Privacy Policy

This Privacy Policy applies to Aspire42 Pty Ltd ACN 638 899 895, Aspire or “we” or “our”, as relevant.

1. Who we are and what this policy is about.

Aspire is part of a group of companies that specialises in infrastructure and financial investments including investments in other aspiring businesses whether in financial services or otherwise.

In the process of communicating with Aspire, we may collect, receive, deal with and store certain information.

Aspire is committed to safeguarding its client’s Personal Information it collects, receives and discloses and is committed to doing so in accordance with the requirements of the Privacy Act, 1988 Commonwealth (Privacy Act) as amended from time to time.

This policy describes our commitment in relation to protecting our client’s or prospective clients’ privacy.

2. What information does this policy apply to?

This policy only applies to Personal Information we receive from you if you applied to receive services from us or submit an inquiry to us in relation to what services we can offer.

If we refer you to another link or site in which you will be asked to provide personal financial information then this policy will apply equally to the collection, storage and handling of such information.

Generally speaking, Personal Information is information (or opinion), in any form, about an individual (not a business, company or trust) whose identity is apparent or can be ascertained from the information held whether the information is true or not.

Credit or financial information means information we collect from you or from a third party in relation about an individual’s consumer and or commercial credit worthiness.

Credit or financial information is a very broad term and includes information about desired credit, income and expenses relating to an individual, affordability measurements, credit worthiness, judgements and credit history.

Instead of referring to each of the categories separately, we refer to the categories in aggregation as Personal Related Information. Accordingly, Personal Related Information – for the purpose of this policy includes, as relevant, any information we collect, store, use or disclose which is Personal Information and Credit or financial information.

By agreeing to receive services or information from Aspire, you agree to the collection, use and disclosure of Personal Related Information (as relevant) as set out in this privacy Policy.

You do not have to disclose Personal Related Information to us. If you do not agree or do not provide some or all of the information requested, we may not be able to provide you with the services we offer to our clients.

3. Our general commitment

Aspire undertakes to collect, store and use Personal Related Information only in a manner which is compliant with the Privacy Act.

Aspire will not use or disclose Personal Related Information other than for:

(a) a purpose set out in this Privacy Policy;

(b) for a purpose for which the information was provided;

(c) for a purpose required or permitted by law;

(d) a purpose you authorised or is disclosed to you; and

(e) to give effect to your instructions.

If you acquire services from us, Aspire may collect, store and or disclose information about you to third parties for the following purposes:

(a) To comply with the law;

(b) to advance the services you require;

(c) to manage and administer the agreement with you;

(d) to protect your and our lawful interests;

(e) to give effect to your instructions; and

(f) to assist you to secure finance, improve your credit rating, manage risk and or manage investment.

4. Our collection and Disclosure of Personal Information

Aspire collects and discloses Personal Related Information as it may become necessary to provide you with our services and give effect to your instructions. We will always endeavour to collect Personal Related Information from you directly but sometimes, we are not able to collect the information directly from you and in this case, we may collect information from third parties.

Third Party Service Provider

If it is required, we may deal with third party service providers in relation to the services we offer to you and if this occurs, we will inform you of such requirement and the identity of these third party service providers.

5. Access to your Personal Information

You have the right to seek access to any information we hold about you. Contact our privacy officer in this regards. We may charge you a fee to access and or correct your Personal Information that is held with us. You have the right to ask us to correct any information we hold about you if the information is inaccurate or erroneous.

If we amend your record, we will notify you of the amendment. If we consider that your request to access your information is unreasonable, frivolous, not necessary, will harm or prevent enforcement action or any other lawful activity by a government or semi government authority, we may decline your request to access or correction of the information.

If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you. If we can’t make corrections within a 30 days’ time frame or the agreed time frame, we must notify you and agree with you an alternative time frame to amend the record.

6. Security of your Personal Information

Aspire maintains strict procedures and standards and takes all reasonable care to prevent unauthorised access to, and modification and disclosure of, your Personal Information.

Aspire will protect any Personal Related Information it holds against misuse or loss. If we no longer need the Personal Information, we will take steps to either destroy the information or de-identify it.

7. Direct marketing

Aspire may use your Personal Information to provide you with information from time to time in relation to additional services and or products we provide. You expressly authorise us to provide you with this information. You may withdraw your consent at any time by calling us.

8. Government identifiers

Aspire does not have access to any Personal Information that can be regarded as or be used as an identifier. For example, Aspire does not have access to your Medicare number or tax file number unless you disclose it to us. Aspire will not use any government identifier that was disclosed to us (such as TFN or Medicare number) to identify you.

9. Complaints

If you believe that your Personal Information is been mishandled by us or that we have breached this policy in any way, we invite you to write to our privacy officer at <. We will make every effort to resolve your complaint internally.

We will acknowledge your complaint within 5 business days of receiving it and we will look to provide a resolution to you compliant within a 30 days’ time frame. If we cannot resolve the matter within the 30 days’ time frame, we will inform you and agree with you on a different time frame to resolve the compliant.

If you are dissatisfied with the resolution, we offered you, you may file a complaint by escalating the grievance to Aspire’s executive team (Chief Operating Officer) who will endeavour to resolve your complaint expeditiously.

If you are still dissatisfied with our action, you may lodge a complaint with the Australian Information Commissioner (Privacy Commissioner.

The Commissioner can be contacted on

Online: WWW.OAIC.GOV.AU/PRIVACY

Phone: 1300 363 992

Email: ENQUIRIES@OAIC.GOV.AU

Fax: +61 2 9284 9666

Mail: GPO Box 5218 Sydney NSW 2001 Email enquiries@oaic.gov.au

10. Changes to this Privacy Policy

Aspire reserves the right to vary this policy from time to time. If we change the policy, we will post the revised policy as soon as it is completed on our website. We do not have to provide you with notice of changes to the policy. We encourage you to periodically review our privacy policy for any changes.

11. Transboarder of data

It is not likely that we will disclose Personal Related Information to overseas entities. If we disclose Personal Related Information to overseas entities, we will provide details on who they are and will ensure that they are bound by similar privacy commitments as we expressed in this Policy.

12. Website

When you use our website, we may collect statistical data in relation to your use of the site. This date includes the time and date of the visit to the site, the nature of the inquiry and any documents loaded. We may record your browser type and other internet protocols as permitted.

If you disclosed any Personal Information on the site, the information will be governed under this policy. The use of public internet public access to our website is not without risk. If you transmit Persona Information via the internet you should ensure that the transmission is secured.

Cookies

If you access our website, we may use Cookies for security and in order to better provide you with services. A “Cookie” is a small text file which is placed on your internet browser. We have access to the Cookie and can derive information in regard to the use of the site. You may change the settings on your browser to reject Cookies, however doing so might prevent you from accessing the secured pages on our website.

13. More Information?

If you have any questions regarding this privacy policy or would like more information about the way we manage your Personal Related Information, please contact us on:

Email: enquiries@aspire42.com.au

November 2021

End of Policy