications) using electronic means from time to time. Electronic means includes emails, telephone, the Blossom App, website usage and social media channels. The electronic means are generally provided by third parties (such as Facebook).
We are not responsible for the third party services, even though we use them to communicate with you. You and We use them on an “as-is” basis, with their risks of delays, suspension or failure, disruptions, government control and access and also access by unauthorised persons (other than you and any of Us). Subject to any overriding duties and liability imposed on Us, We are not liable to you or to any other person for failures, breaches, errors and disruptions in third party services used in electronic communications.
We may give you access to your Account (including allowing messages between Us, transactions and exporting information) by allocating to you a user name and password (whether or not selected by you and also later changed) (Security Information).
We may suspend, terminate or impose conditions on your use of any kind of electronic communications with Us if we believe it is in your interests, or there is or might be a security breach or We are acting in accordance with Our duties or any part of any of Our policies.
By using electronic communications, you and We agree not to contest the validity or enforceability of any electronic communications or transactions Moneytech on the basis of the electronic nature of that communication or transaction.