At Grosvenor Pirie, we take your privacy seriously.
Last updated: 3 August 2022
This policy applies to Flare HR Pty Ltd and its subsidiaries (Flare):
- Flare HR Pty Ltd (ABN 46 607 120 892)
- Flare Financial Services Pty Ltd (ABN 16 612 284 081)
- Responsible Investment Services Pty Ltd (ABN 77 630 578 200)
- Simple Financial Choices Pty Ltd (ABN 58 629 890 900)
- Spark Leasing Pty Ltd (ABN 65 647 814 659)
Flare provides a variety of general and financial services. Certain parts of this policy will only apply based on the services you have chosen to take with us.
1. Collection and holding personal information
Types of personal information
We collect personal information about customers and other people who interact with us. The details of exactly what types of personal information we collect can be found on our website, mobile applications (apps) and forms, and in the questions we ask when we communicate with you in writing or over the phone.
Typically, the personal information we collect includes your name, address, contact details and date of birth. We may also collect information about your gender, marital status, dependents, occupation, employer, salary details, bank account details and Tax File Number (TFN) insofar as such information is necessary to provide contracted or requested services to you.
Sometimes we are required to collect sensitive information from or in relation to you. Sensitive information includes Government identifiers (such as your drivers’ licence number, your passport number, your Medicare number or your visa/work permit status) as well as your health and lifestyle records (usually for insurance purposes), and is subject to greater restrictions relevant to its collection and use. Sensitive information will only be collected with your express consent and where the law requires us to do so and will only be used for the purpose for which it was provided.
How personal information is collected
Generally, we will collect your personal information directly from you. For example, you provide us with personal information:
- During the course of your contact with us on a matter, such as an application, enquiry or complaint;
- When you complete one of our forms;
- When you use our website or app;
- When your employer registers you as a platform user and uses the platform to administer their human resources and payroll functions, for example to update your details;
- When you access products and services from our business partners via the platform;
- When you contact, register with, post to, like or follow any of our social media pages;
- When you register for our events or sign up to our newsletters; and
- When you participate in our competitions, promotions or surveys.
We may also collect personal information about you from a third party, such as your partner or other family members, employer, lawyer or financial advisor, the Australian Taxation Office (ATO), another superannuation fund of which you are a member, a clearing house, or an identity verification service. In such cases, we’ll obtain authority from you first.
Your personal information is only requested if (and insofar as) it is relevant and necessary for us to provide contracted or requested services to you. Before we collect personal information we will explain to you why we are collecting the information, how we intend to use it, whether we are likely to disclose your personal information to overseas recipients, and the consequences if the personal information is not collected. This explanation is sometimes provided in writing, for example via a product disclosure statement or website, or over the phone.
For employment candidates, Flare collects your personal information including employment history and other information during the recruitment process either directly from you or from recruiters.
How personal information is held
We take reasonable precautions to protect and secure your personal information from misuse, interference, loss, unauthorised access, modification or unauthorised disclosure.
Your personal information is held by us and/our administrators electronically on secure systems including those provided by cloud service providers. Within Flare and our administrators, access to your information is restricted to staff who require the information to administer your account and provide information and services to you. This information is secured by passwords, encryption and firewalls, in line with Australian information security standards.
We apply industry practice in our security measures, but we cannot guarantee the security of your personal information. If there is a breach of our security, we will investigate it, let any affected users and customers know, and take all other appropriate steps relevant in the circumstances.
Retention of personal information
Your personal information is only retained for as long as necessary to fulfil the purpose/s for which it was collected; unless we are required to retain the information for a certain period under an Australian law or court or tribunal order. Once the information is no longer required we take such steps as are reasonable in the circumstances to destroy or permanently de-identify your personal information.
2. Use of personal information
We use your personal information for the primary purposes of:
- Establishing and administering your account in accordance with contract that we have with you as well as the laws that we must comply with;
- Enable you to access and use the platform, our products and our services;
- ensure you’re eligible for products and services (including insurance);
- help you combine your super accounts and check if you have lost super (when you ask us to);
- manage and resolve complaints made;
- report information required by law or regulations; and
- perform any other appropriate related functions.
