Honesty. Transparency. Technical Excellence. Independence

+61 2 8332 2605

Privacy Policy

1. Privacy generally

This privacy policy applies to the handling of personal information by Bricktop Group Pty Limited (ABN 52 134 500 477) of Suite 3, Level 10, 6 O’Connell Street Sydney NSW 2000 (Bricktop, we us, our).
Bricktop understands the importance of protecting an individual’s personal information.  This privacy policy sets out how Bricktop aims to protect your personal information, your rights in relation to your personal information held by Bricktop and how Bricktop collects, holds, uses, discloses, and otherwise manages, your personal information.
In collecting, holding, using, disclosing and otherwise managing your personal information, Bricktop will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.
Bricktop will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time.  Any updated privacy policy will be made available on the Bricktop website, https://www.bricktop.com.au/, or can otherwise be obtained by contacting us and requesting a copy.

2. Kinds of personal information collected

Personal information is information or an opinion about an identified, or reasonably identifiable, individual.  During the provision of services, or as a result of our other interactions or dealings with you, Bricktop may collect your personal information.  Bricktop provides a range of real property investment services, including originating, assessing, structuring and settling real property transactions.  Bricktop also provides financial advice and funding solutions.
The kinds of personal information that Bricktop collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Bricktop collects may include:
a) contact and identification information you provide to Bricktop through inquiries you make to us such as your name, address, telephone number, email address, date of birth or other types of verification details; and
b) information about your financial circumstances and objectives, including your assets, liabilities, income, expenditure and investment preferences, including:
i) general identity information including the names and addresses of account holders; and
ii) your credit card information (which may include transactional histories, balances and limits);
Bricktop also collects internet/technology related information from visitors to our site or users of our other online services, including the referring URL, your IP address, which browser you used to come to the site, the country, state or province, the pages of our site that you viewed during your visit and any search terms entered on our site.

Bricktop may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.
Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information.  If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law.

3. How we collect personal information

Generally, Bricktop collects your personal information directly from you.  For example, Bricktop may collect your personal information:
* when you register for an account with us, request information or services, or otherwise provide us with your details;
* where you use our websites or other online services or otherwise interact with us;
* when you complete a survey;
* if you post information to our website; or
* where you engage us to provide services to you, including real property investment services and financial advice services.
There may be occasions when Bricktop collects your personal information from someone other than you, for example:
* from your bank or other relevant financial institutions in order to provide our services to you;
* from third parties you authorise to disclose your information to us (including banks and other third party financial services);
* from a publicly maintained record or other publicly available sources of information including social media and similar websites;
* from our vendors or suppliers that help provide our services to you (for example, customer support information or payment information); or
* from third parties if you connect to our services or register an account with us using an external third-party application, such as Facebook or Google.
Generally, Bricktop will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you.

4. Purposes for which personal information is used

Generally speaking, Bricktop collects, holds, uses or discloses personal information so that we can provide you investment services and financial advice.
Some examples of the purposes for which Bricktop collects, holds, uses and discloses your personal information include to:
* enable us to supply you with information you request from us;
* facilitate the supply of services to you, including communicating with and providing a quote to you about engaging us to provide services;
* supply our services to you, including real property investment services and financial advice services;
* personalise your experience with our services;
* conduct promotions, competitions, giveaways and events;
* contact you to obtain your feedback regarding our goods or services or to conduct other market research;
* undertake direct marketing (as detailed in paragraph 5 below);
* conduct investigations in cases of fraud, credit or data security risks;
* analyse information we collect so that we can administer, support, improve and develop our business and the services we offer (including by monitoring or recording our interactions with you for training purposes); and
* comply with the obligations of Bricktop under any applicable laws.
In addition to the purposes listed above, Bricktop may use your personal information for purposes related to the above purposes, other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law.
Where personal information is used or disclosed, Bricktop takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.  You are under no obligation to provide your personal information to Bricktop.  However, without certain information from you, Bricktop may not be able to provide services or information to you or may be limited in how we can interact with you.

5. Direct marketing

In addition to the purposes outlined in paragraph 4 above, Bricktop may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, goods or services that may be of interest to you.  This may include Bricktop disclosing the information to related companies of Bricktop or other entities with which Bricktop has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes.  If you do not wish to receive such communications, you can opt-out by contacting Bricktop via the contact details set out in paragraph 12 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you.

