Privacy Policy

Maple Investment Group Co. (ACN 665 963 235) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website and property services to you (Services) or when otherwise interacting with you.

The information we collect

Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

• Identity Data including first name, middle name, last name, maiden name, title, date of birth, gender, job title, photographic identification, marital status, pronouns and images of you.
• Contact Data including billing address, delivery address, email address and telephone numbers.
• Financial Data including bank account and payment card details (through our third party payment processor).
• Background Verification Data including your passport number, driver licence number, photographic identification or other details requested as part of our verification process to comply with our due diligence obligations, anti-money laundering laws and related ongoing monitoring commitments.
• Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
• Profile Data including your purchases or orders you have made with us, support requests you have made, content you post, send receive and share through our platform, information you have shared with our social media platforms, your interests, preferences, feedback and survey responses.
• Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Sensitive information is a sub-set of personal information that is given a higher level of protection. 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. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

How we collect personal information

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including when you register for an account, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
• From publicly available sources: We collect personal data from publicly available resources such as the Australian Securities and Investment Commission (ASIC) and professional networking sites such as LinkedIn.

Why we collect, hold, use and disclose personal information

We have set out below a description of the purposes for which we plan to collect, hold, use, and disclose your personal information.

• To assess whether to take you on as a new client, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you.
• To provide our Services to you, including to provide you with our educational resources, to assist you with your wealth management matters, and to arrange for any additional services requested by you with us or our partners.
• To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.
• To contact and communicate with you about any enquiries you make with us via our website.
• To offer you access to additional services or supports through third parties.
• For internal record keeping, administrative, invoicing and billing purposes.
• For analytics including profiling on our website, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.
• For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.
• To run promotions, competitions and/or offer additional benefits to you.
• If you have applied for employment with us; to consider your employment application.
• To comply with our legal obligations or if otherwise required or authorised by law.

Our disclosures of personal information to third parties

We may disclose personal information to:

• our employees, contractors and/or related entities, including where you request for our related entities to provide additional services to you;
• IT service providers, data storage, web-hosting and server providers, such as OneDrive;
• marketing or advertising providers;
• professional advisors, accountants, bankers, auditors, our insurers and insurance brokers;
• insurance brokers, real estate agents and or other service providers with your consent to provide additional services to you;
• payment systems operators;
• our existing or potential agents or business partners, including where you request for our partners to provide additional services to you;
• sponsors or promoters of any promotions or competition we run;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as Google Analytics, Meta Pixel or other relevant analytics businesses; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Google Analytics: We may have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, and Google Display Network Impression reporting. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. You can opt-out of Google Analytics Advertising Features using a Google Analytics Opt-out Browser add-on or by visiting Google’s Ads Preferences Manager.

Overseas disclosure

We may store personal information overseas. Where we disclose your personal information to the third parties listed above, these third parties may also store, transfer or access personal information outside of Australia, including but not limited to, UAE. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services, including for us to adequately verify your identity which may be required prior to us providing you with the Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Use of geo-localisation data

We collect your precise or approximate location via our mobile application for the following purposes:

• to tailor property options and our investments solutions for you based on your location;
• for security and safety;
• to prevent and detect fraud; and
• as permitted by law.

We collect this information when our mobile application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you.

Artificial Intelligence (AI) Technologies

We may use artificial intelligence and machine learning technologies in our business operations and when providing our Services to you, including AI tools provided by third parties.

How we use AI

We may use AI technologies to:

• improve and optimise our Services and operations;
• automate routine tasks and communications;
• personalise your experience with our Services;
• support quality assurance processes; and
• assist with customer support and enquiries.

When we work with third-party AI providers, we take reasonable steps to ensure they handle your personal information in accordance with the Australian Privacy Principles through contractual requirements and appropriate safeguards.

Our commitments when using AI

When using AI with your personal information, we commit to:

• informing you when AI is used to make decisions that may significantly affect you;
• maintaining human oversight and review of significant AI-generated decisions;
• training our staff to understand AI limitations and verify outputs before relying on them;
• implementing processes to verify the accuracy of AI-generated outputs;
• using appropriate technical and organisational measures to maintain the security and integrity of your personal information when processed by AI;
• regularly assessing and documenting risks associated with using AI to process personal information; and
• implementing appropriate measures to address identified risks and continuously monitoring AI performance.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

Contact us

For any questions or notices, please contact us at:

Maple Investment Group Co. (ACN 665 963 235)
Email: info@maplegroup.com.au

Last updated: 14 June 2024