Enable your employer and its nominated personnel to administer your employer’s human resources and payroll functions;
- Complying with our customer identification and verification procedures;
- Where your TFN has been provided, locating or identifying your super accounts, reporting to other regulated superannuation entities (when transferring your benefits to that entity), and reporting to the ATO; and
- Dealing with enquiries and complaints.
We also collect personal information for related secondary purposes, including:
- Informing you of additional services and products that might be available to you through us;
- provide financial education;
- Improving or helping us to better tailor our products and services generally and to you specifically;
- Administering rewards, surveys, competitions and other promotional activities or event sponsored or managed by us; and
- Statistical, prudential, market or other research purposes (aggregated results only).
We are always working to improve our platform, products, services and consumer insights to give you the best customer experience. We may provide de-identified information about you to third parties as part of a data analytics process. If we do, it will be aggregated and anonymous information that does not identify individuals.
If you choose not to provide the personal information that we request, or provide us with incomplete or inaccurate information, we may be prevented from efficiently administering your account, providing insurance coverage, responding to your enquiry, investigating your complaint and/or maintaining contact with you. Additionally, we may not be able to provide the products and services that best meet your needs.
For employment candidates, Flare collects your personal information for recruitment purposes, to manage your employment application and, if you are successfully placed in a position at Flare, your ongoing employment.
3. Anonymity and pseudonymity
If you’re requesting general information, you may do so anonymously or by using a pseudonym. However, for specific account enquiries it is generally impracticable and illegal for us to deal with you on an anonymous basis. We must be certain of your identity before we can discuss your account with you. If you contact us to discuss your account, you must be able to prove your identity. This ensures that we can protect your personal information by only giving it to you or someone who can prove that they are lawfully authorised to act on your behalf.
4. Disclosure of personal information
In undertaking our obligations to you, we may disclose your personal information to:
- Our employees and related bodies corporate;
- Your employer;
- Our primary business partners for the purpose of establishing and administering your account.
- Our business support providers, including credit reporting agencies, debt collection agencies, third party payment providers, identity verification service providers, card issuers, mailing houses, document storage, printing and collating companies, digital data back-up and storage companies and IT service providers.
- Independent consultants and market research companies, for the purpose of conducting data analysis and market research with respect to our products and services.
- Our loyalty or affinity program partners.
- Law enforcement and government agencies, regulatory and complaints handling bodies, and/or courts and tribunals in order to comply with legal or regulatory obligations or requests or where there is a legal or professional right or duty to disclose.
- Our audit, legal and other professional advisers.
- Another superannuation fund, should you elect to rollover some or all your account balance to that fund.
- Those organisations and people as authorised by you under a signed third-party authority or power of attorney, such as your parent/guardian, financial advisor, lawyer or estate planner.
- Your potential beneficiaries, legal personal representative or estate in relation to a distribution of your superannuation account upon your death
Where personal information is disclosed, we’ll seek to ensure the information is held, used and disclosed consistently with the APPs and other applicable privacy laws and codes.
Tax file number
If you disclose your tax file number (TFN) to us, you authorise us, our related companies, and our agents, to store and use your TFN as authorised by law.
Due to the sensitivity of TFNs and the legal restraints on their use and disclosure, if you lose or forget your TFN, we will not be able to provide it to you. You will have to ask the ATO for a copy of it.
Where commercially feasible, we contract with other software vendors in Australia, who are subject to the APPs. However, from time to time we may engage global enterprise software vendors to support our internal operations, meaning there are circumstances where your personal information may be disclosed to a recipient in a foreign country.
In addition, anonymised web traffic information is disclosed to third party analytics platforms when you visit our website (who may store the information across multiple countries) and when you communicate with us through our social media channels, where the provider and its partners may collect and hold your personal information overseas.
We will not disclose your personal information to overseas recipients unless and until we have taken reasonable steps to ensure that the overseas recipient will handle your personal information in a manner consistent with the APPs, or you have consented to the transfer of the information.
