Privacy Policy
SFDS Pty Ltd and its Authorised Representatives, trading as Solace Financial
Version: October 2026 · Replaces the policy dated 8 November 2021
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About this policy
This Privacy Policy explains how SFDS Pty Ltd (ABN 69 626 587 817, AFSL 509493) and its Corporate Authorised Representatives collect, hold, use and disclose your personal information. The Corporate Authorised Representatives are Quinlan Holdings Pty Ltd, Solace Financial Group Pty Ltd and Stratford Planning Group Pty Ltd, all trading as Solace Financial. In this policy, “we”, “us” and “our” means all of them.
We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). “Personal information” means information about you as an identifiable individual. This policy also tells you how to access or correct your information and how to make a complaint.
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What personal information we collect
To give you financial advice we need to understand your whole financial position. The kinds of personal information we collect depend on the services you ask for. They include:
- your name, date of birth, address, email, phone number and other contact details;
- your employment, income, expenses, assets, liabilities, superannuation, investments, insurance and estate planning arrangements;
- your goals, objectives, family circumstances and attitude to risk;
- your Tax File Number, where we need it to provide our services;
- identification documents and details (for example a driver’s licence or passport) where we need to verify your identity;
- information about your dependants, beneficiaries or other people you ask us to consider in your advice;
- notes of our meetings and calls with you, and copies of our correspondence;
- any other information you give us, or that we reasonably need, to provide our services and meet our legal obligations.
SENSITIVE INFORMATION
Some of this information is “sensitive information” under the Privacy Act, such as health information we need for personal insurance advice. We only collect sensitive information with your consent and when it is reasonably necessary for the services we provide.
TAX FILE NUMBERS
We handle your Tax File Number in line with the Privacy (Tax File Number) Rule 2015. We only collect it where the law allows (for example to quote on superannuation and investment applications or to search for lost super), we only disclose it to the product provider concerned, and we never include it in AI tools or in unencrypted email.
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How we collect it
We usually collect information directly from you: in meetings, by phone, video call and email, and through our fact find, application forms, website forms and client portals. With your consent we may also collect information from third parties such as product and platform providers, super funds, insurers, banks, your accountant, solicitor or other advisers, and government agencies.
If you don’t give us the information we ask for, we may not be able to give you appropriate advice or implement our recommendations. You can contact us anonymously or under a pseudonym for general enquiries. We must identify you before we provide personal advice or arrange financial products.
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How we use it
We use your personal information to:
- understand your circumstances and prepare, present and review our advice (including Statements and Records of Advice);
- arrange, implement and manage financial products on your behalf;
- provide our ongoing service and manage our relationship with you;
- verify your identity and meet our legal obligations, including under the Corporations Act, tax and superannuation laws and the Anti-Money Laundering and Counter-Terrorism Financing Act;
- manage complaints, insurance claims and legal proceedings, including with our professional indemnity insurer and lawyers;
- run our business: record keeping, quality assurance, compliance monitoring, complaint handling, training and internal reporting. For business reporting we use aggregated or de-identified information wherever possible.
DIRECT MARKETING
We may send you newsletters, updates, event invitations or information about our services. You can opt out at any time by using the unsubscribe link or by contacting us. We never sell, trade or rent your personal information.
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How we use technology and artificial intelligence
We use secure software to help prepare and manage your advice. This includes client relationship management and financial planning software, cloud document storage, email and productivity tools, and artificial intelligence (AI) tools.
AI-assisted preparation. Our advisers and support staff may use AI tools to help summarise information you give us, draft sections of advice documents, and prepare meeting notes and correspondence. The AI tools we currently use include Microsoft Copilot (including Copilot within Microsoft 365, which may route some requests to Claude, an AI model provided by Anthropic) and Claude, provided directly by Anthropic. We may adopt other AI tools in future once our licensee has approved them, and we will update this policy when we do. Our use of AI is governed by our licensee’s AI Usage Standard. When we use AI tools:
- your adviser reviews, checks and takes responsibility for every document before it is given to you;
- we only use AI tools approved by our licensee, and never free consumer chatbots;
- we only use business versions of these tools, under contracts that stop the provider using your information to train its AI models;
- we do not enter your Tax File Number, identity documents, account numbers or passwords into AI tools;
- we only include health information in AI-assisted drafting where you have consented to us using AI tools;
- we take reasonable steps to make sure information produced with AI tools is accurate, complete and up to date before we rely on it;
- we record in your file when AI has helped prepare your advice.
MEETING NOTES AND RECORDINGS
With your agreement, we may use Microsoft Teams to transcribe or record our meetings and calls with you, and use AI to prepare a file note from the transcript. We will tell you at the start of the meeting and you can ask us not to. The transcript and file note are stored in our Microsoft 365 environment with the rest of your file.
AUTOMATED DECISIONS
We do not make any decision about you using a computer program alone. All advice, recommendations and decisions about your affairs are made by a qualified adviser.
