The kinds of personal information we collect and hold
We may collect and hold various types of personal information including your name, mobile phone number, address, email address, date of birth, gender, location and other information about you which we may need in order to conduct our business and / or provide you with our services. We may also collect personal information such as billing details when required.
We will generally collect any personal information we need in order to conduct our business and/or provide you with our services, functions and activities including the administration of our business and our marketing activities.
We do not usually collect sensitive information, such as information about your health, racial or ethnic origin, sexual orientation, religious beliefs or affiliations. We will only collect such information if required in a specific situation and with your consent, or otherwise in accordance with the Privacy Act.
It may not be practical for us to deal with you if you have not identified yourself or you are using a pseudonym. However, where it is practical, such as to respond to an enquiry about our business, we will allow individuals to remain anonymous.
How we collect and hold personal information
If it is reasonable and practicable to do so, we will collect personal information directly from you by phone, onsite, via our website or by email (including when you contact us with a comment or query or subscribe to one of our newsletters).
We may collect your personal information from other sources including from:
- third parties;
- publicly available sources of information;
- video, images, text, messages, comments and submissions you may upload or post on our website or social media platforms;
- cookies and other technologies to collect information;
- information collected automatically from your browser and your phone when you visit our website; and
- any other collection of or incidental or directly or indirectly related to the services we may be able to provide to you.
When you visit our website, we may assign your computer or phone one or more cookies, to facilitate access to our website and to personalize your online experience. We do not use the online "cookie" data to identify individuals and associated personal information. We use the information only for internal analysis of the way customers navigate our site, and to make sure that the content is structured and informative, and easy to navigate. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit/use and the links you click. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our website.
Cookies defined: A cookie is a small text file that is stored on a user’s computer/phone for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time. For example, when you sign in to our website, we may record your username and the name on your account in the cookie file on your computer/phone. We also may record your password in this cookie file, if you indicated that you would like your password saved for automatic sign-in. For security purposes, we will encrypt any usernames, passwords, and other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a username or ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and services.
You may delete or decline cookies by changing your browser settings. If you do so, some of the features and services of our website/App may not function properly.
We may use standard internet technology, such as web beacons and other similar technologies, to track your use of our website. We also may include web beacons in promotional e-mail messages or SMS to determine whether messages/notifications have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our users in order to measure the overall effectiveness of our website and business.
Web Beacons defined: Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies which are stored on the user’s computer hard drive/phone, web beacons are embedded invisibly on the web pages or in an email.
Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our site from an online advertisement displayed on a third-party website.
We will only collect personal information from you by lawful and fair means.
We will take reasonable steps to protect the personal information we collect, in both paper and electronic form, from misuse and loss as well as from unauthorized access, modification and disclosure. Reasonable steps include:
- Confirming the identity of any individual wishing to access personal information;
- In order to make every effort to ensure that your experience is secure, we use encryption technology to protect you against the loss, misuse or alteration of your personal information.
- Only staff members who need your personal information in order to do deal with your business or answer your requests or are given access to it. Employees are provided with training and information regarding the proper handling of personal information. All information stored in our computer system is protected from unauthorised access and information that is stored in document form is kept in secure locations to prevent access by unauthorised persons.
The purposes for which we collect, hold, use and disclose personal information
We collect, hold, use and disclose your personal information for our business and activities, and in our efforts to expand and improve our business, including for the following purposes:
- delivering, supplying and improving our services;
- provide services you request;
- develop new features for our website;
- to achieve our business objectives;
- handling privacy complaints and issues;
- managing your account and providing you with customer support;
- performing research and analysis about your use of our products, services, or content, or that of our sponsors and advertisers;
- to communicate with you to better understand your needs through competitions, market research, loyalty programs or to comply with First Class Wealth’s legal obligations;
- to provide you with information about products and services offered by First Class Wealth;
- to monitor or improve the quality and standard of service provided to you;
- to notify you of promotions that may be of interest you;
- to better understand your preferences;
- to provide account activity;
- to determine the advertising that may appear during your use of the website;
- to send you emails, SMS and push notifications, however, you may elect to opt-out of such correspondence at any time by notifying us;
- to communicate administrative issues and issues with your account;
- to assess the performance of the website and to improve the operation of the website;
- to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers, advertisers, sponsors or other third parties;
- for the administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes of First Class Wealth, its related bodies corporate, contractors, advertisers, sponsors or service providers;
- recommend features, content, social connections, referrals and advertisements;
- to provide you with marketing communication and invitations and offers including for new products and services;
- to determine if you are eligible for certain products, services or offers;
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).
Does First Class Wealth share this information with anyone else?
Yes, First Class Wealth may share your information with:
- our employees, affiliates, subsidiaries, related bodies corporate, contractors and service providers;
- marketing partners, consultants and retailers;
- web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators;
- other third parties with whom we have commercial relationships, for business, marketing, and related purposes;
- With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us;
- With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our services that are viewable by the general public; and
- With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our website
We, or Third Parties, may disclose specific individual information if we or they reasonably believe that it's necessary to comply with applicable laws or regulations, or to protect the interests of First Class Wealth, our business partners, affiliates or its guests, or the interests of our Third Parties.
We may also disclose your personal information:
- As required by law;
- To enforce our terms and conditions; and
- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale.
We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, board members, shareholders, and investors, for the purpose of conducting general business analysis.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
How you may access or correct the personal information that we are holding
To access your information or to correct information we are holding or for more information or assistance with accessing your personal information, please contact us and we will endeavour to respond to your request as soon as possible. First Class Wealth will give access in the manner requested unless it is unreasonable or impractical to do so.
There are some circumstances in which the APPs provide that we can refuse your request for access to your personal information including if we believe the access would pose a serious threat to the life or health of any individual or if the access would have an unreasonable impact on the privacy of other individuals or if the information contains commercially sensitive information or if we can refuse the request by law. We shall inform you of our decision and reasons for any refusal of your request.
How to complain about a breach of the APPs and how we will deal with such a complaint
If you would like to make a complaint about our handling of your personal information or if you think we have breached the APPs or any other binding APP code that has been registered under the Privacy Act, please contact us with your complaint in writing. We will endeavour to deal with your complaint as quickly as possible. We may give a copy of your complaint to any affected party for their comment so we can properly investigate any issues. We will determined what (if any) action we should take to resolve the complaint and notify you of our decision and our reasons.
If you are not satisfied with the way we have dealt with your complaint you may file a complaint with the Office of the Australian Information Commissioner.
Overseas disclosure of personal information
Personal information may be released to overseas recipients. We will only release information overseas in accordance with the requirements of the APPs and all Australian data protection and privacy laws.
Where we send your information to overseas service providers, we will make sure that appropriate data handling and security arrangements are in place. We have been advised by the relevant companies that they will protect such personal information in accordance with the Privacy Act and we will take all reasonable steps to ensure such compliance. Notwithstanding the above, Privacy Principle 8.1 of the APPs, to the extent permissible by the Act, shall not apply to disclosure of your personal information.
No Rights of Third Parties
The Privacy Act and the Office of the Australian Information Commissioner
For more information in relation to Privacy you can contact the Office of the Australian Information Commissioner by visiting their website at htttp://www.oaic.gov.au/.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Hosted in Australia
First Class Wealth’s website is hosted in Australia. If you do not reside in Australia, then you, by using our website or App you consent to the transfer of any personal information to Australia.