This document sets out the policy of Gallus Partners Pty Ltd A.C.N. 100 644 666 (Gallus) relating to the protection of the privacy of personal information.
This policy document is intended to enable our clients, partners, and the general public to understand what types of personal information we collect, and what we do with such information in performing our functions and in light of our privacy obligations.
In some respects, the laws of jurisdictions outside Australia in which Gallus operates have additional requirements binding us. We are committed to complying with all such requirements.
2.What is personal information?
Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about a living individual who is either identified or reasonably identifiable. Examples include an individual’s name, address, contact number and email address.
Gallus Partners is required to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection/receipt to use and disclosure, storage, accessibility and disposal.
We are also required to comply with other laws, including more specific privacy legislation in some circumstances, such as:
Applicable data protection and privacy legislation of the other national jurisdictions in which Gallus operates.
The Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).
Gallus is generally exempt from the Privacy Act when it collects and handles employee records. However, our policy is to protect the personal information of its employees as it does other personal information.
The purposes for which we collect, hold, use and disclose personal information
In Australia and around the world, Gallus needs personal information to be able to perform its core functions, including advisory, investment management and real estate development.
The main purposes for which we collect, hold, use and disclose personal information are to provide investment opportunities to our wholesale and sophisticated investor clients, or creating personal profiles of individuals that are decision makers, influencers or other stakeholders involved either directly or indirectly in mandates or engagements directly linked to Gallus’ core functions.
Gallus may use personal information of clients and business associates, specifically your name and relevant address details and information about preferences for direct marketing, both as to the preferred communication channels for receiving direct marketing from Gallus and the types of products and services of interest, to let people know about Gallus’ services, facilities and benefits and those of third party partners, contractors and/or suppliers to Gallus, where we have recipient consent. Under Australian law, Gallus is not permitted to do so unless we have consent.
Where permitted by law to do so, Gallus or our partners, contractors and/or suppliers may contact persons for direct marketing purposes in a variety of ways, including by mail, email, SMS, telephone, online advertising, or facsimile.
3.Communication of your consent
You may communicate your consent to Gallus’ use of your personal data for Direct Marketing free of charge by:
When providing Gallus with your personal data through a form, signing on the form indicating your consent; or
Following the instructions in the document on which you are providing your personal data to Gallus.
Subject to the above, where you have consented to receiving direct marketing communications from Gallus, your consent will remain current until you advise us otherwise. However, you can, at no cost, opt out at any time, in the following ways sending a letter to;
Gallus Partners Privacy Officer,
PO Box 2602
Ascot QLD 4007
Or send an email to email@example.com
The kinds of personal information we collect and hold
The type of personal information that Gallus collects and holds about you depends on the type of dealings that you have with us. In each case, we seek to keep the personal information we need updated and accurate.
Under Australian law, sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection. Sensitive information includes health and genetic information and information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record and some types of biometric information.
Gallus’ policy is only to collect sensitive information where it is reasonably necessary for our functions or activities and either:
the individual has consented; and
we are required or authorised by or under law (including applicable privacy legislation) to do so.
3.Collection of information through our website
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website (such as preventing users from logging on and making purchases).
What if you don’t want to provide your personal information?
Gallus’ policy is to provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name.
In some cases, however, if you don’t provide us with your personal information when requested, we may not be able to respond to your request or provide you with the product or service that you are seeking.
How we collect and hold personal information
1.Methods of collection
Gallus is required by the Privacy Act also to collect personal information only by lawful and fair means. If it is reasonable and practicable, we will collect personal information we require directly from you.
Gallus collects personal information in a number of ways, including:
Over the telephone
Through written correspondence (such as letters, faxes and emails)
On hard copy forms
Electronic systems such as applications: and
Public sources, such as telephone directories, membership lists of business, professional and trade associations, public websites. ASIC searches, bankruptcy searches and searches of court registries.
Unsolicited personal information is personal information Gallus receives that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).
We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our functions or activities). If not, Gallus’ policy is to destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.
3.Disclosure of personal information to third parties
Under Gallus’ policy, personal information may be disclosed to the following third parties where appropriate for the purposes set out under Heading 2 above:
Financial institutions for payment processing
Regulatory bodies for Anti-Money Laundering and Counter- Terrorism, and combatting Fraud and other crime, in compliance with legislative requirements.
Bodies such as the Financial Ombudsman Service for the resolution of complaints and disputes
ASIC and similar bodies to comply with our legal obligations.
Referees whose details are provided to us by job applicants.
Information technology service providers.
Marketing and communications agencies.
Mailing houses, freight, and courier services.
Printers and distributors of direct marketing material.
External business advisers (such as recruitment advisers, auditors, and lawyers).
Regulatory bodies as required by law.
Cross border disclosure of personal information
Gallus has affiliates and investment partners in more than eight countries. These associated offices are part of Gallus’ normal business activities. Disclosure of personal information to these countries may occur in the normal course of Gallus’ business.
Under Heading 4 above, we set out a wide variety of situations in which personal information may be disclosed. In some of those situations, the disclosure may be to parties located overseas.
Use of government related identifiers
The Gallus policy is to not:
Use a government related identifier of an individual (such as a Medicare number or driver's licence number) as our own identifier of individuals.
Otherwise use or disclose such a government related identifier; and
Unless this is permitted by the Privacy Act (for example, where the use or disclosure is required or authorised by or under an Australian law or a court or tribunal order).
Data quality and security
Gallus holds personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in drawers and cabinets, locked where appropriate. Paper files may also be archived in boxes and stored offsite in secure facilities. Gallus’ policy is to take reasonable steps to:
Make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant; and
Protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.
You can also help us keep your information up to date; by letting us know about any changes to your personal information, such as your email address or phone number.
The steps we take to secure the personal information we hold include Information, Communications and Technology (ICT) security (such as encryption, firewalls, anti-virus software and login and password protection), and secure office access.
While Gallus strives to protect the personal information and privacy of website users, we cannot guarantee the security of any information that you disclose online, and you disclose that information at your own risk.
4.Third party websites
Access and correction of your personal information
Individuals have a right to request access to the personal information that Gallus holds about them and to request its correction.
Gallus policy is to provide you with access to your personal information, subject to some exceptions permitted by law. We may provide access in the manner that you have requested provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask Gallus to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, Gallus policy is to take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
If Gallus corrects personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, the Gallus policy is to take reasonable steps to do so, unless this would be impracticable or unlawful.
3.Timeframe for access and correction requests
Except in the case of more complicated requests, Gallus will endeavour to respond to access and correction requests within 30 days. What if we refuse your request for access or correction?
If you have a complaint about how Gallus has collected or handled your personal information, please contact our Privacy Officer (details under Heading 10 below).
Our Privacy Officer will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within one week.
If your complaint can’t be resolved at the first instance, we will ask you to complete a Privacy Complaint Form, which details (for example) the date, time and circumstances of the matter that you are complaining about, how you believe your privacy has been interfered with and how would you like your complaint resolved.
Please contact Gallus if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details for privacy queries and complaints are set out below.
Privacy Officer Gallus Partners Pty Ltd
PO Box 2602
Ascot QLD 4007 Australia
P: + 61 411 544 441
Changes to this policy