Last updated: March 16, 2019 First Hedge Pty Ltd (“us”, “we”, or “our”) operates the Stewart Financial Services website (the “Service”).

  • Stewart Financial Services and our subsidiaries (herein referred to as “we” “our” or “us”) are always focused on ensuring and providing the best service for our users. We are committed to protecting your privacy and will always take all necessary measures to ensure that your information is safe and secure.
  • We seek to provide the best possible service to our users (herein referred to as “you”). To do this, we are required to collect some personal information from our users to ensure that you are eligible to use our services and to provide you with the most relevant and beneficial content.
  • Although we try our best by implementing various methods to safeguard your personal information. Unfortunately, no measures can be guaranteed to provide 100% security, so please ensure you carefully consider the terms contained here within because we cannot guarantee the security of your information.
  • Stewart Financial Services Wealth deals with information privacy in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles set out in the Privacy Act and the European Union’s General Data Protection Regulation (GDPR).
  • We recommend that you read this Privacy Policy in full to ensure you are fully aware and informed. Your continued use of the site confirms your confirmation of acceptance of these terms. If you have any questions about this Privacy Policy, please contact us at angus@stewartfinancialservices.com.au.

 

1. Information We Collect

What do we collect?
Personal Data means any information relating to an identified or identifiable individual.

For Stewart Financial Services to provide you with the best possible service, we may ask you to provide us with some of your personal information, including, but not limited to: your name, mailing address, phone number, email address, occupation, proof of earning and expenses, contact preferences and credit card information.

Financial Information means any general information about your current financial position.

For Stewart Financial Services to correctly assess and understand your personal situation, we will collect information on your financial position, including (but not limited to) information on your investments, savings, debts, tax position, superannuation and insurances.

Government Identifiers means any information provided to us provided from the government, for example your Tax File Number.

When we collect government identifiers, such as your tax file number, we do not use or disclose this information other than as required by law. We will never use a government identifier to identify you.

How do we collect the information?
Stewart Financial Services will collect your personal information directly from you, upon registration or through our training courses and events. Stewart Financial Services may also collect information from you by liaising with our affiliate companies, your references or credit reporting bodies.

We may also receive your personal information indirectly from third party websites that we are affiliated with.

Browser and device data, such as IP address, device type, operating system and internet browser type, device manufacturer and model, language, plug-ins, add-ons.
Usage data, such as the time spent on the sites, pages visited, links clicked and referral websites.
Stewart Financial Services may also indirectly collect information from you about how you like to use the services on our site. We do this through your use of certain programs that inform us of the patterns of use related to our site.

How we use your Personal Data
We may also use your personal information to:
• Compile your personal profile;
• Provide you with current information about our services, special offers, changes to our organisation;
• Inform you of relevant seminars, conventions, new products and services that Stewart Financial Services, or any affiliate companies are offering;
• Understand your financial circumstances to better advise you.
• When you participate in some of our courses, or use some of the features of our site, we may provide this information to our partner organisations to analyse the data. This is to ensure we can better our services to you. We will not disclose any personal information without your consent, however the data collected in surveys may be passed on to third parties. The information will always be de-identified unless we inform you otherwise.
• Other professionals who may need to be engaged in order to implement certain components of my adviser’s business succession advice.

Why do we collect your information?
The information we collect allows us to keep you updated on our latest announcements, services and upcoming events. We also collect your personal information to help us create, develop, operate, deliver and improve our services and content. We want to enhance your user experience by ensuring that we are able to keep up to date with what you want and need.

When we have no ongoing legitimate business need to process your personal information, we will either delete your data, anonymise it, or archive it until it is possible to delete the personal information safely.

We use cloud storage to store personal information that we hold. The cloud storage and the IT servers may be located outside Australia.

 

2. Payment Information

When you make a payment with us online, we collect credit/debit card/ bank account information, purchase amount, date of purchase. The information we collect will be different according to what payment method you adopt. We enlist the help of a third parties, to ensure that all payments made are safe and secure. Please note that arrangements with these third parties are subject to change.

We do our best to ensure information provided to third parties is safe and secure, should you suspect that your information has been misused and/or compromised please contact us so that we may seek to resolve the issue.

3. User’s Rights

We want you to feel in control of your personal information and to make sure you feel comfortable with providing us with your details. Therefore, Stewart Financial Services want you to know your rights and our limitations.

Opting out from receipt of communication from Stewart Financial Services

If you wish to opt out from receiving direct marketing, via email address or phone, you have the right to contact us, in writing, to decline the receipt of such information. We will do our best to promptly respond to the request.

Please note that if you choose to opt out from the mailing list, we will continue to contact you with Administrative or account related messages to ensure we provide our best service.

Consent

When you sign up to our service we are required to obtain your consent in order to access and store your personal information. You are able to withdraw your consent any time by notifying us in writing.

Accessing, updating and sharing your personal information

You have the right to access your personal information at any time. Any requests for access to your personal information should be made to us in writing.

