This policy explains how Kestrel Global Group LLC ("we", "us"), operating the Harbour brand, handles your personal information. We are bound by the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and this policy is our APP 1 policy. Kestrel Global Group LLC is a company registered in the United States (131 Continental Dr, Suite 305, Newark, DE 19713, United States); by using Harbour you understand your information is handled in the United States (see section 5). Privacy contact: privacy@kestrelglobal.group.
We collect only what we reasonably need to match you: your name, email, phone number, city/state, and your answers (your retirement timeframe, superannuation and investment band, and whether you have an adviser), together with a record of your consent (the exact wording you agreed to, the date and time, and your IP address). We collect it directly from you by lawful and fair means. We do not seek sensitive information (such as health) and ask that you do not provide it.
We use and disclose your information for the primary purpose of matching you with and referring you to one licensed Australian financial adviser, and for directly related purposes you would reasonably expect (such as verifying your phone number and keeping records of consent). We do not sell your details to a list of companies, resell the same enquiry to multiple advisers, or use it for unrelated purposes.
We share your details with one licensed Australian financial adviser that we match you to; they become responsible for your information as a separate entity and will contact you directly. We also use service providers (for example, hosting and messaging) who act on our instructions, and we may disclose information where required by law.
With your consent, Harbour and the adviser we match you with may contact you by phone, SMS and email about your enquiry. Every message includes a simple way to opt out, we honour opt-outs, and marketing calls comply with the Spam Act 2003 and the Do Not Call Register Act 2006. You can withdraw your consent at any time by emailing privacy@kestrelglobal.group.
Kestrel Global Group LLC is based in the United States, so your information is stored and handled in the United States (and by our service providers, which may be located overseas). By providing your information and consenting, you agree to this overseas handling. The adviser we refer you to is located in Australia.
You can ask us to access the personal information we hold about you or to correct it, and you can withdraw consent, by emailing privacy@kestrelglobal.group. If you have a privacy complaint, contact us first and we will respond. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or 1300 363 992.
We take reasonable steps to protect your information and to destroy or de-identify it when no longer needed. We keep enquiry and consent records only as long as needed for the referral and to meet legal requirements. We comply with the Notifiable Data Breaches scheme: if an eligible data breach is likely to cause serious harm, we will notify affected individuals and the OAIC as required.
We use automated processes to score and match your answers to a suitable adviser. This does not replace advice, and you can ask us about how the matching works by emailing privacy@kestrelglobal.group.
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This service is for adults and is not directed at anyone under 18.
We may update this policy and will change the date above. Material changes will be made clear on this page.