DISCLAIMER

In developing this web-site Strategem did not take into account the investment objectives, financial situation and particular needs (“financial circumstances”) of any particular person. Accordingly, before acting on any advice contained in this document, you should assess whether the advice is appropriate in light of your own financial circumstances.
No person should rely on any of the contents of this website without obtaining specific advice from one of our advisers. Strategem, its Principals and agents accepts no responsibility to any person who acts or relies in any way on any of the material without first obtaining specific advice.

PRIVACY POLICY

Strategem is committed to protecting the privacy and security of the personal information we collect and receive from our clients and other parties that make contact with us. Strategem is required to comply with the Privacy Act and its thirteen Australian Privacy Principles (APP’s) in so far as they apply to our business operations. This Privacy Policy outlines how Strategem collects, uses and stores that information.

THE INFORMATION WE COLLECT

Strategem needs to collect personal information to be able to perform our core functions in order to deliver our professional services to you and to complete any of our own business transactions. Strategem’s policy is to only collect personal information where it is reasonably necessary for our functions or activities. We will primarily collect your information direct from you in a fair and lawful manner via face to face interviews, over the telephone, or by other means with your prior authority.
The main purposes for which we collect, hold, use and disclose personal information are to provide services to our clients. The type of personal information that Strategem collects and holds about you depends on the type of dealings you have with us. This information could include, but is not limited to, your name, contact details, your requirements, relevant company details, business details, financial information and information as required by taxation law. We may also obtain information on your behalf from external sources but we will only do so with your prior authority.

Strategem will take all reasonable steps to ensure that the personal information we collect from you is accurate, up to date and complete and that when we use or disclose that information it is accurate, up to date and complete. If you request that we correct or change information that we have previously provided to third parties, then we will do so provided it is reasonable and practicable to do so. Strategem does not adopt any government related identifiers in order to identify you, such as a Tax file number, Medicare number or driver’s licence number.
You can also help us keep your information up to date by letting us know about any changes to your personal information, such as your email address or phone number.
The Privacy Act does provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. In some cases however, if you don’t provide us with your personal information when requested, we may not be able to respond to your request or provide you with the product or service that you are seeking. In addition, we are bound by the laws governing our various activities to collect personal information in order to provide you with our services.

HOW WE USE PERSONAL INFORMATION

The information that you provide will be collected and held by us and is used to assess your requirements and to enable Strategem to properly run the organisation, for instance in maintaining client records. That information also enables the relevant services or information to be provided to you. It may also be used for other purposes which you would reasonably expect, for example, financial planning, taxation, business services and audit.
As a Strategem client, you may also receive emails, newsletters, promotional material or other updates from us about new information, seminars or products or services being offered by Strategem. We hope that you will find these items i
nformative and useful. However, should you choose to not receive them you may always unsubscribe and opt out of receiving this information.
Unless otherwise prohibited by law or our contractual obligations, we may disclose personal information if required to do so by law, court order, or as requested by a governmental or law enforcement authority, or in the good faith belief that disclosure is otherwise necessary or advisable.

CROSS BORDER DISCLOSURE OF PERSONAL INFORMATION

In any case, Strategem’s policy is to comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information, as well as with any legal requirements applicable in the relevant jurisdiction.

THE SECURITY OF YOUR PERSONAL INFORMATION

We treat your personal information at all times as confidential.
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in drawers and cabinets, locked where appropriate. Paper files may also be archived in boxes and stored offsite in secure facilities. Strategem’s policy is to take reasonable steps to protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.
The steps we take to secure the personal information we hold include ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security and training and workplace policies.
All personal data that has been collected from you will only be kept for the limited duration that is relevant to the purpose for which your personal data is to be used and for as long as required by applicable law.

ACCESS & CORRECTION OF YOUR PERSONAL INFORMATION

Individuals have a right to request access to the personal information held by Strategem and to request its correction.
Strategem’s policy is to provide you with access to your personal information, subject to some exceptions permitted by law. We may provide access in the manner that you have requested provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you. Except in the case of more complicated requests, we will endeavour to respond to access and correction requests within 30 days.
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, Strategem’s policy is to take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.

If we refuse your access or correction request, or if we refuse to give you access in the manner you requested, Strategem’s policy is to provide you with a written notice setting out:

  • the reasons for our refusal (except to the extent that it would be unreasonable to do so); and,
  • available complaint mechanisms,
  • any other matter prescribed by the regulations of the Privacy Act.

COMPLAINTS

You may make a complaint if you feel your personal information has been handled inappropriately by Strategem in breach of Strategem’s privacy obligations under the Privacy Act.
In the first instance, complaints must be directed to Strategem’s Privacy Officer in writing. Strategem will investigate the complaint and prepare a response to you in writing within a reasonable period of time.
If you are unhappy with Strategem’s response or the manner in which Strategem has dealt with the complaint, you have the option of making a complaint to the Office of the Australian Information Commissioner (“OAIC”).

FURTHER INFORMATION

We may amend this Privacy Policy from time to time. The current version will be posted on our website and a copy may be obtained free of charge from our Office.

Our contact details for privacy queries are set out below.

Privacy Officer
Strategem
35 Mundy Street
Bendigo VIC 3550
E: privacy@strategem.com.au