Legal
Privacy Policy
Important: starting draft. This page is a working draft prepared for the LS Wealth Solutions website. It has not yet been reviewed by an Australian solicitor or privacy consultant. Before publication, the operator must have the document reviewed and tailored to the business's actual data practices, including the third-party services used, the overseas jurisdictions any data is transferred to, and the business's status under the Privacy Act 1988 (Cth).
About this policy
LS Wealth Solutions Pty Ltd (ACN 621 317 342) ("LS Wealth Solutions", "we", "us", "our") respects your privacy and is committed to handling your personal information in accordance with the Privacy Act 1988(Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs") contained in that Act.
This Privacy Policy explains what personal information we collect, how we collect it, why we collect it, how we use and disclose it, how we store and secure it, and how you can access, correct or complain about our handling of your information.
By using this website or engaging our services, you consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.
0A. Anonymity and pseudonymity (APP 2)
Where lawful and practicable, you may interact with LS Wealth Solutions anonymously or under a pseudonym, for example, when reading this website or sending a general enquiry that does not require a personalised response. For an active Considered Review or any paid engagement, identification is necessary because the work involves your household's actual financial position, written plan documents in your name, and record-keeping obligations under Australian tax and financial-services law.
1. What personal information we collect
The personal information we collect about you depends on the nature of your engagement with us. It may include:
- Identity information: your name, your partner's name where you provide it, date of birth band, and household stage.
- Contact information: postal address, email address, telephone number, suburb and state.
- Engagement information: the substance of any enquiry, the content of messages you send us, calendar booking details, and notes from coaching conversations.
- Household and financial profile information: provided voluntarily by you in the course of a Considered Review or other engagement, including general details of your property, shares, superannuation and cashflow position. We collect only the information needed to deliver the coaching service you have engaged us for.
- Technical information: IP address, browser type, device type, pages visited, referring URL, and approximate location, collected automatically via cookies and analytics tools (see Section 7).
- Marketing information: your subscription status to our newsletter, downloads of our guides such as the Pre-Retirement Stocktake, and your engagement with our emails.
We do not knowingly collect personal information from children. We do not collect tax file numbers. We do not collect government identifiers except where required by law.
We aim to avoid collecting sensitive information (as defined in the Privacy Act). Where it is unavoidable for a particular service, we will seek your express consent first.
2. How we collect personal information
We collect personal information:
- Directly from you: when you complete a form on our website, download a guide, subscribe to our newsletter, book a Considered Review, exchange emails or calls with our team, or attend a coaching session.
- Automatically: when you use our website, through cookies, server logs and analytics tools.
- From third parties: only where you have authorised it (for example, a referral partner introducing you to us with your consent), or where collection from a third party is permitted by law.
Where it is reasonable and practical to do so, we collect personal information directly from you.
3. Why we collect personal information
We collect, hold, use and disclose personal information for the following purposes:
- to respond to your enquiries and provide the coaching, education and mentoring services you have requested;
- to deliver, administer and improve our website, the Pre-Retirement Stocktake, the Considered Wealth Method™ and our other materials;
- to maintain accurate records of our engagements and meet our legal and regulatory obligations;
- to send you service-related communications (booking confirmations, reminders, plan documents);
- to send you marketing communications about our services, with your consent and where you can opt out at any time;
- to analyse website usage so we can improve content, structure and user experience;
- to protect our rights, property and team, and to investigate suspected misuse of our services.
We will not use your personal information for any purpose that is unrelated to the purpose for which it was collected, unless you would reasonably expect us to do so, or you have consented, or we are required or authorised by law.
4. How we use your personal information
We use your personal information internally only by team members who need it to perform their role, typically those involved in delivering or administering your Considered Review.
We do not sell, rent or trade your personal information to any third party for any purpose, ever.
5. Disclosure to third parties
We may disclose your personal information to:
- Our staff and contractors: bound by confidentiality, only to the extent needed to perform their role for us.
