Privacy Policy and Collection Statement

(Privacy Policy)

1. Introduction
Levitate Pty Ltd ABN 644 958 903 (referred to as Levitate, we, our, us) is bound by the Privacy Act
1988 (Privacy Act), including the Australian Privacy Principles (APPs), and recognises the
importance of ensuring the confidentiality and security of your personal information.
All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use
personal information collected and held by Levitate, must abide by this Privacy Policy and Collection
Statement (Privacy Policy). Levitate makes this Privacy Policy available free of charge and can be
downloaded from its website
In this Privacy Policy:
• Disclosure of information means providing information to persons outside of Levitate;
• Personal information means information or an opinion relating to an individual, which can be
used to identify that individual;
• Director means the contact person within Levitate for questions or complaints regarding
Levitate’s handling of personal information;
• Sensitive information is personal information that includes information relating to a person’s
racial or ethnic origin, political opinions, religion, trade union or other professional or trade
association membership, sexual preferences and criminal record, and also includes health
information; and
• Use of information means use of information within Levitate.

2. What kind of personal information do we collect and hold?
We may collect and hold a range of personal information about you to provide you with our services,
• name
• address
• phone numbers
• email addresses
• occupation
• age
• marital status
• financial information, including details of:
            your investments


3. How do we collect personal information?
We generally collect personal information directly from you. For example, personal information will be
collected through our application processes, forms and other interactions with you in the course of
providing you with our products and services, including when you visit our website, use a mobile app
from us, call us or send us correspondence.
We may also collect personal information about you from a third party, such as electronic verification
services, referrers and marketing agencies. If so, we will take reasonable steps to ensure that you
are made aware of this Privacy Policy. We may also use third parties to analyse traffic at our website,
which may involve the use of cookies. Information collected through such analysis is anonymous.
We will not collect sensitive information about you without your consent, unless an exemption in the
APPs applies. These exceptions include if the collection is required or authorised by law, or
necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If the personal information we request is not provided by you, we may not be able to provide you with
the benefit of our services, or meet your needs appropriately.
We do not give you the option of dealing with them anonymously, or under a pseudonym. This is
because it is impractical, and, in some circumstances, illegal for Levitate to deal with individuals who
are not identified.

4. Unsolicited personal information
We may receive unsolicited personal information about you. We destroy or de-identify all unsolicited
personal information we receive, unless it is relevant to our purposes for collecting personal
information. We may retain additional information we receive about you if it is combined with other
information we are required or entitled to collect. If we do this, we will retain the information in the
same way we hold your other personal information.
5. Who do we collect personal information about?
The personal information we may collect and hold includes (but is not limited to) personal information
• clients;
• potential clients;
• service providers or suppliers;
• prospective employees, employees and contractors; and

6. Why do we collect and hold personal information?
We may use and disclose the information we collect about you for the following purposes:
• provide you with our products and services;
• review and meet your ongoing needs;
• provide you with information we believe may be relevant or of interest to you;
• let you know about other products or services we offer, send you information about special
offers or invite you to events;
• consider any concerns or complaints you may have;

• comply with relevant laws, regulations and other legal obligations;
• help us improve the products and services offered to our customers and enhance our overall
• to assist in providing a general superannuation health check.
We may use and disclose your personal information for any of these purposes. We may also use and
disclose your personal information for secondary purposes which are related to the primary purposes
set out above, or in other circumstances authorised by the Privacy Act.
Sensitive information will be used and disclosed only for the purpose for which it was provided (or a
directly related secondary purpose), unless you agree otherwise, or an exemption in the Privacy Act

7. Who might we disclose personal information to?
We may disclose personal information to:
• a related entity of Levitate;
• an agent, contractor or service provider we engage to carry out our functions and activities,
such as our lawyers, accountants, debt collectors or other advisers;
• organisations involved in a transfer or sale of all or part of our assets or business;
• organisations involved in managing payments, including payment merchants and other
financial institutions, such as banks;
• regulatory bodies, government agencies, law enforcement bodies and courts;
• financial product issuers;
• anyone else to whom you authorise us to disclose it or is required by law; and

If we disclose your personal information to service providers that perform business activities for us,
they may only use your personal information for the specific purpose for which we supply it. We will
ensure that all contractual arrangements with third parties adequately address privacy issues, and we
will make third parties aware of this Privacy Policy.

8. Management of personal information
We recognise the importance of securing the personal information of our customers. We will take
steps to ensure your personal information is protected from misuse, interference or loss, and
unauthorised access, modification or disclosure.
Your personal information is generally stored in our computer database. Any paper files are stored in
secure areas. In relation to information that is held on our computer database, we apply the following
• passwords are required to access the system, and passwords are routinely checked;
• data ownership is clearly defined;
• we change employees’ access capabilities when they are assigned to a new position;
• employees have restricted access to certain sections of the system;
• the system automatically logs and reviews all unauthorised access attempts;
• unauthorised employees are barred from updating and editing personal information;

• all computers which contain personal information are secured both physically and
• data is encrypted during transmission over the network; and
• print reporting of data containing personal information is limited.

