Privacy Policy
Sovereign Private Pty Ltd Website Privacy Statement
At Sovereign Private Pty Ltd ("Sovereign Private," "we," "us," or "our"), we are dedicated to handling personal information in accordance with the Australian Privacy Principles outlined in the Privacy Act 1988 (Cth) ("Privacy Act"). This Privacy Policy details our practices regarding the collection, use, disclosure, and management of personal information.
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. Any significant modifications will be posted on our website.
1. Personal Information We Collect
The personal information we collect varies based on our engagement with you and may include:
- Identification Details: Name, job title, occupation, date of birth, and gender.
- Contact Information: Address, email address, phone numbers, and IP address.
- Credentials: Usernames and passwords.
- Professional Background: Educational qualifications, employment history, and referee reports.
- Identification Documents: Passport or driver's license details.
- Government Identifiers: Tax file numbers.
- Financial Information: Credit card and bank account details, shareholdings, investment information (e.g., dividend payments, investment gains or losses, associated income and expenditure).
- Superannuation and Insurance Details.
- Visa or Work Permit Status.
- Immigration Status.
In certain circumstances, we may collect sensitive information, such as details about your race, gender diversity, sexual orientation, disability, ethnic origin, political opinions, health, religious or philosophical beliefs, and criminal history. We will only collect and use sensitive information with your consent, in accordance with applicable laws, or in a de-identified, aggregated manner.
If you provide us with personal information about others (e.g., spouse, dependents), please ensure you have informed them and directed them to this Privacy Policy.
Remaining anonymous or using a pseudonym may not be practical when dealing with us, as we often require your personal information to provide specific services.
2. Collection of Personal Information
We primarily collect personal information directly from you through:
- In-person or phone interactions.
- Correspondence (including email).
- Completion of questionnaires, forms, or surveys.
- Subscriptions to our publications.
We may also collect information from external sources, including:
- Public information (e.g., social media profiles like LinkedIn).
- Third parties such as your employer (if they are our client), referees, personal representatives, financial advisors, or banks (with your authorisation).
- Your interactions with our websites and social media platforms.
3. Holding Personal Information
We store personal information in both physical and electronic formats. Security measures include:
- Physical Controls: Secure office entry and locked storage cabinets.
- Technological Controls: Access restrictions, firewalls, encryption, passwords, and digital certificates.
Our policies govern document retention and data breach responses. We strive to keep personal information current and delete or anonymise data when no longer needed, unless retention is required for legal or business purposes.
4. Purpose of Collecting, Holding, Using, and Disclosing Personal Information
We use your personal information for lawful purposes, including:
- Service Provision: Delivering services per our engagement terms.
- Service Improvement: Developing new products, responding to inquiries, verifying identity, and seeking feedback.
- Client Relations: Informing clients about our services, industry developments, seminars, and events.
- Administration: Processing payments, billing, fraud detection/prevention, and enforcing terms of engagement.
- Employment: Managing personnel, contractors, and subcontractors.
- Governance and Compliance: Addressing quality, conduct, or risk management issues, meeting regulatory obligations, and complying with legal requirements.
- Business Transactions: Managing actual or proposed acquisitions, mergers, de-mergers, alliances, joint ventures, or referral arrangements.
5. Sharing Personal Information
We may share your personal information with:
- Authorised representatives, advisors, and referees.
- Our personnel and professional advisors.
- Experts or third parties engaged for specific services.
- Agents, contractors, and suppliers assisting with our business operations.
- Nominated superannuation funds.
- Third parties involved in business transactions (e.g., acquisitions, mergers).
- Government or regulatory bodies (e.g., Australian Taxation Office, Australian Securities and Investments Commission) as required.
- Other parties with your consent or as directed by you.
We do not disclose personal information to third parties for their marketing purposes.
Some information may be stored or processed overseas or in cloud-based systems. In such cases, we ensure appropriate measures are in place to protect your information.
6. Website and Online Interactions
6.1 Automatic Collection
We, along with our service providers, use cookies, web beacons, and similar technologies to collect information automatically. This helps us personalise your online experience and improve our services. You can adjust your device's privacy and browser settings to manage these technologies.
6.2 Analytics Tools
We utilise tools like Google Analytics to understand website usage. For more information, visit Google Analytics Terms of Service.
6.3 Social Media Features
Our websites may include social media features (e.g., LinkedIn Like button) that collect information about your interactions. These features are governed by the privacy policies of the respective social media platforms.
7. Children
We prioritise children's privacy and do not intentionally design our websites for individuals under 13. We do not knowingly collect information about children under 13, except as required by law for specific services.
8. Access to Personal Information
To ensure the accuracy of your personal information, please notify us of any changes. You can request access to the information we hold about you by contacting us (see 'How to Contact Us'). We may charge reasonable fees for providing access.
9. Complaints
If you have concerns about our handling of your personal information, please contact us via our 'Contact' page. We aim to respond within 30 days. If you're unsatisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner.
10. How to Contact Us
For questions regarding this Privacy Policy or our data management practices, please contact us through the details provided on our website.