privacy policy
HW One Pty Ltd (HW One) is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au.
1. Personal and Sensitive Information
1.1 Purposes for which HW One collects personal information
We collect your personal information for the primary purpose of providing our services to you and marketing. We may also use your personal information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.When we collect personal information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
1.2 Personal information
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect can include details such as:
- Names, employment titles, contact details;
- Date of birth and gender;
- Information in identification documents (eg. passport, driver's licence);
- Tax file numbers and other government related identifiers;
- Assets and liabilities;
- Educational qualifications and employment history;
- Personal income;
- Visa and work permit status;
- Bank account details;
- Shareholdings and details of investments;
- Superannuation details;
- Tax and financial statements;
- Information regarding insurance;
- Personal information about your spouse and dependents.
- Purposes for which HW One collects sensitive information
It may be necessary for HW One to collect sensitive information about you in order to provide specific services. Sensitive information will be used by us only for the primary purposes for which it was obtained, for a secondary purpose that is directly related to the primary purpose and with your consent where required or authorised by law.
1.3 Sensitive information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
1.4 Refusal to provide personal information
You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information or request the use of anonymity or a pseudonym we may be unable to complete or fulfil the purpose for which such information was collected, including providing you with the services we were engaged to perform.
2. Collection, holding, using and disclosing of personal information
2.1 Collection
When we collect, hold, use and disclose personal or sensitive information it must be done through lawful and fair means. Consent must be obtained to collect, hold, use and disclose personal information. We are not required to obtain your consent to collect, hold, use of disclose your personal or sensitive information if the collection is required or authorised by or under an Australian law or a court/tribunal order. There are other exceptions to the requirement of obtaining your consent in accordance with the Australian Privacy Principles.
2.2 Methods of collection
Personal information is obtained in many ways including requiring you to complete forms, interviews, correspondence, by telephone and facsimile, by email, via our website, from other publicly available sources, through your personal representative and from third parties.
Where reasonable and practicable, we will collect your personal information only from you. However, in some circumstances we may be provided with information by third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to use by a third party.
2.3 Collection of someone else's personal information
You should only provide us with someone else's personal information where you have their express consent to do so and it is for the purpose of us providing services to you. Matters in this policy should be communicated to any person whose information you collect and provide to us. In providing such information you agree that you have obtained the revenant consent and this is authorised to do so.
3. Security of personal information
3.1 Storage and destruction
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information.
4. Disclosure of personal information
We disclose information to the following organisations or individuals when and to the extent necessary to conduct our business and comply with applicable laws and regulations;
- Government and Regulatory authorities, as required or authorised by law;
- Our professional advisers (including legal firms, consultants and other advisers); and
- Third party service providers we may engage to provide administration, technology, auditing, mailing, printing or financial services. We take reasonable steps to ensure that such third party service providers exercise the same standard of care as us in handling your personal information.
5. Privacy on our websites
The HW One website uses Google Analytics or other third party software to analyse aggregate user behaviour. Google Analytics and such other software use first party cookies, which are text files placed on your computer for the purpose of anonymously identifying your session. These cookies are not used to grant HW One access to your personally identifiable information. Non-identifiable information (such as the pages you visit) may be tracked. By directing your browser to delete your cookies, this data will be erased.
For more information about Google Analytics, please follow the links provided on our website.
The information is collected using first party cookies, meaning that only HW One can access your information. Your information may be aggregated with information from other users for the purpose of improving our website and offerings. We will not associate any data gathered from our website with any personally identifiable information, unless you explicitly submit that information (e.g. your email address) via our online information form.
Any links to third party websites on the HW One website are not covered by our privacy policy.
6. Access to your personal information
6.1 Requesting access
You have the right to access any personal information regarding you that HW One holds. This is subject to some limited exceptions. Such requests should be made in writing to us and we may require personal identification. We will acknowledge your request within 14 days and respond to it within a reasonable time.
HW One may charge a fee only to cover the cost of locating, retrieving, reviewing and copying any material requested. We will not charge any fee to make the request or to for us to give effect to the request.
6.2 Responding to your request
If your request is approved, we will provide you with access to the information in the manner requested if it is reasonable and practicable to do so.
6.3 Procedure if your request to access or correct is refused
There may be limited circumstances where your request is refused or partially refused. If this occurs we will give you a written notice that sets out:
- The reasons for the refusal, including the reasons why access cannot be granted in an alternative way (except where it would be unreasonable to provide those reasons);
- How to make a complaint about the refusal;
- Any other matter as prescribed by the regulations.
If your request to correct is refused you have the option of submitting a statement associated with your personal information.
7. Maintaining the quality of your personal information
It is an important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
8. Direct marketing
HW One may engage in direct marketing to you from time to time. When required, your personal information will only be used or disclosed for direct marketing where the information is not sensitive, is collected directly from you and there is an easy means to opt out of such marketing (and such an opt out request has not been made) in the following circumstances:
- Where you would expect HW One to use or disclose the information for direct marketing purposes; or
- You have consented to the use or disclosure of the information for direct marketing purposes.If you do not wish to receive these materials, please contact us.
9. Policy updates
This policy may change from time to time and is available on our website.
10. How to make a complaint
If you consider that any action of HW One breaches this policy or the Australian Privacy Principles, you are able to make a complaint. Once we have received your complaint, it will be assessed and acted upon within a reasonable time.
HW One Pty Ltd
16 Trinity Lane,
Woolloongabba QLD 4102
(07) 3360 9600
16 TRINITY LANE, WOOLLOONGABBA QLD 4102
PO BOX 8406, WOOLLOONGABBA QLD 4102
PHONE: +61 7 3360 9600
EMAIL: connect@hwone.com.au
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