Privacy Policy & Privacy Collection Notice

Privacy Collection Notice

The Privacy Collection Notice provides you with a summary of the key points on how we collect, use, disclose, and store your personal information. We do this in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APPs).

Our Privacy Policy is available at https://www.spaceship.com.au/privacy-policy/ and it contains more information about how you may access and seek correction of your personal information, how you may complain about a breach of the APPs by us, and how we will deal with such a complaint. If you have any concerns about your privacy or would like a free digital or paper copy of our Privacy Policy, please feel free to contact us by calling us at 1300 049 532, by emailing us at help@spaceship.com.au, or by sending us a letter to Level 1, 20 Hunter Street, Sydney NSW 2000.

This Privacy Collection Notice was last updated on 18 May 2024.

About us

Spaceship Capital Limited (ABN 67 621 011 649, AFSL 501605) (Spaceship Capital):

is the AFS Licensee (Licensee) that carries on business as the promoter of the Spaceship superannuation product (Spaceship Super);
is the responsible entity of the registered managed investment schemes Spaceship Universe Portfolio, Spaceship Earth Portfolio, Spaceship Origin Portfolio, as well as the Spaceship Galaxy Portfolio and Spaceship Explorer Portfolio (which are the investment options offered within the Spaceship Master Fund individually) (together Spaceship Voyager); and
provides customers with the ability to invest in eligible US securities (Spaceship US Investing Service) through Alpaca Securities LLC (Alpaca).

This policy applies to Spaceship Capital and its related corporate entities, including Spaceship Financial Services Pty Ltd (ACN 611 615 797) (together we, us, our and the Spaceship Group).

Spaceship Super is issued by Diversa Trustees Limited (ABN 49 006 421 638, AFSL 235153, RSEL L0000635) (Diversa, Trustee) as trustee of OneSuper (ABN 43 905 581 638).

Spaceship is on a mission to transform the way people think about and invest their money.

The personal information we collect and why we collect it

The types of personal information we collect include your name, gender, date of birth, contact details, and tax file number (TFN). Please refer to our Privacy Policy for a full list of the information we collect.

We collect your personal information to allow us to provide you with the products and services you have requested from us. We’re also required to collect the information to comply with laws and regulations relevant to our products and services.

You can request to access and correct the personal information we hold about you at any time.

How we collect and store the information

We only collect your personal information by lawful and fair means. We’ll generally collect your personal information:

directly from you, for example, when you apply for or request information in relation to a product or service online or over the phone;
during the course of our relationship with you, which may include recording your interactions with us;
through identification documents you provide us; and/or
through public sources, information brokers, and third parties such as the trustee of our superannuation product, and referral partners.

The information we collect is stored electronically and physically both at our own premises, and where relevant, with our service providers. The Spaceship Group is committed to protecting the personal information we hold about you from misuse, loss, and unauthorised access. Some of the ways we do this are by:

using firewalls, encrypting and password protecting your personal information;
restricting employee access to our databases based on their roles and responsibilities; and
requiring our employees to complete privacy training.

The period we are required to hold and store your personal information is set out in our Privacy Policy and is in accordance with applicable laws.

Who do we share your info with?

In addition to Spaceship Group staff, we share your personal information with others only where we need to. These parties may be located in Australia or overseas. This includes:

organisations that help us to provide our products and services to you e.g. trustees, administrators, custodians, auditors, US brokerage, clearing and settlement providers, and providers of banking, insurance, marketing, advertising, valuation, technology and data processing services;
government and law enforcement agencies or regulators, including courts and tribunals;
your executor, administrator, trustee, guardian or attorney;
your agents, such as financial or legal advisers, or person with power of attorney, or anyone else you authorise us to provide your information to;
credit reporting agencies and other organisations used to verify your identity; and
people that introduce you to us, such as our referral partners.

What if you don’t provide your info to us?

You don’t have to give us your personal information, including your TFN, however, if you don’t, we may not be able to provide the products or services you have requested from us, or more information about them.