It is important to Stewart Financial Services that our relationship with you is always evolving. Stewart Financial Services expects users to update their personal information so that we can continue to provide you with relevant content through our services.

It will also ensure that, if need be, Stewart Financial Services can verify your identity. Users can request access to their previously disclosed personal information if it necessary that they review, correct or update the information.

Stewart Financial Services will consider each request seriously, and will only deny access or withhold information, if we are permitted to do so by law.

Right to Rectification

You have the right to obtain from us the rectification of inaccurate personal data concerning you and you have the right to provide additional personal data to complete any incomplete personal data, including by means of providing a supplementary statement.

Right to Erase Personal Information

You have the right to request, in writing to Stewart Financial Services, to have your personal data destroyed. This may be, but is not limited to, circumstances where your personal information is no longer required for its permitted purpose, or if you withdraw your consent. If Stewart Financial Services is required to destroy your information, we will ensure that any links, copies or replications of your information are also destroyed.

Please note, Stewart Financial Services reserves the right to not destroy your data or information if it is necessary, in the circumstances, to exercise their right of freedom of expression and information or if it is required in order to maintain Stewart Financial Services compliance requirements.

To affect this right, you can request us to have your data deleted by writing to us.

Data Portability

You have the right to receive your personal data in a transferrable format which can be transmitted to another data controller, if it is necessary to do so.

This right can only be accessed for information that has been provided to Stewart Financial Services, if the individual provides consent or if it is permitted for the performance of a contract through automated means. We will aim to provide you with your data within 30 days of receiving your request.

Restriction of Processing

You have the right to restrict the processing of data in certain circumstances which may include a temporary restriction if a user contests the accuracy of their personal data. This will allow Stewart Financial Services to verify the data and update the information if necessary.

Unfortunately, no data storage or processing system can be 100% secure. If at any time you feel that the security of your account or personal data is being threatened, or no longer secure, please contact us immediately.

Right to Object

You have the right to object at any time to processing of personal data concerning yourself with regards to profiling.

You also have the right to object at any time to processing of personal data concerning yourself where personal data are processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing.

Complaints:

Our goal is to ensure that your information is kept safe, that being said, If you are unhappy with how we have handled your personal information, you have the right to file a complaint and let us know. You may contact our complaints officer by contacting us in writing.

We will acknowledge your complaint within seven days. We aim to provide you with a decision on your complaint within 30 days

4. International Data Transfers

As we operate within Australia and we serve users across the world and deliver our services through the use of Third Party processors, we may transfer personal information to countries other than the country in which the data was originally collected.

5. Third Party Disclosure

Stewart Financial Services works with numerous individuals and organisations to tailor make programs to suit our user’s needs. We will at times disclose information to these parties for the purposes of collecting data to ensure that we can better the products and services which we provide to our users.

Where possible, we will inform you, at or before the time of collecting your personal information, the types of organisations that we intend to disclose your personal information to. You have the right to object at any time to stop the processing of your data. This only applies to certain types of processing such as for when it is for a legitimate business purpose, or for direct marketing (including profiling).

We do not share any personal information with companies, organisation and individuals outside of Stewart Financial Services unless one of the following circumstances apply:
• To anybody who provides a service to Stewart Financial Services who contributes to their ability to operate their business effectively such as third parties who provide Stewart Financial Services administrative, banking, financial, insurance, tax or legal services.
• You provide us with your express consent – we will always ask you before we share any of your information
• For legal reasons – we will share your personal information with any company, organisation or individual if it is necessary to:

  • Meet any applicable law, regulation, legal process or enforceable governmental request;
  • Enforce applicable terms of service, including investigations of potential user breaches of our terms;
  • Detect, prevent or otherwise address fraud, security or technical issues;
  • Protect against harm to the rights, property or safety of Stewart Financial Services, our users, or the public as required or permitted by law.

• To confirm your identity, such as when you contact us with an inquiry;
• To conduct research about our training programs; and
• For other everyday business purposes that involve collecting data and information from our users for the purpose of improving our services to Stewart Financial Service users.
Stewart Financial Services attempts to do everything possible to protect our users from unauthorised access or unauthorised alteration, disclosure or destruction of information we hold.
We implement the following services to ensure that our user’s information remains private and confidential pursuant to our terms:
• Identity Verification processes.
• Data is securely stored on our servers, protected by passwords and only accessible by authorised personnel;
• We do not hold your credit card details, they are held by an external third party. The only circumstance where we may hold your credit card details is when we receive this information on direct debit request forms.

6. Data Breach Notifications

If Stewart Financial Services becomes known of a data breach, we will provide a Statement to the Commissioner notifying of the occurrence of the breach. If the breach is likely to result in serious harm or risk to a user’s rights and freedoms, the effected users will be notified as soon practicable.

7. Changes to the Privacy Policy

Occasionally, we may, in our discretion, make changes to this policy in accordance with applicable laws and regulations. If we make any changes to this policy, you will receive prominent notice appropriate to the circumstances. Your continued use of our services will constitute as acceptance of those changes.