Privacy Policy

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy (Policy) sets out how and why Empower Due Diligence Pty Ltd trading as SuitabilityHub ACN 650 236 561 (“SuitabilityHub”, “we” or “us”) collects, stores, uses and discloses your personal information, and how you may access your personal information held by us.

If you are accessing our services, website or platform on behalf of another person or legal entity, you represent and acknowledge that you have the authority to bind that person or legal entity and its affiliates, in which case references to “you” and “your” in this Policy shall also be a reference to such person, entity and its affiliates.

We collect a variety of information from visitors to our website and users of our platform, some of which may be confidential. This Policy, among other things, explains the types of information we collect and what we do with that information. By visiting our website, using our platform or any of our other services or otherwise providing us with your personal information (or authorising that it be provided to us by a third party), you agree to your personal information being handled in accordance with this Policy.

We may revise this Policy from time to time so please review it periodically for changes. Your continued use of our website, platform or services, any request for our assistance or your provision of further personal information to us (directly or via an authorised third party) after this Policy has been revised will constitute your acceptance of the revised Policy.

WHY WE COLLECT PERSONAL INFORMATION

We collect personal information where it is reasonably necessary for a business purpose, including in order to supply our services and to or help us improve our services, or to comply with our legal obligations. Personal information includes information or opinions you, or from which you can reasonably be identified, such as your name, address, date of birth, employment details, qualifications and contact details.

By disclosing personal information to us, you warrant that:

  • you have obtained any necessary consent to make such disclosure;

  • such disclosure does not breach Australian privacy legislation (as amended from time to time); and

  • such disclosure does not breach of any obligation of confidentiality to which you are subject.

We will not be liable for your breach of Australian privacy legislation or any confidentiality obligations to which you are subject.

THE KINDS OF INFORMATION WE COLLECT

Personal and sensitive information

We collect personal information that is necessary to assist us in providing our website, platform and services, and so that you may receive the benefit of those things. We collect personal information from and about financial product providers, financial advisers (including any of their clients) and other financial service providers, including but not limited to names, phone numbers, addresses, email addresses, ages, and genders.

We collect personal information in a number of ways, including:

  • User-provided information: When you engage with our services, you may provide, and we may collect, personal information. Examples of such engagement include when you sign up for a subscription to our platform, when you contact us for service-related requests, and when you complete our surveys.

  • Automatically collected information: When you use our services, we may automatically record certain information from your device (such as your computer, mobile phone or tablet) by using various types of technology, including cookies, pixels and web beacons. This information may include (but may not be limited to) the IP address or other device address or ID, information about your web browser and/or type of device, the web pages visited just before or just after using our services, the webpages or other content viewed or interacted with, and the dates and times of your visit, access, or use of services. We may also use these technologies to collect information regarding your individual interactions with our services (for example, to confirm whether an email is opened or forwarded), and to collect data on how successful our advertising is and the performance of our advertising partners. We gather these kinds of information from all individuals who interact with our website, platform and services.

  • Information from other sources: We may obtain personal information from third parties and other publicly available sources, such as our partners, regulators and advertisers. If we combine or associate information from other sources with personal information directly collected through our services, we will treat the combined information as personal information in accordance with this Policy.

We do not generally collect sensitive information, however the personal information we receive from and/or about you may include some ‘sensitive information’ (being information or opinions about your health, political affiliations, sexual preferences, religious beliefs, racial or ethnic origin, memberships in trade or professional associations or trade unions, criminal record and biometrics). If we do collect sensitive information, we do so only where it is necessary for the purpose for which it is being collected and with your consent.

You may refuse to provide personal information to us, however doing so will limit your ability to engage with our website, platform and services.

General information

We also collect general information that is not personal to you. This type of information generally relates to your behaviour on our website and/or platform, and includes but is not limited to the type of browser you use, your geographic location, and how you came to visit the website and/or platform. It also includes information that will help us troubleshoot problems, analyse our resources and improve our services.

UNSOLICITED INFORMATION

If we receive personal information that we have not requested (unsolicited personal information), within a reasonable period after receiving it we will determine whether or not we could have collected it if we had sought it. If so, we will treat it in accordance with this Policy. If we could not have collected it, if it is lawful and reasonable to do so we will, as soon as practicable, destroy it or ensure that it is de-identified.

HOW WE USE YOUR PERSONAL INFORMATION

Subject to this Policy, we may use your personal information:

  • to verify your identity and credentials;

  • to establish, maintain and administer your account;

  • to tailor the content and information that is shown to you on our website and platform;

  • to contact you, including to send you service or promotional communications, and offers to participate in our market research surveys;

  • to create and/or distribute advertising or marketing material that is relevant to you;

  • to aggregate with other users or members for the purposes of industry reports or information services;  

  • to otherwise provide you with our services; and

  • for any other uses identified at the time of collecting your personal information.

From time to time we may also use your personal information to identify particular services that we offer that we believe may be of interest to you, and contact you to discuss those services and how they may benefit you. This kind of direct marketing will generally (but not always) take the form of an email. We will always give you a choice to opt out of receiving further marketing information.

You consent to us using your personal information in any manner reasonably contemplated by this Policy, and the terms and conditions of our website, platform and services generally. Where relevant, you also consent to us using any photographs, personal information and other information you upload to our website, platform or social media pages, otherwise provide to us, or that we lawfully collect in some other way, for our business purposes and activities.

