Privacy & Security

Cleva & The Cleva Co Pty Ltd (ABN 77 630 503 285) is a Corporate Authorised Representative (CAR No. 123456) of Wealth Trail Pty Ltd (ACN 634 620 956) (AFSL xxxxxx). Any financial product advice contained is general in nature and has been prepared without taking into account your objectives, financial situation or needs – even if these may have been provided to us. You should consider if the information is appropriate and whether you need to speak to an accredited professional. We have accredited professionals available or you may seek out your own. Where we provide personalised financial advice taking into account your objectives, financial situation or needs this will be clearly labelled as Personal Financial Advice and provided to you in a document labelled Statement of Advice. For the sake of eliminating confusion if advice is not documented in a Statement of Advice it is intended to be general in nature. Once you are registered we will email a copy of our Financial Services Guide (FSG) to the email address provided and save a copy in your Coach tab under Advice. If you have any questions or concerns you may contact us via email at [email protected] Cleva is committed to ensuring the confidentiality and security of your personal information. This policy provides a summary of the type of personal information collected and held by Cleva, as well as how we disclose this information when required, and your rights regarding your personal information. Cleva acts in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth)

 

What is personal information?

The definition of personal information under the Privacy Act 1988 is information or an opinion about an identified individual, or an individual who can be reasonably identified.

 

Personal information we collect

To provide you with services related to Cleva and to comply with our legal obligations, we collect a number of pieces of information that would be classified as personal. They include your name, address, email address, telephone number, date of birth, tax file number and other financial details.

To continuously enhance the user experience of our products, we may also collect data related to the use of our website and platform, including your IP address and the dates and times of your visits.

 

How we collect your personal information?

There are a number of ways Cleva collects personal information. They include when you submit information to us via our app, register an account and retrieve log-in information, and request a new password. If you participate in promotions and market research programs run by Cleva, we may also collect personal information from you then.

When you join Cleva we will collect personal information from you during the online discovery process. Similar information may also be collected by our coaches for the purposes of providing services to you.

You may join Cleva via an affiliate or partner, in this case we may receive or request your personal data need to join from them with your consent to complete the joining process. You may also provide us with information stored by third party sites, such as social media networks. By linking an account managed by a third party to your Cleva account, you are authorising Cleva to access the information made available, for the purposes of providing you with our services.

 

How do we hold this personal information?

We take all reasonable steps to protect and keep secure any personal information we hold about you. Your information is stored securely. We require employees who are given access to your personal information in order to perform their function to maintain the confidentiality of your personal information. We have security measures in place to protect your personal information, such as restricted access to our offices and restricted access to our technology. This includes but is not limited to, user defined access permissions, firewalls, encryption of data transfer at all times, user logons, passwords and digital certificates. Cleva may engage third parties to host electronic data (including data in relation to the services we provide) on our behalf. These data warehouses are primarily located in Australia. 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 Cleva 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.

 

Data breaches

Cleva must report certain data breaches to the Office of the Australian Information Commissioner (OAIC) and where required, the impacted members.

How do we use and disclose this personal information?

Any use or disclosure of your personal information is done in accordance with Privacy Laws and this Privacy Policy.

The primary use of your personal information is to provide you with services from Cleva. This means we may share your personal information with:

suppliers who are contracted by us to perform services on our behalf, such as administration services, trustee services, custodial services, security and fraud protection services, the Australian Tax Office, marketing services and technology services.
financial institutions that we may partner with to provide services, or additional products and offerings
If required or authorised by law, Cleva will also disclose your personal information to law enforcement, government agencies or officials.

 

Remarketing

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 remarketing services to advertise to you in search engines or on social networks. Any data collected through these advertising platforms will be used in accordance with our 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 can you access & correct personal information we hold?

If you would like to know what personal information we hold about you, please send your request to [email protected] We will respond to your request within 21 days. If you would like to change any personal information that we hold about you because it is inaccurate or out of date, you can update your information inside your Cleva account online. You can also contact us at [email protected] for assistance if required or speak to a coach within the platform.

If you would like your personal information deleted we will action your request provided we are legally allowed to do so.

It is important you are aware in some instances, we may not be able to allow you access to your personal information. This is mainly related to legal reasons, and if we are unable to action your request, we will explain why and what your next steps may be, if you are not satisfied with our response.

 

Changes to this policy

Our Privacy Policy may change at any time, and we will notify you by posting an updated version on our website. The version of the privacy policy that will apply to you is the one that was published at the time your personal information was collected.

 

How to contact us

If you would like to raise a concern or make a complaint about how your personal information is handled, or if you have specific questions about this policy, we ask that you please firstly contact us using the details below:

ATTN: Privacy Compliance Officer
The Cleva Co Pty Ltd
Victoria, 3165

If you are not satisfied with the resolution of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au.