This Policy was last reviewed and updated on: May 2023 

Privacy Policy  

Wealth Health & Heels Pty Ltd (known as Jessica Brady) values and respects the privacy of the people we deal with.  

Jessica Brady is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and other applicable privacy laws and regulations.  

This Privacy Policy (Policy) describes how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of your personal information. 

The collection of personal information about individuals by organisations is governed by the above Privacy Policy Act which contains a national scheme for collections, use, correction, disclosure and transfer of personal information by organisations in the private sector. 

 Protecting your privacy is very important to us. As part of our commitment to ensuring the safety of your private and confidential information and as a mechanism to ensure our compliance with the Privacy Act, we have established and implemented a Privacy Policy.

Purpose

The Policy explains our policies and practices with respect to the collection and management of personal information we collect from you. 

The Privacy Act requires us to handle your personal information in accordance with a set of principles, known as the Australian Privacy Principles (APPs). Those principles and our approach to those principles are set out below.

Scope

The policy applies to Jessica Brady and all of its related companies together referred to in this policy as “Jessica Brady”, “us”, “our”, or “we”. 

We seek to offer the best possible service to our users “you”. To do this, we are required to collect some personal information from our users to ensure that you are eligible to use our services and to provide you with the most relevant and beneficial content.  

While we try our best by implementing several methods to safeguard personal information as outlined below, no measure can be guaranteed to provide 100% security, so please ensure you are carefully considering the terms contained within this policy as we cannot guarantee the security of your information. 

We recommend that you read this policy in full to ensure you are fully aware and informed.   

Your continued use of the site confirms your confirmation of acceptance of these terms. If you have any questions about the privacy policy, please contact us at [email protected] or use our other contact details below.

What is personal information?

“Personal information” means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.

What personal information do we collect?

For Jessica Brady to provide you with the best possible service, we can ask you to provide us with some personal information.  

 We will collect and hold your personal information for the purposes of: 

• Providing general advisory services and courses to you 
• Letting you know about our other products or services.  

The personal information we collect about you depends on the nature of your dealings with us or what you choose to share with us. The personal information we collect about you can include:   

• name;  
• contact details; 
• mailing, or street address;  
• date of birth; 
• email address;  
• phone number; 
• occupation;  
• gender; 
• photographs; 
• credit information; 
• financial information/details; 
• bank details; 
• sensitive information; 
• biometrics  

Financial information means general information about your financial position.  

Under certain circumstances, Jessica Brady may need to collect sensitive information about you. This might include any information or opinion about your racial or ethnic origin, political opinions, philosophical beliefs, sexual preferences, or health information.  

If we collect your sensitive information, we will do so only with your consent, if it is necessary to prevent a serious and imminent threat to life or health, or as otherwise required or authorised by law, and we take appropriate measures to protect the security of this information. 

You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our services or otherwise interact with you. 

How do we collect your personal information?

Jessica Brady will collect your personal information directly from you, upon registration or through our training courses and events. Jessica Brady can also collect information from you by liaising with our affiliate companies, your references, or credit reporting bodies.  

We could also receive your personal information indirectly from third-party websites that we are affiliated with. 

We collect your personal information directly from you when you: 

• interact with us over the phone;  
• interact with us in person;  
• interact with us online;  
• participate in surveys or questionnaires;  
• attend a Jessica Brady or third party event;  
• subscribe to our mailing list;  
• apply for a position with us as an employee, contractor or volunteer;  

Much of this information is collected through application forms, the use of our online facilities, or ongoing communications with you. 

We could also be required to ask for certain information by law. Wherever there is a legal requirement for us to ask for information about you, we will inform you of the obligation and the consequences of not giving us the requested information. For example, in addition to obtaining personal information from you, whenever you acquire a new product or service from us, we will need to obtain certain documentary evidence from you as to your identity. 

You are not required to give us the information that we request. However, if you do not give us the information that we ask for, or the information you give is not complete or accurate, this may impact how we provide our services to you. 

Collecting personal information from third parties

We could also collect your personal information from third parties or through publicly available sources, for example from referral partners and other organisations, services providers or business partners who provide you with product or services along with us. We collect your personal information from these third parties so that we can provide you with our services. 

Re-Marketing

In the event that you do not submit information to us after visiting our website or through any of our online channels, it is possible we may use re-marketing services to communicate to you in search engines or on social networks. Any data collected through these advertising platforms will be used in accordance with the Jessica Brady Privacy Policy and the policy of the remarketing service provider. To opt out of cookie-based advertising you must visit the ad settings for each respective platform. 

How do we use your Personal information?

We use personal information for many purposes in connection with our functions and activities, including the following purposes:  

• provide you with information or services that you request from us;  
• deliver to you a more personalised experience and service offering;  
• improve the quality of the services we offer;  
• internal administrative purposes;  
• marketing and research purposes;  
• verifying your identity for anti-money laundering and counter terrorism financial purposes; or in order to prevent crime or fraud  
• complying with legal requirements  
• sending you offers, updates, educational information, articles, newsletters or other information about product or services that we believe may be of interest to you; 
• handling complaints 

Jessica Brady is an authorised representative of Paragem Pty Ltd. Like other financial services companies, there are situations where we may also disclose your personal information where it is:  

• Required by law (such as to the Australian Taxation Office or Australian Security & Investment Commission)  
• authorised by law (such as where we are obliged to disclose information in the public interest or to protect our interests)  
• Required to assist in law enforcement (such as to a police force). We will also disclose your information if you give your consent. 

