We are committed to ensuring your personal information is protected. We manage your personal information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act).
1. What is “personal information”?
(a) The Privacy Act 1988 (Cth) currently defines “personal information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
2. What information do we collect?
The kind of personal information that we collect from you will depend on how you use the website. The personal information which we collect and hold about you may include:
(a) contact details (for example, full name, address, date of birth, email address, details relating to your age, gender and marital status);
(b) information relating to your dealings, or enquiries you have made, with us, including information about the Services you have ordered on, or via the website;
(c) payment and billing information;
(d) information regarding your access and use of our website, including location information, IP address, products you viewed or searched for, length of visits to certain pages, page interaction information, methods used to browse away from the page and any third party websites you access;
(e) information relating to your account on our website, including your username and password;
(f) information relating to your estate planning requirements and financial circumstances, including your assets and details of persons who are involved in your estate; and
(g) other information that you provide to us or that we may collect in the course of our relationship with you.
We do not intend to collect your Sensitive Information (as defined by the Privacy Act). However, some of our services are automated and we may not recognise that you have accidentally provided us with sensitive information. If you have accidentally sent us Sensitive Information, please contact us using the details below.
3. How we collect your personal information
(a) We may collect personal information from you whenever you input such information into the website. This may include where you:
- set up or update an account or other registration on our website;
- visit, access and use the customer portal on the website;
- use or access our Services, including when you use any technical support services that are provided by us or our contractors, agents or affiliates;
- submit an enquiry to us via our support system;
- participate in our surveys, competitions, promotions, questionnaires or other promotional activities or complete any forms or documents for our products or services or subscribe to our publications, alerts and newsletters; or
- interact or communicate with us, such as by telephone, email or in person or make a comment on our social media sites
4. Collection about others
(a) If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:
- inform them that you are providing their Personal Information to us; and
- advise them that they can contact us for further information.
(c) Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.
5. How we use your personal information
(a) We only use, process and disclose your Personal Information for the purposes for which it is collected.
(b) In particular, we use, process and disclose your Personal Information to:
- provide you with our Services;
- improve, develop and manage our Services, and to assist us in providing a better service to you;
- operate, maintain, test and upgrade the customer portal and business systems;
- notify you of opportunities we think you might be interested in, including new product or service offerings, competitions, promotions, events and surveys;
- verify your identity;
- conduct fraud, risk reduction and creditworthiness checks;
- perform research and analysis about our Services, including usage patterns, trends, benchmarking and other statistical or behavioural data. Before we use your Personal Information for this purpose, we ensure Personal Information is made anonymous by removing data that can identify you;
- advise your executors that you have appointed them as executors of your estate or after you pass away to assist them with applying for probate;
- advise specific charities, in circumstances where you have chosen to bequeath assets from your estate to them, for the purpose of contacting you or your executors;
- seek advice from external business advisors, such as auditors, lawyers (including the lawyers of your estate to assist them to apply for probate), insurers and financiers.
- comply with regulatory or other legal requirements,
- for any purpose to which you have consented; and
- for any other purpose notified to you at the time of collection.
(c) We customarily disclose personal information only to our service providers, agents, contractors and affiliates who assist us in operating the website and delivering our Services to you. Your personal information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
(d) In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your personal information as part of the transaction, without your consent or notice to you.
6. Payment Processor
We use the Stripe payment system to process credit card payments. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any Personal Information or payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processor, Stripe. Before making a payment via the Stripe system, you should review Stripe’s privacy and security policies. We are not responsible for Stripe’s privacy and security policies. For more information about Stripe visit www.stripe.com/au/privacy
7. Other websites
Whilst our website contains links to other websites, we are not responsible for the privacy practices or the content of such websites.
8. Access and correction
Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.
9. Complaint procedure
If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by management and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
10. Overseas transfer
Your personal information may be transferred overseas or stored overseas for a variety of reasons. It is not possible to identify each and every country to which your personal information may be sent. If your personal information is sent to a recipient in a country with data protection laws which are at least substantially similar to the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your personal information under that overseas law, we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled in that jurisdiction. If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia’s, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles.
In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. The fact that you may be located in Europe does not, however, on its own entitle you to protection under the GDPR. Our website does not specifically target customers located in the European Union and we do not monitor the behavior of individuals in the European Union, and accordingly the GDPR does not apply.
12. Storage and security
(a) We take reasonable steps in the circumstances to keep your Personal Information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your personal information, including use of Secure Sockets Layer (SSL) which is an encryption technology used to protect data as it travels over the internet.
(b) Our officers, contractors, employees, agents and affiliates are expected to observe the confidentiality of your Personal Information.
(c) Wherever possible, we procure that the above mentioned who have access to your Personal Information take reasonable steps to:
- protect and maintain the security of your Personal Information; and
- comply with the relevant APPs when accessing and using your Personal Information.
(d) The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information, we cannot guarantee the security of any Personal Information transmitted through our website.
(e) You provide your Personal Information to us at your own risk and we are not responsible for any unauthorised access to, and disclosure of, your Personal Information.
13. Direct Marketing
(a) We may use and disclose your Personal Information to send you information about the Services we offer, as well as other information that may be of interest to you.
(b) We may send this information to you via the communication channels specified at the time you provide your consent.
(c) These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying advertising on our website.
(d) If you do not wish to receive any of these marketing communications, you can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us using the contact details set out below.
14. Changes to this policy
15. How to contact us about privacy
If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us at: email@example.com or on a phone number published on our website from time to time.