WHEN WE MIGHT DISCLOSE YOUR PERSONAL INFORMATION

Any personal information collected by us may also be disclosed, if appropriate, to other entities in order to facilitate the purpose for which the information was collected. Such entities may include:

  • third party ‘partners’ with whom we have a commercial relationship, in order to provide you with the benefit of our services or to make available products or opportunities provided by such third parties that are considered relevant or likely to be of interest to you;

  • third party service providers for the purpose of enabling them to provide a service to us or on our behalf such as (but not limited to) IT service providers, data storage providers, web-hosting and server providers and debt collectors;

  • any related entity of SuitabilityHub;

  • any applicable or relevant regulator or third party for the purpose of legislative or contractual compliance and/or reporting; or

  • other entities where you have given your express consent.

In addition, if at any time we are required to take payment from you, some of your personal information may be provided to a third-party payment processor for the completion of that transaction.

From time to time, these parties may reside outside Australia. Our contracts with these parties generally include an obligation for them to comply with Australian privacy legislation and this Policy. However, by agreeing to the disclosure of your personal information to these entities outside of Australia, you acknowledge that we will no longer be required to take reasonable steps to ensure the recipient’s compliance with Australian privacy legislation in relation to your personal information and we will not be liable for any breach of Australian privacy legislation by the recipient.

PERSONAL INFORMATION ABOUT EMPLOYEES OR JOB APPLICANTS

We will collect personal information from you if you apply for a job with and/or become employed by us. In these circumstances:

  • You authorise us to collect any personal information (whether written or verbal) from any referee or previous employer specified in your application for employment or curriculum vitae for our evaluation of your application, and to hold such information on your personal file for future evaluation of your employment; and

  • You acknowledge that your personal information is collected for the purpose of evaluating your application for employment by us and, should you accept employment with us, the assessment and administration of your continued employment.

A failure by you to provide requested personal information in these circumstances will limit our ability to give your application proper consideration.

DEALING WITH US ANONYMOUSLY OR BY PSEUDONYM

Our provision of services to you (including the platform) will not generally be possible without your provision of relevant personal information. However, where it is lawful and practicable to do so, you may deal with us anonymously or by using a pseudonym.

LINKS TO THIRD PARTY WEBSITES

Our website may contain links to the websites of third parties. If you click on those links, you will be transferred to a third party website. We have no control over, and are not responsible for, the privacy practices of those third parties.

ACCESSING YOUR PERSONAL INFORMATION

You may request to access personal information we hold about you at any time. Such request may be refused on certain grounds including, for example, because such access would be unlawful or have an unreasonable impact upon the privacy of other individuals, or because your request is frivolous or vexatious. Where your request to access the personal information we hold about you is refused, we will provide you with written reasons for doing so.

We do not generally charge for requests to access personal information, however where your enquiry is complex or resource intensive, a handling fee may apply. We will advise you of any fee that becomes payable before processing your request.

We take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up-to-date. However, we also rely on you to advise us of any changes to your personal information. Please let us know as soon as possible where there are any changes to your personal information, or if you believe the personal information we hold about you is not accurate, complete or up-to-date, so that we can update our records accordingly. You can update your profile information on our platform, including your contact details, via the platform at any time.

If you wish to access the personal information we hold about you or request a correction of it, our Privacy Officer can be contacted via the details set out below.

STORAGE AND SECURITY

The information we hold about you is stored in a secure electronic third-party database.

We will use reasonable endeavours to protect and maintain the security of your personal information and to make our website and platform secure against misuse, interference, loss and unauthorised access. However, despite our reasonable endeavours, we are unable to ensure or warrant the security of any information held by us. All personal information disclosed by you is at your own risk.

When your personal information is no longer needed for any purpose for which it was collected, used or disclosed, it will be destroyed or permanently de-identified, subject to our usual document retention and disposal practice.

CHANGES TO THIS POLICY

We may change this Policy from time to time, as required. The current version of this Policy will be available on our website at all times. This Policy was last updated in August 2022.

ENQUIRIES AND COMPLAINTS

If you believe that we have breached your privacy rights in any way or you would like to discuss any part of this Policy, please contact our Privacy Officer via the details set out below.

If you wish to make a complaint about a breach of this Policy or Australian privacy legislation, you can contact us via the details set out below. You will need to provide us with sufficient detail of your complaint as well as any supporting evidence. Our Privacy Officer will investigate your complaint and determine the steps, if any, that we will undertake to resolve your complaint. We will contact you if we require any additional information about your complaint, and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us via the details set out below to discuss your concerns or contact the Australian Privacy Commissioner.

CONTACT US

Please contact us via the details set out below if you want to:

  • access your personal information held by us;

  • correct or update your personal information held by us;

  • obtain further information about the way we manage your personal information; 

  • raise a concern or make a complaint regarding how we collect or handle your personal information;

  • unsubscribe from our mailing list; or

  • ask a question about an unsolicited electronic communication that you have received.

Please contact us immediately via the details set out below if you become aware of any unauthorised use of your account for the platform, or any other breach of security.

Contact Details

Attention: Privacy Officer

Empower Due Diligence Pty Ltd trading as SuitabilityHub (ACN 650 236 561)

Postal Address: 

Privacy Officer c/o SuitabilityHub

WeWork, Level 2, 383 George Street 

Sydney NSW 2000

Contact Email: Privacy@SuitabilityHub.com

Contact Phone: 0410 797 007

FURTHER INFORMATION ON PRIVACY

For general information regarding privacy in Australia, please visit the website of the Office of the Australian Information Commissioner.