Privacy Policy

1. Purpose and Application of the Privacy Policy

1.1. Spaceship Capital Limited (ABN 67 621 011 649, AFSL 501605) (Spaceship Capital) is the AFS Licensee (Licensee) that carries on business:

as the promoter of the Spaceship superannuation product (Spaceship Super);
as the responsible entity of the registered managed investment schemes Spaceship Universe Portfolio, Spaceship Earth Portfolio, Spaceship Origin Portfolio, as well as the Spaceship Galaxy Portfolio and Spaceship Explorer Portfolio (which are the investment options offered within the Spaceship Master Fund individually) (together Spaceship Voyager); and
providing customers with the ability to invest in eligible US securities (Spaceship US Investing Service) through Alpaca Securities LLC (Alpaca).

This policy applies to Spaceship Capital and its related corporate entities, including Spaceship Financial Services Pty Ltd (ACN 611 615 797) (together we, us, our and the Spaceship Group).

Spaceship Super is issued by Diversa Trustees Limited (ABN 49 006 421 638, AFSL 235153, RSEL L0000635) (Diversa, Trustee) as trustee of OneSuper (ABN 43 905 581 638).

1.2 The Privacy Policy details how we collect, use, disclose, and store your personal information. We do this in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APPs).

The Spaceship Group is committed to protecting your privacy and the personal information you entrust us with.

2. Personal information we collect

2.1 Personal information includes any information or opinion about an identified individual, or information from which a person’s identity can be reasonably determined. The information or opinion will still be personal information whether it is true or not, and regardless of whether we have kept a record of it.

2.2 The types of personal information we collect and hold may include your:

name;
date of birth;
contact details (including your residential address, email address and mobile number);
device information (such as device type, operating system, IP address, geo-location information and connection information);
biometric information (such as video footage or photographs of your face);
identification documents and related government identifiers (such as your driver licence, passport and Medicare information);
financial details, and where you use certain features internet banking login details and transactions);
tax file number (TFN);
transaction information and records of our interactions with you;
citizenship and tax residency details;
employment information (such as employment details and salary);
status as a politically exposed person; and
other information required to allow us to provide you with the products and services you have requested.

2.3 If you’re a Spaceship Super customer, we may also collect your:

gender;
superannuation contributions history; and
nominated beneficiary details.

2.4 Sensitive information (such as information about your religious beliefs or affiliations, racial or ethnic origin, political opinions, criminal record, sexual orientation or practices, health information and biometric information) is a subset of personal information.

If we need this type of information, we’ll ask for your permission – except where otherwise allowed by law.

3. Why we collect your personal information and how we use it

3.1 We collect your personal information to allow us to provide you with the products and services you have requested from us. We’re also required to collect the information to comply with laws and regulations that are relevant to the products and services that we provide.

3.2 Some of the reasons we collect and use your personal information are:

to create, maintain, and carry out transactions in Spaceship Voyager;
to create, maintain and provide you with information relating to your Spaceship Super account;
to provide you with the ability to use our Spaceship US Investing Service;
to verify your identity, bank account information, and investigate and protect against fraud and unlawful activity;
to meet our obligations specified in applicable laws such as the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), the Superannuation Industry (Supervision) Act 1993 (Cth) (SIS Act), and the Income Tax Assessment Act 1936 (Cth) (ITAA Act); and
to comply with requests and orders served on us by courts and enforcement agencies.

4. Your tax file number

4.1 Spaceship Voyager

If you apply for a Spaceship Voyager account and you choose to provide your TFN, we collect your TFN as the responsible entity of those managed investment schemes.

4.2 Spaceship Super

If you apply for a Spaceship Super membership and you choose to provide your TFN, we collect your TFN on behalf of Diversa, and you give us and our agents permission to store and use your TFN as authorised by the SIS Act.

We collect your TFN to facilitate your Spaceship Super membership and enable you to search for and consolidate other superannuation funds you may have, in compliance with the ATO SuperMatch Terms and Conditions.

We may disclose your TFN to another superannuation provider when your benefits are being rolled out. However, we won't do this where you've asked us in writing not to disclose your TFN to any other superannuation provider.

4.3 Spaceship US Investing Service

In order to open a Spaceship US Investing Service account, you must provide your TFN, which is required by Alpaca. You authorise us to provide your TFN to Alpaca.

4.4 You don’t have to provide your TFN to us

If you decide not to provide your TFN, we may not be able to provide you with the product or service that you have requested.

If you have a Spaceship Voyager account, we will be required to deduct withholding tax from your investment income at the highest marginal rate plus the Medicare levy. You may be able to claim a credit from the ATO for amounts withheld as part of your tax return.

