PRIVACY POLICY

 

Solomons Group Australia (collectively Solomons Capital Australia Pty Ltd ACN 635 595 309, Solomons Wealth Management Australia Pty Ltd ACN 633 678 172 and The Trustee for Kevin Choi Family Trust ABN 79 196 898 150 trading as Solomons Accountants & Advisers) (referred to in these terms and conditions as ‘Solomons’, ‘we’, ‘us’, or ‘our’) cares about your privacy and is committed to protecting your personal information in accordance with this Privacy Policy (Privacy Policy) and the Privacy Act 1988 (Cth).

This Privacy Policy outlines the way in which Solomons may collect, hold, use and disclose your personal information.

By using Solomons’ website and services, requesting goods from Solomons or otherwise providing Solomons with your personal information, you consent to Solomons collecting, holding, using and disclosing your personal information as described in this Privacy Policy. If Solomons is unable to collect, handle, use and disclose your personal information in accordance with this Privacy Policy, Solomons may not be able to provide you with the relevant goods and services or with access to Solomons’ website.

 

PERSONAL INFORMATION

“Personal information” is defined in the Privacy Act 1988 (Cth) to mean information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not.


‍PERSONAL INFORMATION COLLECTED BY SOLOMONS 

The personal information Solomons collects depends on the nature of your interactions with Solomons. Solomons may collect personal information about:

  • Solomons’ clients, potential clients, and other individuals Solomons may come into contact with in the course of acting for Solomons’ clients;
  • Solomons’ business associates, referrers, suppliers and their employees and personnel;
  • Solomons current, prospective and former employees, partners and contractors;
  • other people who come into contact with Solomons.

The personal information Solomons may collect and hold includes your name, telephone numbers, email addresses, street address, postal address, other contact details, date of birth, occupation, company name, employment history, education and qualifications, personal preferences, financial information, payment details, feedback and other information which assists Solomons in conducting its business and complying with its legal obligations.

Sometimes Solomons may also collect your ‘sensitive information’, such as information about your membership in a professional association, criminal record or health information.

You may choose not to provide Solomons with your personal information, however Solomons may not be able to provide you with access to its website, goods or services as a result.


‍COLLECTING & HOLDING PERSONAL INFORMATION

Solomons collects personal information in a variety of ways, including:

  • when you provide it directly or indirectly to Solomons, for example through emails, written forms, meetings, telephone conversations or messaging technology, business cards, when you sign up to Solomons’ email lists, when you register or attend a Solomons seminar, through your feedback, via the internet, website or social media, online queries, or when someone else provides it on your behalf, such as your employer or a third party service provider;
  • from public sources of information;
  • in some circumstances, from third parties, for example, Solomons may use third parties to analyse traffic at its website and social media channels, which may involve the use of cookies.

Solomons collection of your personal information may be on a one-off, ad hoc or recurring basis using any of the above sources and Solomons may combine or link the personal information Solomons collects with the other personal information Solomons already knows about you.

When Solomons obtains personal information from third parties, Solomons will assume and you must ensure that you have made the third party aware that you have referred Solomons to them and of the purposes involved in the collection, use and disclosure of the relevant personal information.

If you supply Solomons with personal information about another individual, please refer that person to this Privacy Policy.


‍TECHNOLOGY

Solomons may also collect and process non-personal information provided to Solomons by your browser when you visit Solomons’ website for example, the website you came from, your location information, IP address, web browser and/or device type and the time and date of access.

You are able to control your browser settings to limit the collection of information by your browser, however, if you limit your browser settings, you may not be able to use certain features of Solomons’ website.


‍PURPOSE FOR COLLECTING, HOLDING, USING & DISCLOSING PERSONAL INFORMATION

‍Generally, Solomons may collect, hold, use and disclose your personal information for the primary purposes for which it was collected, including to:

  • provide you with Solomons’ goods or services;
  • conduct Solomons’ business, including marketing Solomons’ goods and services, and communicating with you;
  • confirm your identity;
  • understand your needs, requirements and interactions with Solomons so that Solomons can tailor and enhance its goods and services, including its website;
  • enable third parties or suppliers to facilitate the provision of goods or services to you, for example barristers, title and court searches, accountants, mediators, valuers, printers, carriers and recruitment;
  • manage Solomons’ relationship with you including communicating goods or services that may interest you, sending you email newsletters and providing you with technical assistance;
  • conduct marketing activities;
  • organise events;
  • consider the suitability of prospective employees, partners and contractors; and
  • comply with Solomons’ legal obligations.

