Privacy Policy

Last updated: 01 January 2022

2022 FWD Focus (“the”, “us”, “we”, or “our”) operates the website:

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.

We will not use or share your information with anyone except as described in this Privacy Policy.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at

If you need to get into contact with us, please refer to our Contact Us page on our website.


1. Information Collection and Use

 1.1 While using our Service, we may ask you to provide us with certain personallyidentifiable information that can be used to contact or identify you. Personally,identifiable information may include, but is not limited to, your email address, name,phone number, postal address and date of birth (“Personal Information”).

1.2 The purpose for which we collect personal information is to provide you with thebest service experience possible on the Service and for our internal businesspurposes that form part of normal business practices. Some provision of personalinformation is optional. However, if you do not provide us with certain types ofpersonal information, you may be unable to enjoy the full functionality of the Service.

1.3 Your personal information may be used for the purposes of sending newsletterscommunications due to the subject matter of the website.


2. Log Data

 2.1 We may also collect information that your browser sends whenever you visit ourService (“Log Data”). This Log Data may include information such as your computer’sInternet Protocol (“IP”) address, browser type, browser version, the pages of ourService that you visit, the time and date of your visit, the time spent on those pagesand other statistics.

2.2 In addition, we may use third-party services, that collect, monitor and analyse thistype of information in order to increase our Service’s functionality.

2.3 These third parties may use cookies to help us analyse how our users are usingthe Service and they have their own Privacy Policies addressing how they use suchinformation.


3. Service Providers

3.1 We may employ third-party companies and individuals to facilitate our Service, tothe Service on our behalf, to perform Service-related services or to assist us inanalysing how our Service is used.

3.2 These third parties have access to your Personal Information only to performthese tasks on our behalf and are obligated not to disclose or use it for any otherpurpose. 


4. Communications

4.1 We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

5. Compliance with Laws

5.1 We may disclose personal information in special situations where we havereason to believe that doing so is necessary to identify, contact or bring legal actionagainst anyone damaging, injuring or interfering (intentionally or unintentionally) withour rights or property, users or anyone else who could be harmed by such activities.We will disclose your Personal Information where required to do so by law orsubpoena or if we believe that such action is necessary to comply with the law andthe reasonable requests of law enforcement or to protect the security or integrity ofour Service.


6. Security

6.1 The security of your Personal Information is important to us but remember that nomethod of transmission over the Internet, or method of electronic storage is 100%secure. While we strive to use commercially acceptable means to protect yourPersonal Information, we cannot guarantee its absolute security.

7. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

7.1 If you are a resident of the European Economic Area (EEA), you have certain data protection rights. FWD Focus aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.7.2 If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.7.3 In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have onyou. Whenever made possible, you can access, update or request deletionof your Personal Data directly within your account settings section. If youare unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your informationrectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of yourPersonal Data.


8. International Transfer

8.1 Your information, including Personal Information, may be transferred to andmaintained on computers located outside of your state, province, country or othergovernmental jurisdiction where the data protection laws may differ than those fromyour jurisdiction.

8.2 If you are located outside Australia and choose to provide information to us,please note that we transfer the information, including Personal Information, toAustralia and process it there.

8.3 There may be an instance where work may be done overseas. In suchcircumstance, we shall expressly inform you and that your consent may be collectedvoluntarily. We note that there are exceptions under Australian Privacy Principles(APPs) where your consent is unnecessary.

8.4 Your consent to this Privacy Policy followed by your submission of suchinformation represents your agreement that your Personal Information will be used ordisclosed for the purpose for which it was collected.


9. Access and Correction

9.1 Australian Privacy Principle 1 of the Privacy Act 1988 (Cth) allows you to getaccess to, and correct, the personal information we hold about you in certaincircumstances. If you would like to obtain such access, please contact us on theemail address set out above.
9.2 Please note that the access and correction requirements under this PrivacyPolicy operates alongside and do not replace other informal or legal procedures bywhich an individual can be provided access to, or correction of, their personalinformation, including the requirements under the Freedom of Information Act 1982(Cth).

10. Complaints

10.1 Australian Privacy Principle 1 of the Privacy Act 1988 (Cth) allows you to makea complaint about any alleged breaches of privacy. In order to lodge a complaint withus, please contact us using the email address above with the following information:

  • Your name and address;
  • Details of the alleged breach of privacy; and
  • URL link to the alleged breach of privacy (if applicable).

10.2 Please allow us 30 days to investigate your complaint, after which we will contact you immediately to resolve the issue.


11. Retention of Information

11.1 We retain information for as long as required, allowed or we believe it useful, butdo not undertake retention obligations. We may dispose of information in ourdiscretion without notice, subject to applicable law that specifically requires thehandling or retention of information. You must keep your own, separate back-uprecords.


12. Links to Other Sites

12.1 Our Service may contain links to other sites that are not operated by us. If youclick on a third-party link, you will be directed to that third-party’s site. We stronglyadvise you to review the Privacy Policy of every site you visit.
12.2 We have no control over, and assume no responsibility for the content, privacypolicies or practices of any third-party sites or services.

13. Children’s Privacy

13.1 Our Service does not address anyone under the age of 18 (“Children”).
13.2 We do not knowingly collect personally identifiable information from childrenunder 18. If you are a parent or guardian and you are aware that your Children haveprovided us with Personal Information, please contact us. If we become aware thatwe have collected Personal Information from children under 18 without verification ofparental consent, we take steps to remove that information from our servers orreplace it with the Personal Information of the Children’s parent or guardian.

14. Changes to This Privacy Policy

14.1 We may update our Privacy Policy from time to time. We will notify you of anychanges by posting the new Privacy Policy on this page.
14.2 You are advised to review this Privacy Policy periodically for any changes.Changes to this Privacy Policy are effective when they are posted on this page.
14.3 If we make any material changes to this Privacy Policy, we will notify you eitherthrough the email address you have provided us, or by placing a prominent notice onour website.


15. Consent

15.1 You warrant that you are able to give consents under Australian Law or, in theevent that you do not have the capacity to give consent, you warrant that yourguardian or attorney is able to give any consent required under this Privacy Policy onyour behalf.
15.2 You hereby expressly and voluntarily grant your informed consent to us to deal with your personal information in accordance with the terms and conditions of this Privacy Policy. Should you retract your consent, please contact us. If you retract your consent, you acknowledge and agree that failure to provide certain types of personal information may not give you access to the full functionality of the Service.

16. Contact Us

16.1 If you have any questions about this Privacy Policy, please contact us via the Contact Us page on our website.