If you have a Spaceship Super account, we won't be able to accept personal (after tax) contributions from you and are required to deduct tax at your highest marginal tax rate plus Medicare levy from your concessional contributions, and benefits paid to you.

If you do not provide us with your TFN, you will be unable to access the Spaceship US Investing Service because it is an Alpaca requirement to provide this information in order to request a Spaceship US Investing Service account.

5. How we collect your information

5.1 We only collect your personal information by lawful and fair means. We’ll generally collect your personal information:

directly from you, for example, when you apply for or request information in relation to a product or service online or over the phone;
during the course of our relationship with you, which may include recording your interactions with us;
through identification documents you provide us; and/or
through public sources, information brokers, and third parties such as the trustee of our superannuation product or our referral partners.

5.2 Email

When we receive emails from you, we will retain the content of the email and our response to you where we consider it necessary to do so. Your email address will only be used or disclosed for the purpose for which it was provided. It will not be added to any mailing lists or used for any other purpose without your consent.

5.3 Website

We collect non-personal information about users of our website, including information on which areas of the website are most often accessed, how users navigate through the site and interact with pages (including fields completed in forms and applications completed), how long visitors visit those areas, and other information such as browser type, operating system and IP addresses to help us manage and improve our website.

We store information that we collect through cookies, log files, and/or third party site traffic software to create profiles of users generally.

We won’t ask you to supply personal information publicly over Facebook, Twitter, or any other social media platform that we use. Sometimes we may invite you to send your details to us by means of private messaging, for example, to answer a question about your account or to record a complaint. You may also be invited to share your personal information through secure channels to participate in other activities, such as competitions.

5.4 Cookies

A "cookie" is a small text file which is placed on your internet browser and which we access each time you visit our website. When you visit the secured pages of our website (i.e. pages that you have to provide login details to access) we use cookies for security and personalisation purposes. When you visit the unsecured pages of our website (i.e. public pages that you can access without providing login details) we use cookies to obtain information about how our website is being used.

You may change the settings on your browser to reject cookies, however doing so may prevent you from accessing the secured pages of our website.

5.5 When you provide information about another individual to us (for example when you nominate a beneficiary or a trusted contact) you will need to first obtain their consent and tell them about our Privacy Policy.

6. Sharing your personal information

6.1 In addition to Spaceship Group staff, we share information with others only where we need to. These parties may be located in Australia or overseas. This includes:

organisations that help us to provide our products and services to you e.g. trustees, administrators, custodians, auditors, US brokerage, clearing and settlements provider, and providers of banking, payments, insurance, marketing, advertising, valuation, technology and data processing services;
government and law enforcement agencies or regulators, including courts and tribunals;
your executor, administrator, trustee, guardian, or attorney;
your agents, such as financial or legal advisers, or person with power of attorney, or anyone else you have authorised us to provide your information to;
credit reporting agencies and other organisations used to verify your identity; and
people that introduce you to us, such as our referral partners.

If you use the Spaceship US Investing Service, we will disclose your personal information to overseas recipients who are located in the United States of America.

We take all reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations with respect to the protection of your personal information. If you direct or permit us to disclose your personal information to a third party through use of our products or services, then please refer to that third party provider’s privacy policy to understand the manner in which that third party treats your personal information.

6.2 Disclosure to a credit reporting agency to verify your identity

We may disclose your name, residential address and date of birth to a credit reporting agency and ask the credit reporting agency to provide an assessment of whether the personal information so provided matches (in whole or in part) personal information contained in a credit information file in the possession or control of the credit reporting agency to assist in verifying your identity for the purposes of the AML/CTF Act. The credit reporting agency may prepare and provide us with such an assessment and may use your personal information including the names, residential addresses and dates of birth contained in credit information files of you and other individuals for the purposes of preparing such an assessment. If you disagree with having your identity verified by a credit reporting agency, please let us know so that we can discuss other options with you.

7. Accessing and correcting your personal info

7.1 You can request access to, or correction of, the personal information that we hold about you by calling us at 1300 049 532 or emailing us at help@spaceship.com.au.

We will provide our reasons if we deny any request for access to, or correction of, personal information. You can make a complaint in the event you are not satisfied with the reasons provided for denial of your request.

Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

7.2 There is no fee for requesting access to your personal information, requesting correction of your personal information or for us to make any corrections to your personal information. However, we might charge a fee to cover the time we spend finding and putting together information you want. If there’s a fee, we’ll let you know how much it is likely to be, so you can choose if you want to go ahead.

8. Storing and securing your personal information

8.1 Under applicable laws, we are required to hold and store your personal information, including information collected in customer identification procedures and transactions for:

seven years from the date your Spaceship Voyager or Spaceship US Investing Service access was closed or the date the last designated service was processed; or
ten years from the date your Spaceship Super account was closed or the date the last designated service was processed.

8.2 The information we collect is stored electronically and physically both at our own premises and, where relevant, with our service providers. The Spaceship Group is committed to protecting the personal information we hold on you from misuse, loss, and unauthorised access. Some of the ways we do this are by:

using firewalls, encrypting and password protecting your personal information;
restricting employee access to our databases based on their roles and responsibilities; and
requiring our employees to complete privacy training.

8.3 If you are considering sending us any personal information through our website or other electronic means, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email).

8.4 We take reasonable steps to destroy or permanently de-identify any personal information when we no longer need it – for example, for business or legal reasons.

9. Links on our website

Our website may contain links to third party websites. We advise that the terms of this policy do not apply to external websites. If you wish to find out how any third parties handle your personal information, you will need to obtain a copy of their privacy policy.

10. Bank account linking

10.1 We provide the option for you to use a third-party service provider (illion Australia Pty Ltd (illion)) to help you choose what account you'd like to make payments from and to, and to help us verify your bank account details.

We do this by asking you to provide your internet banking login details, which will be used by illion to establish a secure and automatic connection with your bank. illion will retrieve your bank account details (including the type, name, BSB, account number and balance). We'll present these details to you so that you can select the bank account from which you'll make payments and payments will be made to you. Once you have selected your preferred bank account, illion will provide your bank account name, BSB and account number (of your selected account) to us. Illion will then securely destroy your internet banking login details.

10.2 We only have access to view and store your account name, BSB and account number of the account that you select to use. Neither illion nor us will have the ability to control your account or perform any transactions on your account.

The ePayments Code is a code of practice that most banks have subscribed to. The ePayments Code protects you when making electronic payments such as by using internet banking. If your bank subscribes to the ePayments Code, you have rights and obligations in relation to sharing your internet banking details. By entering your internet banking details, you acknowledge that your rights under the ePayments Code may be affected and where an unauthorised transaction or fraudulent activity occurs, you may be liable for loss that arises.

11. Marketing

11.1 We may use your personal information to provide you with information about products and services, including those of third parties, which we consider may be of interest to you.

We may also provide your details to other organisations for specific marketing purposes.

11.2 You may opt out at any time if you no longer wish to receive marketing information. In order to do so, you will need to request that we no longer send marketing materials to you or disclose your information to other organisations for marketing purposes. You can make this request by emailing us at help@spaceship.com.au, calling us at 1300 049 532, by "unsubscribing" from marketing messages, or turning off push notifications on your mobile device.

12. Contacting us to ask questions, raise concerns or provide feedback

If you have any questions, concerns, complaints or feedback about privacy, please contact our Privacy Officer:

Privacy Officer
Level 1, 20 Hunter Street
Sydney NSW 2000
1300 049 532
help@spaceship.com.au

We take your privacy concerns seriously. Where you express any concerns that we have interfered with your privacy or have breached Australian Privacy Principles, we will respond to let you know who will be handling your matter and provide a response within 30 days. Exceptions may apply, refer to Spaceship Capital’s Complaints Policy for more information.

We aim to resolve your concerns in a fair and efficient manner and in compliance with our Complaint Policy which can be viewed at https://www.spaceship.com.au/complaints-policy/.

If, however, you are unsatisfied with our response, you can lodge a dispute with our external dispute resolution scheme, the Australian Financial Complaints Authority (AFCA), which provides a free independent industry dispute resolution service:

AFCA
GPO Box 3, Melbourne VIC 3001
1800 931 678
info@afca.org.au
www.afca.org.au/make-a-complaint

You may also lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

OAIC
GPO Box 5218, Sydney, NSW 2001
1300 363 992
enquiries@oaic.gov.au
www.oaic.gov.au

13. Changes to this policy

We may make changes to this policy from time to time, without prior notice to you. An up-to-date copy of this policy is available on our website.