Privacy Collection Statement

Privacy Collection Statement

Spire Capital Ltd, ABN 21 141 096 120 (‘Spire’) is committed to respecting the privacy of individuals we deal with and we understand your concerns about privacy and the security of your Personal Information. This Privacy statement summarises how we protect your privacy, how we manage your Personal Information and how we comply with the requirements of the Privacy Act 1988 (Cth) (‘Privacy Act’) and the Australian Privacy Principles (refer to www.oaic.gov.au for further information).

We collect Personal Information that is reasonably necessary for us to provide you with our products and services as well as to administer them. We may collect Sensitive Information from you as required under the law,  but only where you have consented to such collection of Sensitive Information, where such information is necessary to provide you with a specific product or service, or where the collection is necessary to lessen or prevent a serious threat to life, health or safety.

Spire may collect and use your Personal Information for the purpose for which it was provided to us, including to communicate with you about the products and services that we offer, subject to legal requirements and your right to opt out. You can choose not to provide us with your personal information.  If you do not provide us with the personal information we request, such as identity verification documents, we may not be able to provide you with our services or undertake, process transactions requested by you or respond to your enquiry or query. We will also use and disclose your Personal Information to send direct marketing to you. You may opt out of receiving this direct marketing through the ‘unsubscribe’ function that will be available to you with each direct marketing communication.

We may also collect Personal Information from third parties including your organisation and representatives, our related companies, public sources and third parties such as our fund administrators, agents, brokers, referrers or other independent publicly available sources. We may disclose your Personal Information to third parties (some of whom may be located overseas, including the United States) who may be involved in assisting us with one or more of our functions or activities, in accordance with our Privacy Policy and the Privacy Act.

We take reasonable steps to protect the Personal Information we hold about you from misuse, loss, unauthorised access, modification or disclosure. We will promptly notify you if we are aware of or have reasonable grounds to believe that your Personal Information held by us is involved in an eligible notifiable data breach and involves Personal Information being lost or subjected to unauthorised access or unauthorised disclosure which is likely to result in serious harm. Our assessment and escalation of such breaches will be in done in accordance with our internal Breach Reporting policy and procedures.

In some cases, we may also collect your Personal Information through the use of cookies. When you access our website, we may place a cookie (which is a small summary file containing a unique identification number) on your computer. This enables us to recognise you when you return and greet you each time you visit our websites with any relevant preferences. It also enables us to keep track of services you view or preferences you have so that, if you consent, we can send you news about those services..

At your request, we will provide you with a copy of any information which we hold about you, unless an exception under the Privacy Act applies, or there is some legal or administrative reason why we be unable to do so and must deny such request. Where we deny your request, we will provide you with a reason why (if we can).

We have developed a Privacy Policy which embodies the spirit of the Australian Privacy Principles and outlines Spire Capital’s approach to privacy and how it collects, uses and protects Personal Information.

If you would like more information about how we handle your information, please view our detailed Privacy Policy, maintained on our website.

The Privacy Policy  contains information about how you may request access to and correction of personal information Spire Capital Ltd holds about you,  or to make a complaint about an alleged breach of the Australian Privacy Principles. You can also contact our Spire Privacy Officer using the following details:

Spire Capital Ltd, Level 30, Suite 3/264 George Street, Sydney, NSW, 2000.

Email: info@spirecapital.com.au.

If you have any questions about your privacy (including any access, correction, complaint or marketing opt-out requests, or for further details of the entities to which this Privacy Statement applies) you can contact us via the contact details above or on our website.

This Statement is subject to change at any time. Please check the Privacy Policy link on our website regularly for any changes.

Issued December 2025