Privacy Policy

Spruce Global places great importance on Customers’ privacy and understands Customers’ concerns regarding the security of Customers’ personal information. We are dedicated to safeguarding any personal information that we possess. This Privacy Policy outlines our general practices for collecting, holding, using, and disclosing personal information, as well as Customers’ rights concerning the personal information, we maintain about Customers of Spruce Global.

This document explains the reasons why Spruce Global may collect personal information from Customers of Spruce Global, how we handle it, and the process for requesting access to the personal information we have on record. Spruce Global adheres to the National Privacy Principles, as outlined in the Privacy Act of 1988 (Privacy Act) (as amended) and the Australian Privacy Principles (APP).

For the purposes of this Privacy Policy, 'we' and ‘us’ means Spruce Global Pty Ltd ACN 667 961 382. By providing us with Customers’ personal information Customers of Spruce Global consent to us using and handling Customers’ information in accordance with this Privacy Policy. If Customers of Spruce Global provide any personal information about another individual then we rely upon Customers of Spruce Global to inform him or her of the details contained in our Privacy Policy.

When this Privacy Policy mentions a party, which may be an individual or an organization (such as our clients or service providers), this reference encompasses individuals who serve as employees, directors, or principals of an organization or its affiliates.

Personal Information

The term 'personal information' is defined in the Privacy Act 1988 (Cth) as any information or opinion regarding an identified individual or an individual who can be reasonably identified. This definition encompasses information or opinions, whether true or not, and whether they are recorded in a material form or not.

As part of our business operations and functions as a service provider, we gather and retain various types of personal information. The specific personal information we collect and retain about Customers of Spruce Global is contingent upon the nature of our relationship with Customers of Spruce Global.

Our clients

In our interactions with clients, we generally gather and retain the following categories of personal information:

• Personal details such as Customers’ name, job title, address, date of birth, and contact information.
• Company-related information, including details about Customers’ company's branches, operational areas, jurisdictions, organizational structure, and information about directors and beneficial owners.
• Information regarding Customers’ company's structure, the source of funds, and the source of wealth.
• Any other information that Customers of Spruce Global furnish to us or that we collect during the course of our association with Customers of Spruce Global.
• To the extent that it is relevant to the service we are providing for a client or our general relationship with a client, we may also collect and hold personal information about clients that is sensitive information under the Privacy Act.
• Details of a Clients AML/CTF program and certain operational details, including results of any reviews.

The amount and nature of information we collect from Customers of Spruce Global when Customers of Spruce Global use our website or engage with us online will vary based on Customers’ utilization of the website's features and the services available online. However, the only personal information we gather from Customers of Spruce Global through our website or online contact methods is the information Customers of Spruce Global voluntarily provide, such as when Customers of Spruce Global fill out an application form or when Customers of Spruce Global send us an email.

What are the purposes for which we collect personal information?

We collect personal information from Customers of Spruce Global and other relevant sources for various purposes, including:

• Assessing and processing Customers’ applications for our products or services and any related proposals.
• Providing Customers of Spruce Global with the products and services we offer as part of our business.
• Administering and managing all products or services provided to Customers of Spruce Global.
• Carrying out administrative tasks like risk assessment, planning, research, statistical analysis, systems development, and testing.
• Responding to Customers’ inquiries and addressing any complaints Customers of Spruce Global may have regarding our products or services.
• Conducting data analytics to enhance our products and services.
• Verifying Customers’ identity and complying with legal and regulatory obligations.
• Supporting our internal business operations, including audits, record-keeping, and account reviews.
• Analysing products and customer needs to develop new offerings.
• Keeping Customers of Spruce Global informed about products and services provided by us, our related companies, or preferred providers that we believe may be of interest to Customers of Spruce Global, unless Customers of Spruce Global've indicated otherwise.
• Managing overdue payments and debt recovery.
• Implementing fraud prevention measures.
• Outsourcing certain functions to external service providers and suppliers, such as mailing houses, IT services, advertising, and marketing.
• Assessing and evaluating applications from potential contractors and service providers.
• Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, we are mandated to collect specific personal information. If Customers of Spruce Global choose not to provide us with Customers’ personal information or do not consent to its collection, use, or disclosure, we will be unable to perform the activities outlined in this document.

Disclosure of Personal Information

Spruce Global will exclusively utilize Customers’ personal information for the purposes outlined in this statement or those directly related to it. We will not engage in trading, selling, or leasing Customers’ information. However, there may be situations where we are obligated to share Customers’ information with specific third parties. The entities most likely to receive Customers’ information include:

• Regulators
• Government authorities

Customers of Spruce Global have a right to request access to personal information that we hold about Customers of Spruce Global and request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. Customers of Spruce Global may do so by contacting us as compliance@spruceglobal.com.au. We will respond to all requests for access to or correction of personal information within a reasonable period.

In some instances, in accordance with the Privacy Act, we may charge a fee for access to personal information we hold about Customers of Spruce Global or refuse to grant access to such information. 

Complaints

If Customers of Spruce Global wish to file a complaint regarding a breach of the Australian Privacy Principles, Customers of Spruce Global can contact our Privacy Officer at compliance@spruceglobal.com.au. We will promptly respond to complaints, typically within 30 days.

If Customers of Spruce Global are not satisfied with our response, Customers of Spruce Global have the option to escalate Customers’ complaint to the Office of the Australian Information Commissioner. Customers of Spruce Global can reach them by visiting www.oaic.gov.au, calling 1300 363 992, or emailing enquiries@oaic.gov.au.

For more information on how we handle personal information, to request access to or correction of Customers’ personal information held by us, or to make a complaint, please don't hesitate to contact our Privacy Officer via email at compliance@spruceglobal.com.au.

Storage and Security

Customers’ personal (including credit information) may be held in physical or electronic form on our systems or the systems of our service providers. In order to assist with the prevention of unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

No information transmitted over the Internet can be guaranteed to be secure. We cannot guarantee the security of any information that Customers of Spruce Global transmit to us, or receive from us. The transmission and exchange of information is carried out at Customers’ own risk. Although we take measures to safeguard against un-authorised disclosures of information, we cannot assure Customers of Spruce Global that information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Please notify us immediately if there is any unauthorised use of Customers’ account by any other Internet user or any other breach of security. For the purposes of viewing our website Customers of Spruce Global may have a username and password. Customers of Spruce Global are responsible for the security and confidentiality of Customers’ password and log-in information.

Changes to our privacy policy

We understand that our Privacy Policy may need occasional review and revision. We encourage Customers of Spruce Global to visit our website periodically to stay informed about our latest Privacy Policy.

Please note that our Privacy Policy was last updated on the 21 June 2025.