Privacy Policy

Purpose

1. EWL Wealth Pty Ltd (ABN92 657 938 102), its subsidiaries and affiliates (collectively referred to as “EWL Wealth” or “EWL”,2 “we”, “us”, or “our”) are committed to safeguarding personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and other applicable privacy laws.
2. This Privacy Policy outlines how we manage personal information, including how we collect, use, disclose, store, and secure it.

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About EWL Wealth

1. EWL Wealth is a licensed provider of financial planning and wealth management services. We provide tailored financial advice to individuals, families, and businesses.
2. If you have any questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer using the contact details below.

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Data Classification Policy

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Classification of personal and sensitive information

1. EWL Wealth applies a structured Data Classification Policy to ensure all personal information is appropriately handled based on its sensitivity and risk level. All data collected, processed, and stored by EWL is classified into the following categories:
   
   1. Public: Information that is approved for public release (e.g. marketing materials, website content).
   2. Internal: Non-sensitive operational data used within the organisation (e.g. staff directories, internal processes).
   3. Confidential: Information that could cause harm to individuals or the organisation if disclosed, including client financial details, contact information, and internal reports.
   4. Restricted: Highly sensitive personal or financial data, including Tax File Numbers (TFNs), health data, identity verification documents, and regulatory communications.
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2. Each classification level has specific handling, access, and storage requirements. Access to confidential and restricted information is limited to authorised personnel based on job role and responsibilities, using secure authentication and access controls. Staff and contractors are trained on these classifications and the associated security obligations.
3. EWL reviews and updates classifications periodically to account for new data types, regulatory changes, and evolving business needs.

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What Information do we Collect?

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Clients and prospective clients

1. We collect personal information necessary to provide our financial services and meet our legal obligations. The type of information we collect includes:
   
   1. Full name and contact details (e.g. email, phone, address)
   2. Date of birth, gender, and identification documents
   3. Employment and income details
   4. Financial goals and investment preferences
   5. Banking and superannuation information
   6. Tax file number (TFN), with your consent
   7. Sensitive information such as health or medical details (e.g. for insurance advice), with your consent

Prospective employees or applicants

1. We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.
2. We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions which involve working with children).

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Other individuals

1. EWL may collect personal information about other individuals who are not clients of EWL. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to EWL, and other individuals who interact with EWL on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with EWL.
2. If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
3. In limited circumstances, EWL may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by EWL we may collect health information about you in an emergency or otherwise with your consent.
4. We may collect personal information about children (for example, when children participate in events we are involved with). Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf.
5. You can always decline to give EWL any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.

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How EWL interacts with you via the internet

1. You may visit our website without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to EWL will be managed in accordance with this Privacy Policy.
2. EWL's website uses cookies. A “cookie” is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.
3. You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
4. EWL's website may contain links to third-party websites. EWL is not responsible for the content or privacy practices of websites that are linked to our website.

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Why we collect your information

1. We collect, use, and disclose personal information for the following purposes:
   
   1. To provide financial planning, superannuation, insurance, and investment services
   2. To assess your financial situation and tailor advice
   3. To communicate with you about your goals, portfolios, and regulatory updates
   4. To meet our compliance obligations under Australian law, including AML/CTF
   5. To administer billing, contracts, and customer service
   6. For internal business operations, risk management, analytics, and quality assurance

How we collect information

1. We collect personal information directly from you via forms, meetings, phone calls, emails, our website, and secure online portals. We may also collect information from:
   
   1. Financial institutions, insurers, or superannuation funds
   2. Your authorised representatives (e.g. accountants or legal advisers)
   3. Publicly available sources and regulatory databases

How we store and secure your data

1. We take reasonable steps to protect your information from misuse, loss, unauthorised access, modification, or disclosure. This includes:
   
   1. Secure electronic databases with role-based access
   2. Encrypted communication channels and data storage
   3. Physical security controls at office premises
   4. Policies around document retention, destruction, and de-identification

Disclosure of Your Information

1. We may share personal information with:
   
   1. Authorised third-party service providers (e.g. IT, legal, accounting, CRM providers)
   2. Product issuers, insurance providers, or fund managers as part of your advice or applications
   3. Regulators such as ASIC, ATO, AUSTRAC, or other government agencies, if legally required
   4. Other parties as permitted or required by law
2. Where we disclose information to overseas recipients (e.g. for data processing), we will ensure they comply with Australian privacy standards.

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Use and disclosure for administration and management

1. EWL will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
   
   1. administering billing and payments and debt recovery;
   2. planning, managing, monitoring and evaluating our services;
   3. quality improvement activities;
   4. statistical analysis and reporting;
   5. training staff, contractors and other workers;
   6. risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
   7. responding to enquiries and complaints regarding our services;
   8. obtaining advice from consultants and other professional advisers; and
   9. responding to subpoenas and other legal orders and obligations.

Data Retention and Disposal

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Retention and secure disposal of personal information

1. EWL Wealth retains personal information only for as long as is necessary to fulfil the purposes for which it was collected, or to meet legal, regulatory, or business obligations.
2. Typical retention periods include:
   
   1. Client records: Minimum of 7 years from the date of last engagement, in accordance with financial services regulations and the Corporations Act 2001.
   2. Prospective employee information: Up to 2 years from application date unless legally required to retain longer.
   3. Event and marketing data: 12 months or until the individual opts out, whichever comes first.
   4. At the end of a retention period, data is reviewed and securely disposed of using appropriate methods:
   5. Digital records: Permanently deleted from systems and backups using secure erasure protocols.
   6. Physical documents: Destroyed using cross-cut shredding or professional document destruction services.
3. De-identified data may be retained for analytical or audit purposes, provided it no longer identifies an individual and cannot be reasonably re-identified.
4. EWL regularly audits its data holdings to ensure compliance with this retention policy and to prevent unnecessary data accumulation.

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Your rights and access

1. You are entitled to access your personal information held by EWL on request. To request access to your personal information please contact our privacy officer using the contact details set out below.
2. You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
3. We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
4. However, if you consider any personal information we hold about you is inaccurate, out-of- date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
5. We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

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Making a privacy complaint

1. You may contact EWL at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
2. You may make a complaint about privacy to the privacy officer at the contact details set out below.
3. The privacy officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
4. If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
5. In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
6. If you are not satisfied with our response to your complaint, or you consider that EWL may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website (www.oaic.gov.au).

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Changes to This Privacy Policy

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We may amend this Privacy Policy from time to time. Updated versions will be published on our website at https://www.ewlwealth.com.au.

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Version Control Table

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