Some computer programs do substantially assist our advisers’ decisions. Financial modelling software and AI tools use the information described in section 2 (in particular your financial position, goals and, for insurance advice, health information) to produce cashflow and retirement projections, superannuation and insurance needs calculations, product and portfolio comparisons, and draft advice documents. Your adviser reviews these outputs and decides what to recommend to you. Decisions assisted in this way include the strategies and products we recommend, the level of insurance cover we suggest, and the fees we quote.
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Who we share it with
We may disclose your personal information to:
- SFDS Pty Ltd as our licensee, and its compliance and audit providers;
- product issuers, platforms, super funds, fund managers, insurers and banks, when we arrange or manage products for you;
- other professionals you ask us to work with, such as your accountant, solicitor or mortgage broker (with your consent);
- our service providers, including financial planning and CRM software providers (currently Morningstar’s AdviserLogic), Microsoft 365, business reporting providers, paraplanning and administration support (including offshore staff, see section 7), IT support, cloud storage and AI providers, electronic signing, mailing and archiving services;
- our professional indemnity insurer, lawyers, auditors and external compliance consultants;
- government and regulatory bodies, such as the ATO, Services Australia (Centrelink), the Department of Veterans’ Affairs, ASIC, AUSTRAC, and the Australian Financial Complaints Authority (AFCA);
- a purchaser or its advisers if our business, or part of it, is sold or restructured;
- anyone else where the law requires or allows it.
We require our service providers to keep your information confidential and to use it only to provide services to us.
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Disclosure overseas
Some of our service providers store or process information outside Australia, or have staff who access it from overseas. Your personal information is likely to be disclosed to recipients in the following countries:
- United States – AI and cloud service providers, currently including Anthropic (Claude, whether used directly or through Microsoft Copilot). Their data may also be processed in other countries where they or their partners operate;
- Philippines – our offshore administrative assistant, engaged through YVP Limited (a Hong Kong company, trading as Your Virtual People), who accesses our systems remotely from the Philippines.
Our Microsoft 365 environment (email, documents, Teams and Copilot) is hosted in Australian data centres, although some Microsoft services and AI features may process information in other countries. Other software and cloud providers may also store or back up information overseas. Where practical, we choose providers that store data in Australia.
Before disclosing information overseas, we take reasonable steps to make sure the recipient protects it to a standard consistent with the APPs. We do this through written contracts covering confidentiality, security, permitted use and return or destruction of data, and by reviewing the provider’s security certifications. We remain accountable for how these recipients handle your information.
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How we store and protect it
We hold information electronically, in secure cloud-based systems in Australia and overseas (see section 7), and in paper files at our office. We protect it with measures including access controls, multi-factor authentication, encryption in transit and at rest, antivirus and monitoring, secure backups, staff training and confidentiality obligations, and physical security at our premises.
We keep advice records for at least seven years after we stop providing services to you, as the law requires. When we no longer need information, we destroy or de-identify it securely. We keep the identification details we are required to hold under anti-money laundering laws for seven years, but we keep copies of identity documents only where necessary and, where we can, record the details we need instead.
We review our security and destruction practices regularly, including the security standards of the providers and offshore staff we use, and we require our staff and contractors to complete privacy and security training.
If we suspect a data breach, we will assess it promptly. If it is likely to cause you serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as soon as practicable under the Notifiable Data Breaches scheme.
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Our website
When you use our website forms, calculators or newsletter sign-up, we collect the details you enter (such as your name, email, phone number and message) to respond to you. We use cookies and analytics tools (such as Google Analytics) to understand how our website is used; this information does not usually identify you and may be processed by the analytics provider overseas. You can disable cookies in your browser. Our website links to other sites (for example platform logins), and we are not responsible for their privacy practices.
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Accessing and correcting your information
You can ask to see the personal information we hold about you, or ask us to correct it, at any time. We may need to verify your identity first. We will respond within 30 days and there is no charge for the request. If we refuse access or correction (only in limited circumstances allowed by law), we will tell you why in writing and how you can complain. If we correct information we have already given to a third party, we will tell them too where you ask us to and it is practical.
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Complaints
If you think we have breached the Privacy Act or this policy, please contact our Privacy Officer first. We will acknowledge your complaint within one business day and aim to resolve it within 30 days.
If you are not satisfied with our response, you can contact:
- Australian Financial Complaints Authority (AFCA) – www.afca.org.au · 1800 931 678 · [email protected] · GPO Box 3, Melbourne VIC 3001
- Office of the Australian Information Commissioner (OAIC) – www.oaic.gov.au · 1300 363 992
- Contact our Privacy Officer
Scott Quinlan, Privacy Officer, SFDS Pty Ltd
Email: [email protected] · Phone: 07 3106 3106 · Post: GPO Box 980, Brisbane QLD 4001
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Your consent
We ask for your consent to overseas disclosure and to the use of AI tools when you engage us, in our Letter of Initial Engagement and client fact find. You can tell us at any time if you would prefer we don’t use AI tools or offshore staff in preparing your advice. We will respect that choice, and your fee will not change.
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Changes to this policy
We review this policy at least once a year and whenever our practices change. The current version is always available at www.solacefinancial.com.au, and we will give you a free copy on request.