9. Direct marketing
We may only use personal information we collect from you for the purposes of direct marketing
without your consent if:
• the personal information does not include sensitive information; and
• you would reasonably expect us to use or disclose the information for the purpose of direct
marketing; and
• we provide a simple way of opting out of direct marketing; and
• you have not requested to opt out of receiving direct marketing from us.
If we collect personal information about you from a third party, we will only use that information for the
purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and
we will provide a simple means by which you can easily request not to receive direct marketing
communications from us. We will draw your attention to the fact you may make such a request in our
direct marketing communications.
You have the right to request us not to use or disclose your personal information for the purposes of
direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must
give effect to the request within a reasonable period of time. You may also request that we provide
you with the source of their information. If such a request is made, we must notify you of the source
of the information free of charge within a reasonable period of time.

10. Identifiers
We do not adopt identifiers assigned by the Government (such as drivers’ licence numbers) for our
own file recording purposes, unless one of the exemptions in the Privacy Act applies.

11. How do we keep personal information accurate and up-to-

We are committed to ensuring that the personal information we collect, use and disclose is relevant,
accurate, complete and up-to-date.
We encourage you to contact us to update any personal information we hold about you. If we correct
information that has previously been disclosed to another entity, we will notify the other entity within a
reasonable period of the correction. Where we are satisfied information is inaccurate, we will take
reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not
charge you for correcting the information.

12. Accessing your personal information
Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information
that we hold about you by contacting the Director. We will provide access within 30 days of the
individual’s request. If we refuse to provide the information, we will provide reasons for the refusal.
We will require identity verification and specification of what information is required. An administrative
fee for search and photocopying costs may be charged for providing access.

13. Updates to this Privacy Policy
This Privacy Policy will be reviewed from time to time to take account of new laws and technology,
and changes to our operations and the business environment.
14. Responsibilities
It is the responsibility of management to inform employees and other relevant third parties about this
Privacy Policy. Management must ensure that employees and other relevant third parties are advised
of any changes to this Privacy Policy. All new employees are to be provided with timely and
appropriate access to this Privacy Policy, and all employees are provided with training in relation to
appropriate handling of personal information. Employees or other relevant third parties that do not
comply with this Privacy Policy may be subject to disciplinary action.

15. Non-compliance and disciplinary actions
Privacy breaches must be reported to management by employees and relevant third parties.
Ignorance of this Privacy Policy will not be an acceptable excuse for non-compliance. Employees or
other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary

16. Incidents/Complaints handling/Making a complaint
We have an effective complaints handling process in place to manage privacy risks and issues. The
company maintains a Data Breach Register where any issues are logged. This register is reviewed
daily by the Director of Levitate and any issues that may arise are actioned immediately and resolved
within 10 business days.
The complaints handling process involves:
• identifying (and addressing) any systemic/ongoing compliance problems;
• increasing consumer confidence in our privacy procedures; and
• helping to build and preserve our reputation and business.
You can make a complaint to us about the treatment or handling of your personal information by
lodging a complaint with the Director.
If you have any questions about this Privacy Policy, or wish to make a complaint about how we have
handled your personal information, you can lodge a complaint with us by:
• writing – Levitate Pty Ltd, Unit 1, 21 Upton Street, BUNDALL, QLD 4217
• emailing –

If you are not satisfied with our response to your complaint, you can also refer your complaint to the
Office of the Australian Information Commissioner by:
• telephoning – 1300 363 992
• writing – Director of Complaints, Office of the Australian Information Commissioner, GPO Box
5218, SYDNEY NSW 2001
• online submission –

17. Contractual arrangements with third parties
We ensure that all contractual arrangements with third parties adequately address privacy issues, and
we make third parties aware of this Privacy Policy.
Third parties will be required to implement policies in relation to the management of your personal
information in accordance with the Privacy Act. These policies include:
• regulating the collection, use and disclosure of personal and sensitive information;
• de-identifying personal and sensitive information wherever possible;
• ensuring that personal and sensitive information is kept securely, with access to it only by
authorised employees or agents of the third parties; and
• ensuring that the personal and sensitive information is only disclosed to organisations which
are approved by us.

18. Your rights
This Privacy Policy contains information about how:
• you may access the personal information we hold about you;
• you may seek the correction of your personal information;
• you may ask us to provide an alternative means of identity verification for the purposes of the
Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• you may complain about a breach of the Privacy Act, including the APPs; and
• we will deal with a privacy complaint.