- Service providers: including our website host, email and calendar platforms, customer relationship management system, document storage provider, analytics provider, and payment processor. Each provider is engaged under contract and is required to handle personal information consistently with the Privacy Act.
- Referral partners: only where you have asked us to refer you (for example, to a licensed financial adviser, accountant, mortgage broker or solicitor), and only with your prior consent. Any commercial arrangement with a referral partner is disclosed to you in writing before the introduction is made.
- Regulators, courts and law enforcement: where we are required or authorised by law to do so.
- Professional advisers: including our own legal and accounting advisers, where reasonably necessary.
5.1 Overseas disclosure
Some of the third-party service providers we use may store or process personal information outside Australia, including in countries such as the United States, the European Union, and the United Kingdom. Where overseas disclosure occurs, we take reasonable steps to ensure the overseas recipient handles your personal information consistently with the APPs.
The specific overseas jurisdictions to which personal information may be disclosed depends on the service providers we use at the time. A current list is available on request to hello@lswealthsolutions.au.
6. Storage and security of personal information
We hold personal information in a combination of:
- secure cloud-based systems operated by reputable service providers;
- restricted-access internal storage on devices used by our team;
- limited paper records where unavoidable, stored securely.
We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure, including access controls, multi-factor authentication on key systems, encryption in transit and at rest where supported by the provider, staff confidentiality obligations, and regular review of our security practices.
We retain personal information only for as long as it is needed for the purposes set out in this policy, or as required by law. When personal information is no longer needed and we are not required by law to retain it, we take reasonable steps to destroy or de-identify it.
7. Cookies and analytics
Our website uses cookies and similar technologies to:
- remember your preferences across visits;
- understand how the site is used in aggregate (page views, navigation paths, time on page);
- support basic security and performance.
We may use third-party analytics tools (such as a privacy-respecting analytics provider) and may use advertising-platform tags where you have consented via our cookie banner.
You can control or disable cookies through your browser settings. Disabling cookies may affect parts of the site that rely on them.
8. Marketing and opt-out
Where you have provided your email address, for example, by downloading the Pre-Retirement Stocktake or subscribing to our list, we may send you occasional emails containing educational content, updates to our materials, and notice of our services.
Every marketing email we send contains an unsubscribe link. You may also opt out at any time by emailing hello@lswealthsolutions.auwith the word "Unsubscribe" in the subject line. We action opt-out requests within five business days.
We do not send SMS marketing without your express prior consent.
9. Accessing and correcting your personal information
Under APP 12 and APP 13, you have the right to:
- Request access to the personal information we hold about you; and
- Request correction of personal information you believe is inaccurate, out of date, incomplete, irrelevant or misleading.
To make a request, contact us at hello@lswealthsolutions.au. We will respond to your request within a reasonable period, typically within 30 days, and we will not charge you for making a request. We may need to verify your identity before providing information.
If we decline a request, we will give you written reasons and information about how to complain.
10. Complaints
If you believe we have breached the Privacy Act or the APPs in our handling of your personal information, please tell us first. Most concerns can be resolved quickly and directly.
To make a complaint, write to:
Privacy OfficerLS Wealth Solutions Pty Ltd
hello@lswealthsolutions.au
We will acknowledge your complaint within five business days and aim to provide a substantive response within 30 days.
Office of the Australian Information Commissioner
If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC):
- Website: oaic.gov.au
- Phone: 1300 363 992
- Email: enquiries@oaic.gov.au
- Post: GPO Box 5288, Sydney NSW 2001
11. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal obligations or for other operational reasons. The current version is always the version published on this page. Material changes will be communicated by email to active clients and by a notice on the website.
12. Contact us
For any question about this Privacy Policy or about how we handle your personal information:
LS Wealth Solutions Pty LtdACN 621 317 342
hello@lswealthsolutions.au
Last updated: [DATE TO BE INSERTED AT PUBLICATION]