Our privacy commitment to you
In this policy ‘we’ or ‘us’ means Hunt Strategic Advisors Pty Ltd (ABN 99 615 095 639), Hunt Strategic Capital Pty Ltd (ABN 12 615 100 859), Hunt Strategic Nominees (ACN 619 441 039) and other entities within our businesses.
This policy does not apply to the personal information we collect and hold about our employees.
Types of personal information we may collect about you
We will only ask for personal information that is relevant to our relationship with you and if it is reasonably necessary for one or more of our functions or activities. We may ask you for your:
- Name, address, telephone number, email and other contact details
- Date of birth, place of birth, gender and marital status
- Financial and investment information including shareholdings, debts or debts owed and bank account details
- Government identifiers including your tax file number
- Superannuation and insurance information
- Your opinion about our services and our people
How we collect personal information from you and from others
We will usually collect personal information directly from you. For example, we collect personal information directly from you via documents and materials you provide to us and from mail and electronic communications with you.
Sometimes we may collect information about you from someone else. For example, from someone acting on your behalf or your representatives (such as financial advisers, accountants, and solicitors), your employer (if they are our client), your insurers or brokers, publicly available sources (such as publications and online profiles), referees, referrers or other intermediaries.
The purposes for which we collect your personal information
We collect retain, use and disclose your personal information to enable us to provide our services, to respond to your inquiries and to comply with the law. Some of the purposes for which we use your personal information are to:
- provide professional services to you or to other clients
- communicate with you, including responding to your inquiries and feedback, keeping you informed of news and events, and sending you industry publications and other material that we think may be of interest to you
- develop and provide system and technology solutions for you
- conduct client satisfaction feedback activities
- conduct administration activities
- manage our conflict of interest and independence obligations
- to comply with legislative and regulatory requirements including under the Corporations Act, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and taxation and employment laws
- marketing purposes (see the section below titled ‘ Marketing our services to you’)
Dealing with us anonymously or using a pseudonym
We prefer to know our clients’ identities and do not wish to deal with people on an anonymous basis or those who use pseudonyms.
You may decide not to provide us with your personal information we ask for. However if you do so, or if you provide us with personal information that is inaccurate or incomplete, we may not be able to respond adequately to your inquiries or provide you with the services you or our other clients require.
When and to whom we may disclose personal information
Depending on the nature of your relationship with us, for the purposes listed in the section above we may provide your personal information to:
- Our professional advisers and specialist consultants
- Brokers and agents who refer your business to us
- Any person acting on your behalf, such as your financial advisor, solicitor, settlement agent or administrator
- Vendors and other third parties who provide services to us, including data processing, audit and quality review activities
- Agents who assist us to dispose of property or equipment
- Investors, advisers, and trustees
- Professional associations and organisations
- Industry regulators, government agencies or courts and tribunals
- Other professional firms in Australia or abroad with whom we have a relationship.
The entities described above to whom we may disclose your personal information may be located overseas, including China, Europe, India, New Zealand, Singapore, United Kingdom and the United States of America. We will take reasonable steps to ensure that these overseas recipients maintain the same high standards of protection of your personal information that we do, and that they comply with the requirements of the Australian Privacy Principles.
Disclosure required by law
We may be required to disclose your personal information by law e.g. under Court Orders or Statutory Notices, or under laws relating to sanctions, anti-money laundering or counter terrorism financing, corporations law, taxation and employment or where we are appointed to administer companies under the Corporations Act.
Marketing our services to you
From time to time we may also use and disclose your personal information to inform you about other services and products we provide or that other companies offer which we think may be of interest to you. If at any time you do not wish to receive direct marketing communications from us you may:
- use the opt-out link provided on direct marketing related material, or
- telephone us
Accessing and correcting your personal information
We take reasonable steps to make sure that your personal information is accurate, complete and up to-date. You may request access to and correction of your personal information by contacting us by phone or in writing. We may need to verify your identity to deal with your request and we will endeavor to deal with your request within a reasonable timeframe. In some circumstances we may not be able to give you access to all of the personal information we hold about you, as authorised under the Australian Privacy Principles.
If you request us to correct, update or delete any personal information that we hold about you, for example if you think it is inaccurate, incomplete, or out of date we will take all reasonable steps to correct or delete the information. If we decide not to correct the information, you can ask us to include with the information a statement that the information is not correct.
If we cannot grant you access to your personal information, or we cannot agree as to correct or delete it, we will confirm our reasons in writing, unless it would be unreasonable to do so. If you do not agree with our decision you may ask us to review the decision via our complaint handling procedures which we will explain to you.
How we handle complaints
If you believe we have not complied with our privacy obligations you can submit a complaint to us in writing by either of the following methods:
- Emailing the Managing Director at email@example.com
- Mailing the Managing Director, David Hunt, at GPO Box 5359 Sydney NSW 2001.
We will respond to your complaint as soon as reasonably practicable after receipt of your written complaint. We will need to verify your identity and we may need to ask you for further information. If you do not agree with our decision or the way we have handled your complaint you can refer your complaint to the Office of the Australian Information Commissioner.
How we store your personal information
We hold personal information in both electronic and hardcopy formats. We will take reasonable steps to protect the security of personal information. We have document management and retention policies and processes in place, and we employ physical controls such as swipe card access to our buildings and office. Our electronic records are protected by a range of security measures, for example, firewalls, passwords, virus scanning software, and data encryption.
Priavcy on our website and applications
This policy also applies to any personal information we collect via our website, including huntstrategicadvisors.com.au, and applications including mobile applications, in addition to personal information you provide to us directly – such as where you make a request or complete a registration form.
Generally, you should be aware that the internet is not a secure environment. We cannot protect personal information before it reaches us. We maintain physical, electronic and procedural safeguards to protect any personal information once we receive it.
“Cookies” are data files (of letters and numbers) that we store within your browser and the hard drive of your computer, if you to agree to us doing so, when you interact with our website. These data files allow us to recall important information about your visit to our website and help to improve your experience if you return.
When you visit our website, our servers collect your log information such as the pages visited, the date and time of your visit, your web browser (eg Internet Explorer or Safari) and device type and the IP address associated with your request. We also collect referring and onward URLs of websites you have visited or will visit; data about the activities you undertake and how you interact with us online, such as what data is displayed, clicked on or shared by you, the click stream patterns, and the length of time you spend on our site or page. We use this information to help us manage and improve our website and for tracking and marketing purposes.
- enhance your access to and the functionality of our website and user experience – we are able to make it easier
for visitors to register for accounts
- show you ads on other websites and social media platforms based on your interests or browsing history
- highlight specific content that you may be interested in based on your previous visits.
The types of cookies we use are:
– Strictly necessary cookies: these are cookies that are required for the operation of our website. Without them, for example, you would not be able to register with us or log in to your account.
– Analytical/performance cookies: these cookies allow us to recognise and count the number of visitors and to see how visitors move around our websites. These helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily and do not encounter technical errors.
– Functionality cookies: these are used to recognize you when you return to our website. Use of these cookies enables us to personalize our content for you and remember your preferences, highlighting relevant content based on the pages you have visited on our website (for example, a cookie can be used to pre populate forms to present relevant information to you based on your interests).
– Targeting cookies: these cookies record your visit to our website, the pages you have visited and the links you have followed. Use of these cookies of this character helps us and our Ad partners to deliver ads or messages that are relevant to you and your interests. We may also share this information with third parties for this purpose.
– Interaction cookies: these cookies allow us to communicate. For example, these cookies allow you to “like” us or recommend us on social media. These social media interaction cookies may collect information about your visit even though you do not interact with them.