Solomons may also use and disclose your personal information for other purposes which you consent to or which are required or permitted by law. This other purpose may include for a secondary purpose that is related to a purpose for which Solomons collected the personal information, and for which you would reasonably expect Solomons to use or disclose your personal information.

 

 

‍DISCLOSING PERSONAL INFORMATION

Solomons may disclose your personal information (including, in certain circumstances, your sensitive information) for the purposes for which it was collected to:

  • courts, tribunals and regulatory authorities, or to anyone else to whom you authorise Solomons to disclose it to;
  • anyone else where Solomons is required or authorised by law to do so;
  • contractors who assist Solomons to provide its services, including third party service providers, hosting and data storage providers and debt collectors; and
  • social media channels where Solomons has a presence.


‍OVERSEAS DISCLOSURE

Solomons may disclose your personal information to, and collect your personal information from, overseas third parties, with your consent, where authorised by law, or where Solomons’ business activities or functions have been outsourced to an overseas service provider. Solomons may disclose your personal information to, and collect your personal information from, the overseas service providers to the extent necessary for Solomons to perform its business activities and functions. These service providers may be located in the United States of America, Germany, India, Pakistan and the Republic of the Philippines.

Solomons may need to disclose your personal information to and collect your personal information from service providers in other countries as well and this will be on an ad hoc or case by case basis, and for the purpose for which Solomons collected your personal information.


‍PROTECTING PERSONAL INFORMATION

Solomons takes reasonable steps to protect your personal information from misuse, interference, loss, and from unauthorised access, modification or disclosure. These steps include secure storage facilities for paper records, secure data centres and cloud storage providers, limiting physical access to Solomons’ premises and paper records, restricting electronic access to the personal information Solomons holds through information security software and firewalls, conducting privacy training for Solomons’ employees and permanently destroying or de-identifying your personal information as required by law and otherwise when it is no longer required.


‍ANONYMITY & PSEUDONYMITY

Where possible, Solomons will provide you with the option to use a pseudonym or not identify yourself, unless Solomons is required or authorised by law to identify you. Solomons may not be able to assist you with your specific requests if you are using a pseudonym or are anonymous.


‍ACCESSING & CORRECTING PERSONAL INFORMATION

Subject to the requirements and exceptions in the Privacy Act 1988 (Cth), you may request access to and seek correction of the personal information Solomons holds about you by contacting support@thesolomons.com.au. There is no fee for submitting a request to access your personal information. Solomons may charge a fee for payment of its reasonable administrative costs in providing the requested personal information to you.

‍THIRD PARTY CONTENT

Solomons may include links to third party content including links to website operated by third parties. Solomons has no control over the privacy practices of these third parties and makes no representations or warranties in relation to the privacy practices of these third parties. Please check the website of each relevant third party for details of their privacy policies.

‍MARKETING

Solomons may use and disclose your personal information to advise you of the range of goods and services Solomons provide, advise you of legal developments, and market Solomons’ services. You can opt out of receiving marketing materials from Solomons at any time, including by sending an unsubscribe message to Solomons using the contact details provided in the relevant electronic message. Otherwise you can contact Solomons at support@thesolomons.com.au to unsubscribe or update your preferences.

‍PRIVACY QUERIES AND COMPLAINTS

If you have any questions about privacy-related issues or wish to complain about a breach of your privacy or the handling of your personal information by Solomons, please contact  support@thesolomons.com.au. Solomons may ask you to lodge your complaint in writing. Any complaint will be investigated by the Privacy Officer and you will be notified of the making of a decision in relation to your complaint as soon as is practicable after it has been made.

If Solomons is unable to satisfactorily resolve your concerns about its handling of your personal information, you can contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Tel: 1300 363 992
Email: enquiries@oaic.gov.au
www.oaic.gov.au

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CHANGES TO PRIVACY POLICY

Solomons may change this Privacy Policy at any time and Solomons will post any changes to this Privacy Policy on its website. Solomons encourages you to check Solomons’ website to view the current Privacy Policy or contact Solomons at support@thesolomons.com.au to obtain a copy of the most recent Privacy Policy.