Disclosure of personal info to third parties

We may disclose your personal information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:  

• our third party service providers (for example, our IT providers);  
• our marketing providers;  
• our professional services advisers;  

Jessica Brady employees, partners and third-party providers who are given access to your personal information in order to perform their function, are legally required to maintain the confidentiality of your personal information. 

Jessica Brady has established a small number of third-party relationships to help support our services and therefore are required to host some electronic data. Some data will be transferred to off-shore locations, but all sensitive financial data is hosted only in Australia as required by law. In addition, personal information may need to be transferred to service providers located in the US and other overseas countries from time to time in order for Jessica Brady to perform its functions or activities. Before using those service providers, we review their data security policies to ensure that they have adequate measures in place to protect your personal information. 

Transfer of personal information overseas

Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia, including but not limited to United States, & Philippines. Details of the countries we disclose to you may change from time to time. You can contact us for further details regarding where we may send your personal information. 

Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained.  

We will only disclose to overseas third parties if:  

• you have given us your consent to disclose personal information to that third party; or 
• we reasonably believe that:  
  • the overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the APPs; and  
  • the law or binding scheme can be enforced; or  
• the disclosure is required or authorised by an Australian law or court / tribunal order. 

How do we protect your personal information?

Jessica Brady will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:  

• having a robust physical security of our premises and databases / records;  
• taking measures to restrict access to only personnel who need that personal information to effectively provide services to you;  
• having technological measures in place (for example, anti-virus software, fire walls) 

Risks of using the internet

You should note that there are inherent security risks in transmitting information through the internet. You should assess these potential risks when deciding whether to use online services. If you do not wish to transmit information via email or through our website, there are other ways in which you can provide this information to us. You can, for example, call us or send us information by post. 

Data Breach Notification

If Jessica Brady becomes known of a data breach, we will provide a Statement to the Commissioner notifying of the occurrence of the breach. If the breach is likely to result in serious harm or risk to a user’s rights and freedoms, the effected users will be notified as soon practicable. We will also notify Jessica Brady’s licence Paragem Pty Ltd of the breach. 

Cookies

The Jessica Brady website uses cookies. A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our websites before, so we can distinguish you from other users of the website. 

This improves your experience and the Jessica Brady websites. We do not use cookies to identify you, just to improve your experience on our websites. If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected. 

Website analytics

Our website uses Google analytics to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.  

Direct Marketing

We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.  

You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe'' set out in the relevant communication/ contacting us using the details set out in the “How to contact us” section below.  

In addition, we may also use your personal information or disclose your personal information to third parties for the purposes of advertising, including online behavioural advertising, website personalisation, and to provide targeted or retargeted advertising & research content to you (including through third party websites). 

Retention of personal information

We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations. 

How to access, correct or destroy your personal information

Jessica Brady will endeavour to keep your personal information accurate, complete and up to date. If you wish to make a request to access and / or correct the personal information we hold about you, you should make a request by contacting us and we will usually respond within 2 days. We will deal with such a request by following the procedure outlined below: 

• Right to amend or erase Personal Information  

You have the right to request, in writing to Jessica Brady, to have your personal data destroyed. This may be, but is not limited to, circumstances where your personal information is no longer required for its permitted purpose, or if you withdraw your consent. If Jessica Brady is required to destroy your information, we will ensure that any links, copies or replications of your information are also destroyed.  

Please note, Jessica Brady reserves the right to not destroy your data or information if it is necessary, in the circumstances, to exercise their right of freedom of expression and information or if it is required in order to maintain Jessica Brady’s Financial Services compliance requirements.  

To affect this right, you can request us to have your data deleted by writing to us. 

Links to third party sites

Jessica Brady websites may contain links to websites operated by third parties. If you access a third party website through our websites, personal information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies. 

Enquiries & Complaints

For complaints about how Jessica Brady handles, processes or manages your personal information, please contact [email protected]  

Note we may require proof of your identity and full details of your request before we can process your complaint. Please allow up to 24 hours or 1 business day for Jessica Brady to respond to your complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with Jessica Brady’s response to a complaint, you have the right to contact the Office of Australian Information Commissioner (at www.oaic.gov.au/) to lodge a complaint. 

You may also lodge a complaint to the Australian Financial Complaints Authority (AFCA) Phone: 1800 931 678 or https://www.afca.org.au/make-a-complaint  

How to contact us

If you have a question or concern in relation to our handling of your personal information or this Policy, you can contact us for assistance as follows:  See Privacy Officer details

Privacy Officer details

Email: [email protected]    

Contact number: 0411 575 341 

Postal Address:   

Attn: Jessica Brady

PO Box 594 Surry Hills NSW 2010

Updates of this policy 

This policy is effective as of 6 January 2023, we will update this policy as and when required and will post the updated policy on our website. Your continue use of this site provides your consent. If you like we can contact us to send you a copy.  

General advice, swearing & discomfort disclaimer

• I swear, you will hear swear words. If this upsets or offends you, I am not your gal.
• All of my courses, workbooks and community calls contain general advice and factual information only. Nothing will take into account your objectives, financial situation or needs. Before acting on any information in this presentation, you should consider the appropriateness of the information having regard to your objectives, financial situation and needs. 
• Before making a decision about a specific financial product, you should consider the Product Disclosure Statement (PDS). We also recommend speaking to a financial adviser should you need one. 
• I am also known as Jessica Gerken. Long story, not very interesting. Anyway, I am a qualified financial adviser and an authorised representative (no 1259972) of Paragem Pty Ltd (AFS Licence no 297276).