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Privacy Policy

Stewart Private Accounting Policy (accessed 13/11/2019)

 

Any information contained in this website is of a general nature only, does not take into account your personal circumstances, and should not be relied upon as a basis for making any financial decisions. Before making any decisions, you should seek appropriate advice specific to your circumstances. By accessing and/or using information at or through this website, each user waives and releases Stewart Private Accounting to the full extent permitted by law from any and all claims relating to the usage of the material made available through the website.

Wealthcierge Pty Ltd T/as Stewart Private Accounting

 

ABN: 91 635 904 013

 

Stewart Private Accounting

 

Respecting your privacy and the law

The privacy of your personal information has always been important to us at Stewart Private Accounting. We are committed to respecting your right to privacy and protecting your personal information. We adhere to the Australian Privacy Principles and any applicable laws and codes affecting your personal information. Our staff are trained to respect your privacy in accordance with the law and our standards, policies and procedures.

We may also need to share your information with third parties, such as financial product providers. Also it is a Stewart Private Accounting policy to use any information gathered to identify and make available to you other broadly related financial services. This enables Stewart Private Accounting to have an integrated view of you, our client.

 

You have the right to request us in writing that your personal information not be provided to other parties, however, that may mean that it is not possible to provide you with the products and services that you have requested. Where this is the case we will inform you in writing.

 

About this Privacy Policy

 

This Privacy Policy outlines how we manage your personal information, including the purposes for which your personal information is held and how that information is collected, used and disclosed.

Our Privacy Policy applies to all your dealings with us whether at one of our branches, through our offices, via our websites or an adviser. However, further privacy information may apply in addition to the matters discussed in this Privacy Policy.

We encourage you to check our websites regularly for any updates to our Privacy Policy.

 

Collecting your personal information

When you visit the Site, we may automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. We use cookies to ensure that we give you the best experience on our website. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually. If you continue to use this site we will assume you are happy with it. Additionally, as you browse the Site, we may collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

 

We may collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, go here. When you log into the client section of our site we may use cookies to identify who you are while you are logged in for the session. The cookie is unique to that session and the data within the cookie is encrypted. You must have cookies enabled to be able to use our site and gain the best experience from it.

• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, when you fill out the contact form on our Site, we may collect certain information from you, including your name, email address, phone number, and company name. We refer to this information as “Contact Information.”

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Contact Information.

Stewart Private Accounting can collect and hold your personal information for the purposes of:

• Providing you with the relevant service (including assessing your application and identifying you);

• Managing and administering the service we provide to you;

• Providing you with the best experience; and

• We may also collect your personal information for the purpose of promoting and marketing products or services that might be of interest to you.

We may collect your personal information when you fill out product or service documentation, an administrative form, or when you give us personal information over the telephone, or through Stewart Private Accounting website.

We may also collect your personal information from third parties such as your employer, or a representative such as a legal adviser or accountant or publicly available sources of information.

 

The type of personal information we collect and hold

Personal information held by Stewart Private Accounting may include identification information such as your name, address, phone numbers, email addresses, tax file number etc. Depending on the type of service or product you require or choose, we may also ask you for other personal information including:

• Employment information;

• Marital status, and family information or circumstances;

• Financial information such as your superannuation and other investment details;

• Business interests and trust structures;

• Your insurance, credit, financial and bankruptcy history;

• Date of birth, Gender, Past times, hobbies, family history;

• Details regarding any circumstances or assets you wish to insure; and

• Other personal information details which are needed depending on the type of financial product or service you require.

 

Your sensitive information

The collection of sensitive information is restricted by the Privacy Act. This includes information such as your racial or ethnic origin, political opinions, association memberships and details of health, disability etc.

This type of information is only collected with your consent and where required to provide you with the products, services or assistance you may require and the collection of this information is needed to provide these.

 

How will we collect your personal information

We collect your personal information:

• Directly from you when you provide information by phone, in person or in documents;

• From third parties including any related firms as listed;

• From publicly available sources of information;

• When required to do so by Federal or State legislation;

• The organisations identified within this document;

Security of your information

We hold your personal information in:

• Our computer systems and electronic databases;

• Digital records; and

• In hard copy or paper files.

We protect your personal information by:

• Our computer systems and electronic databases;

• Digital records and

• In hard copy or paper files.

• Stand by systems and system backups to deal with any business interruptions;

• Limiting physical access to our offices and premises;

• Limiting physical and electronic access to your personal information and our systems;

• Requiring all third party providers to have acceptable security measures and privacy practices / policy in place which meet ours and the Australian Privacy Act requirements;

• Maintaining technical security product to protect your personal data and

• Destroying or de identifying personal data and information pursuant to the law once such data is no longer required to be maintained by us.

• Staff training and through employment agreements and electronic user identifiers and passwords.

In addition, Stewart Private Accounting maintains industry standards in relation to its technology and procedures with respects to management of information and its online services.

 

Using and disclosing your personal information

We use the Contact Information that we collect generally to fulfil any transactions placed through the Site. Additionally, we use this Contact Information to:

• Communicate with you;

• Screen for potential risk or fraud; and

• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

• We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

Further, in order for Stewart Private Accounting to meet your specific needs it may need to disclose your personal information to the type of firms, organisations and government bodies described below. Where your personal information is disclosed we will seek to ensure that the information is held, used or disclosed consistently with the Australian Privacy Principles and any State Legislation and other applicable privacy laws and codes.

