- who we collect information from;
- the types of personal information collected and held by us;
- how this information is collected and held;
- the purposes for which your personal information is used;
- when your personal information may be disclosed;
- when your personal information may be disclosed overseas;
- how you can gain access to your personal information and seek its correction; and
- how you may complain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or inquiry will be handled.
2 Who do we collect personal information from?
In the course of providing our products and services Blackbird Ventures Pty Ltd, may collect personal information from clients, or potential clients.
3 What types of personal information do we collect?
In the course of providing products and services we may collect and hold information that is reasonably necessary for the performance of our functions and activities, including maintaining a unitholders’ registry of investor details. This information may include Personal Information such as:
- names, addresses and other contact details;
- dates of birth;
- financial information;
- your nationality and country of birth;
- career history including areas of expertise;
- data required for AML/CTF purposes; and
- government identifiers (such as your TFN where necessary and relevant, although you may decline to quote your TFN).
We may collect **Sensitive Information*- about you, with your consent. Sensitive Information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. Provided you consent, your sensitive information may only be used and disclosed for purposes you have consented to or which are directly related to the primary purpose for which the sensitive information was collected, including:
- for the purpose of us maintaining a comprehensive company file;
- for the purpose of data compilation or analysis for internal purposes; and
- in an anonymised format for the purpose of data compilation or analysis to share with third parties. Sensitive information may also be used or disclosed if required or authorised by law.
4 How we collect and hold your personal information
How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.
Where possible Blackbird Ventures has attempted to standardise the collection of personal information by using specifically designed forms (e.g. our Application Forms). However, given the nature of our operations we often also receive personal information by email, online forms, letters, notes, over the telephone, in face-to-face meetings and through financial transactions. We may also collect personal information from other people (e.g. a third party administrator) or independent sources, however, we will only do so where it is not reasonable and practical to collect the information from you directly.
- In a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers;
- Only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any application legal reporting or document retention requirements; and
- Using industry standard security methods and best practices to protect your personal information from unauthorised access, modification or disclosure and from misuse, interference and loss. Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
5 How we use your personal information
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our uses of personal information include but are not limited to:
- Providing you with one or more of our financial services or products including to assess your application for a financial product or service;
- Fulfilling our legal and regulatory obligations;
- Connecting people within our community;
- Performing our related administrative and organisational functions and tasks; and/or
- To communicate with you about the products and services that we offer.
6 When we disclose your personal information
We may disclose your personal information, only if one or more of the following apply:
- you have consented;
- you would reasonably expect us to use or disclose your personal information in this way;
- we are authorised or required to do so by law;
- where a permitted general situation under the APPs applies.
This may include disclosure of your personal information to our employees, contractors and related entities, as well as third parties who supply services to us to assist us in performing our administrative functions and in fulfilling our legal and regulatory obligations (e.g. legal and accounting firms, data storage systems and certain SaaS providers). We will take reasonable steps to ensure that they handle your personal information in the same way that we do and in accordance with the Privacy Act and the APPs.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.
7 Disclosure of your personal information to overseas recipients
8 Your rights of access, correction and restriction
You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us in the manner outlined below. You may also contact us if any of the details you have provided change or if you believe that the information we have about you is not accurate, complete or up-to-date. If we do not agree to provide you with access or to amend your personal information as requested you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision and you may seek a review of our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.
You may also request that we restrict the use of your personal information for direct marking purposes by contacting us using the contact details below. Alternatively, to unsubscribe from our e-mail database or opt-out of communications (including marketing communications) you may use the opt-out facilities provided in the communication.
9 Your right of complaint
If you wish to make a complaint about a breach by us of the Australian Privacy Principles, you may do so by providing your written complaint by email, letter or by personal delivery to any one of our contact details as noted below. Where possible, the complaint should include enough information to help us resolve it. We will respond to your complaint in writing within a reasonable time (usually no longer than 30 days) and we make seek further information from you in order to provide a full and complete response.
If you are not satisfied with our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner by visiting www.oaic.gov.au.
We do not charge for receiving a request for access to personal information or for complying with a correction request.
10 How to contact us
- Emailing [email protected]
- Writing to our Privacy Officer at 240 Riley Street, Surry Hills NSW 2010
11 Changes to our privacy and information handling practices