6. Disclosure of personal information

Bricktop discloses your personal information for the purpose for which Bricktop collects it.  As a result, generally, Bricktop will only disclose your personal information for a purpose set out in paragraphs 4 and 5 of this privacy policy.  This may include disclosing your personal information to:
* related companies of Bricktop;
* other parties who invest in or acquire an interest in Bricktop;
* service providers and contractors and other third parties that provide goods or services to us (including our technology service providers, our business consultants, or other business or administration service providers);
* people or entities considering acquiring an interest in Bricktop’s business or assets;
* Bricktop’s professional advisors (including legal and accounting firms, auditors, consultants, insurers and other professional advisers); and
* government authorities where required by law.
Bricktop may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or the disclosure is required or authorised by law.
If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

7. Overseas disclosures

Some of the parties that Bricktop discloses your personal information to may be located outside Australia, including technology service providers in USA and Ireland and related companies of Bricktop located in USA and Ireland.
We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act. 

8. Links to other websites

When you access our websites or other online services, we may provide as a convenience to you, links to other websites, including websites operated by our partners, associates, or independent third parties.  These links are provided as a convenience to you.  Each website has its own privacy practices, as described in that website’s privacy policy.  Those practices may be different from the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that website.  Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party and cannot be and are not responsible for any information that you may submit to that website.

9. Cookies

When you visit our websites or other online services, we will generally leave a ‘Cookie’ in the memory of your web browser.  The website or other online service may only function properly if Cookies are enabled.  Our websites and online services may use persistent Cookies to authenticate you as a user and display content that is relevant and specific to you.
Cookies are very small files that store information about your visit to and use of a website.  Most major commercial Internet sites use them and they make your Internet-surfing more useful and less time-consuming because they store information that is reusable each time you visit our website, such as birthday and other preferences you have chosen to share with us.
Cookies cannot access and read the files on your hard drive.  They do allow us to provide information and products that are more meaningful to you without asking you the same questions every time you visit us.  You may get Cookies from our advertisers.  We cannot pre-screen these Cookies since they come directly to you from other sites.  We hope you will want the better service that Cookies allow, but if you prefer, you can set your browser to refuse Cookies.  However, by doing that, your access to our website, https://www.bricktop.com.au/, may be compromised or limited. This may also affect the provision of certain services through our website.

10. Security of personal information

Bricktop takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Bricktop holds personal information in electronic forms in secure databases on secure premises, accessible only with the appropriate passwords by authorised staff.
The processes and systems we use to secure your personal information include:
a) the use of identity and access management technologies to control access to systems on which information is processed and stored;
b) requiring all employees to comply with internal information security policies and keep information secure;
c) requiring all employees to complete training about information security; and
d) monitoring and regularly reviewing our practise against our own policies and against industry best practice.
Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.
We have in place procedures for training our employees about their obligations under this privacy policy, disciplining them for failure to follow this privacy policy. We also have in place internal procedures to confirm general company compliance with this privacy policy.
Bricktop will destroy or de-identify personal information in circumstances where it is no longer required, unless Bricktop is otherwise required or authorised by law to retain the information.

11. Access and correction

Bricktop takes steps reasonable in the circumstances to ensure any personal information it holds is accurate, up-to-date, complete, relevant and not misleading.
In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Bricktop.  If at any time you would like to access or correct the personal information that Bricktop holds about you, or you would like more information on Bricktop’s approach to privacy, please contact Bricktop using the details set out in paragraph 12 below.  Bricktop will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. 
To obtain access to your personal information:
* you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
* Bricktop requests that you be reasonably specific about the information you require; and
* Bricktop may charge you a reasonable administration fee, which reflects and will not exceed the cost to Bricktop for providing access in accordance with your request.
Bricktop will endeavour to respond to your request to access or correct your personal information within 30 days from your request.  If Bricktop refuses your request to access or correct your personal information, Bricktop will provide you with written reasons for the refusal and details of complaint mechanisms.
If you are dissatisfied with Bricktop’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

12. Contacting Bricktop

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Bricktop using any of the following contact details:
Email:  michael@bricktop.com.au
Post:  Suite 3, Level 10, 6 O’Connell Street Sydney NSW 2000
Phone:  02 8332 2605

13. Privacy complaints

Please direct all privacy complaints to Bricktop.  At all times, privacy complaints:
* will be treated seriously;
* will be dealt with promptly;
* will be dealt with in a confidential manner; and
* will not affect your existing obligations or affect the commercial arrangements between you and Bricktop.
Bricktop will acknowledge your complaint within 14 days of receipt and endeavour to resolve it within 30 days, unless Bricktop informs you otherwise and seeks your agreement in writing.
Bricktop will commence an investigation into your complaint.  You will be informed of the outcome of your complaint following completion of the investigation.  In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Bricktop will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.