 

The relevant organisations are those:

• Involved in providing, managing or administering your product or service including

o Banking and finance organisations;

o Financial Planning service providers

o Trustee or custodial services

o Life or General insurance providers

• Who may wish to promote and market products or services that might be of interest to you;

• Who are external advisers and their service providers;

• Involved in maintaining, reviewing and developing our business systems, procedures and infrastructure;

• Involved in a transfer of all or part of the assets or business associated with or related to Stewart Private Accounting;

• Involved in the payments system including financial institutions, merchants and payment organisations;

• Involved in a service or product planning and development;

• Which are your representatives including your legal advisers and accountants;

• As required or authorised by law;

• Where you have given your consent;

• Departments and agencies of the Australian government or of any State Territory government, where relevant to your business or taxation affairs, including the ATO, ASIC and State Revenue Office.

 

Other use and disclosure around sharing your personal information:

If your personal information is subject to Australian Privacy Principles, we only will use and disclose your personal information for a secondary purpose if it is related to the primary purpose for which we collected it and where you would reasonably expect us to use or disclose your information for that secondary purpose. In the case of sensitive information, we will only use this information for the secondary purposes if it is directly related to the purpose of collection or where we are required or authorised by law to disclose your personal information and sensitive information. For example, to a Court in response to a subpoena or to the Australian Taxation Office, Centrelink or to the Australian Transaction Reports and Analysis Centre (AUSTRAC).

Further, Stewart Private Accounting may share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.

 

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful requests for information we receive, or to otherwise protect our rights.

Use and disclosure of personal information for marketing

Stewart Private Accounting is able to assist you in providing a large range of financial services, products and advice. An important part of our service to you is marketing, by being able to keep you up to date with new products and services which we think may be of benefit and interest to you.

In bringing this information to you, we use a large range of communication tools including mail, telephone, email and other internet based tools as well as direct and Stewart Private Accounting presentations. Third party marketing service providers may combine the personal information we disclosed to them with information they already hold about you, to provide you with more relevant advertising about the products and services we can provide you.

As described above, we may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page here.

You can opt out of targeted advertising by visiting respective sites, for example:

• Facebook

• Google

• Bing

 Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal here.

 

Keeping your personal information accurate and up-to-date

We aim to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. We will take reasonable steps to make sure this is the case. This way we can provide you with better service. If you believe your personal information is not accurate, complete or up to date, please contact us.

Protecting your personal information

We store information in different ways including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, loss unauthorised access, modification or disclosure.

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Our Website/s

 

We take care to ensure that the personal information you give us on our website/s is protected.

For example, our website/s have electronic security systems in place, including the use of firewalls and data encryption. User identifiers, passwords or other access codes may also be used to control access to your personal information where necessary.

Please refer to the website/s associated with Stewart Private Accounting, if any, with which you transact electronically for more information on our website specific privacy and security procedures.

 

Links to other sites

You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy standards, policies and procedures.

 

Overseas Service Providers and disclosure

Stewart Private Accounting, when necessary, may disclose personal information to organisations, persons and contractors overseas. Instances when we will do this include:

• When we are authorised or required by an Australian law or a court/tribunal to do so;

• When we have engaged an overseas service provider to deliver services central to our financial service business operations.

• When a contractor that we engage stores data offshore, e.g. a cloud-based service.

Your personal information will only be disclosed to the extent it is necessary to perform our functions or activities.

These external service providers to whom your data may be provided are for Stewart Private Accounting client service management system and the service providers for this are located in Vietnam. This external overseas service provider provides computer system, computer code support and service to Stewart Private Accounting. Also, our internal document management system is supported by a service provider located both within Australia and overseas in Vietnam.

 

Data Retention and Gaining access to your personal and contact information

You can gain access to the underlying personal information and data Stewart Private Accounting holds in relation to you. You can also ask for corrections to be made. If you would like to request access to your personal information we hold about you please contact us.

There are some circumstances where we are not required to give you access to your personal information. If we refuse your request we will give you reasons if we deny access.

Our response to your request could take up to 30 days from the receipt of your request. If we require further time we will write to you and advise you of the reason for the further time required. If such request incurs a fee, we will advise you of this.

When you fill out the contact form in our Site, we will maintain your Contact Information for our records unless and until you ask us to delete this information.

 

Correction of personal information

You also have the right to request that we correct any inaccurate, out of date, incomplete, irrelevant or misleading personal information we may hold. We will take such steps that are reasonable to make any correction required. If we refuse to change or correct your personal information we will provide reasons for the refusal in writing to you. If we refuse to correct or change any personal information, you have a right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take any steps that are reasonable to associate that statement with all the records containing that relevant information.

 

Using Government identifiers

In certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number. We do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.

 

Dealing with us anonymously or through the use of pseudonyms

You have the option of not identifying yourself and dealing with us anonymously or through the use of a pseudonym, where it is lawful and practicable to do so. We cannot disclose client information to any person other than the client or someone who is properly authorised by the client to receive the information. If we cannot properly identify the person(s) concerned, we may not be able to disclose the relevant information.

Resolving your privacy issues

You have the option of not identifying yourself and dealing with us anonymously or through the use of a pseudonym, where it is lawful and practicable to do so.

 

• You are always welcome to speak directly to our staff and they will do their best to resolve your issue. Alternatively, you can email your issue to support@stewartprivate.com.au, write to us directly or contact us by phone. If investigation is required we will keep you advised of progress.

• If our staff are unable to resolve the matter it will be escalated to an appropriate Senior Manager of Stewart Private Accounting.

• If we are unable to resolve your issue or complaint immediately a response will usually be provided to you within 5 business days. At Stewart Private Accounting we aim to resolve all client complaints the same day where possible. Where this cannot be accomplished we will endeavour to resolve the client complaint within 45 days. However, this may not always be practicable.

• If Stewart Private Accounting is unable to resolve the compliant we will advise you in writing.