Contact with you
If you provide us with your telephone number and/or email address, you agree and accept that we, or an agent or a related entity on our behalf, may contact you via telephone, SMS or email. We will do this to facilitate action on your account, to confirm information, to gauge customer experience or for any other reasonable or marketing purpose. If you do not want this to happen, please contact us.
We may use your personal information to contact you with new information or offers for products or services from us and our business partners which we think might be of interest to you. We may send this information to you by post, email or SMS.
Your personal information will never be added to a general marketing database. We do not sell, rent or trade your personal information to or with third parties for the purpose of allowing them to send marketing material directly to you.
If you don’t wish to receive marketing material, please opt-out by adjusting your account settings using the opt-out facilities provided (e.g. an unsubscribe link) or contacting us.
5. Privacy on the internet
Our mobile application and website
If you log in to your account via either our app or website, we’ll collect personal information when you create and make changes to your account or to provide access to additional functionality, such as calculators. We only collect personal information with your consent via electronic forms on each platform.
The Internet is not a secure environment. If you use the Internet to send us personal information you do so at your own risk.
You can change your browser settings to refuse all cookies or to notify you each time a cookie is sent to your computer and give you the choice whether to accept it. If you reject all cookies, you may not be able to use all functions on our website and mobile app.
We may transmit usage information about visitors to our website and app to third party ad servers for the purpose of targeting our Internet banner advertisements on other websites. The information that is collected and logged on our behalf through this technology is not information from which you can be personally identified.
Links to other websites
You may be able to access external websites by clicking on links provided on our website or app. Those links are provided for your convenience and may not remain current or be maintained.
Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ to ours, so we encourage you to read them before using those websites.
Social media applications
Whilst we may use social networking platforms for communications, we won’t ask you to supply personal information publicly over these platforms. Sometimes we’ll invite you to send your details to us via private messaging, for example, to answer a question you have raised about your account.
Any personal information that you contribute to the publicly accessible sections of social media applications can be read, collected and used by other users of the application. We have little or no control over these other users and cannot guarantee that any information that you contribute to any social media applications will be handled in accordance with our privacy standards.
Interactive tools on our website and app, such as calculators, often require you to enter personal information. We only retain this information where a calculator or similar tool allows you to save your information and retrieve it later. The information stored will not be viewed by us.
We may analyse the customer information we hold against information we are permitted to use from external sources such as statistical data. Generally, this information is based on aggregated data that doesn’t contain information that identifies individuals.
6. Access to and correction of information
You have a right to know what personal information we hold about you and to obtain access to it. If the information we hold is inaccurate, incomplete or not up-to-date, you also have a right to request that we correct it.
There are some circumstances in which we’re entitled to deny you access to information or to refuse to alter your information. We will advise you if any of these circumstances apply.
7. Resolution of privacy concerns
If you’re concerned about a possible interference with your personal information, a breach of this Policy or a breach of the APPs, please contact us.
If we receive a privacy complaint it will be treated seriously and dealt with promptly, in a confidential manner and in accordance with our internal complaints handling procedures. We’ll contact you if we require any additional information from you and will notify you in writing of the investigation’s outcome.
If your complaint is not resolved by us to your satisfaction, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC).
Director of Compliance (Investigations)
Office of the Australian Information Commissioner
Phone: 1300 363 992
Fax: 02 9284 9666
Email: [email protected]
Address: GPO Box 5218 Sydney NSW 2001
8. Review of our policy
We reserve the right to modify this policy from time to time to reflect our current privacy practices. We make the most recent version available to you to read on our website and our app. Alternatively, you may request a copy of the policy by contacting us.
9. Contact Us
We treat any concerns or complaints that you may have with respect and confidentially. A privacy representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
You can contact the Flare Privacy Officer by:
Email [email protected]
Phone 1300 352 734
Post PO Box R1979, Royal Exchange NSW 1225
If you want to contact us in relation to your superannuation account with us:
Email [email protected]
Phone (02) 8074 1772
Post PO Box R1979, Royal Exchange NSW 1225
Information provided in this article is of a general nature only and we have not taken your personal financial objectives, situation or needs into account. We recommend you consider if you need to seek professional financial advice before making any financial decisions.