Privacy Policy

Hawk Trading Education Pty Limited (ABN 53 651 107 158) ("Hawk", "we", "us", "our") is committed to protecting your personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the "Privacy Act"). This Privacy Policy explains what personal information we collect, why we collect it, how we use, store, and disclose it, and how you can access, correct, or complain about the handling of your information.

This Privacy Policy applies to hawktradingeducation.com and to all related services Hawk provides, including enquiry forms and our Discord community gateway (The Campus).

Hawk is a Brisbane, Queensland based financial technology education company. Hawk does not hold an Australian Financial Services Licence and does not provide financial advice. This Privacy Policy concerns the handling of personal information only and should be read alongside our Terms of Business, Risk Disclosure, and Financial Services Disclaimer.

We collect personal information that is reasonably necessary for our business functions and activities, including:

• Contact and enquiry information - name, email address, phone number, and any message content submitted via our general enquiry form or the Innovation Centre B2B enquiry form.
• Business and regulatory information (B2B partners only) - company name, regulatory body and licence number, jurisdiction, and client base description, submitted as part of the Introducing Broker due diligence process.
• Community application information (The Campus) - name, email address, and trading background submitted via the expression of interest form, and information provided through our Discord server once access is granted.
• Technical and usage information - IP address, browser type, device information, pages visited, and referral source, collected automatically via Google Analytics 4 and Cloudflare.

We do not collect financial account information, trading account credentials, or brokerage data. Hawk does not have access to your trading account, broker login, or funds at any time.

We collect personal information directly from you when you:

• Submit an enquiry form, contact form, or expression of interest form on our website
• Apply for or participate in The Campus community via Discord
• Engage with us as a prospective or current Introducing Broker Partner
• Correspond with us by email or phone

We also collect information automatically through cookies and similar technologies when you visit our website. Full detail on cookies is set out in our separate Cookie Policy, which forms part of our privacy practices.

Where practicable, we collect personal information only directly from you. Where we collect information from a third party (for example, where an Introducing Broker Partner provides client base information in aggregate, non-identifying form), we will take reasonable steps to ensure you are aware of the collection.

We collect, hold, use, and disclose personal information for the following purposes:

• To respond to enquiries and provide requested information about our educational content and services
• To assess and progress Introducing Broker partnership applications, including due diligence
• To process applications for and administer membership of The Campus community
• To send service related communications, including responses to enquiries
• To improve our website and services through aggregated, de-identified analytics
• To comply with our legal and regulatory obligations
• To detect, investigate, and prevent fraudulent or unauthorised activity

We do not use personal information for direct marketing without consent, and you may opt out of any marketing communications at any time by contacting us.

Hawk operates a proprietary automated trade execution system (the "Automated Trade Execution Bridge") that delivers trading signals from the Hawk Divitiae Strategy to the funded master accounts of regulated Introducing Broker Partners. This system does not process, use, or make decisions based on the personal information of website visitors, retail traders, or any individual outside of our direct B2B partner relationships, and it does not affect your access to or use of this website.

Where automated systems are used in connection with B2B partner onboarding or due diligence assessment, a human decision maker reviews and approves all material outcomes. Hawk does not use fully automated decision making that produces legal or similarly significant effects concerning an individual without human review.

We will update this section as required to remain consistent with the Privacy Act's automated decision making transparency requirements as they take effect.

We may disclose personal information to:

• Third party service providers who assist us in operating our website and business, including Cloudflare (hosting and security), Google Analytics 4 (website analytics), and Discord (community platform). Each provider processes personal information under its own privacy policy and only to the extent necessary to provide its service to us.
• Regulated Introducing Broker Partners, but only in the context of partnership due diligence, and only with the consent of the individual or entity concerned.
• Professional advisers, including our legal, accounting, and compliance advisers, where reasonably necessary.
• Regulatory and law enforcement bodies, where required or authorised by law.

We do not sell personal information to third parties under any circumstances.

Some of our third party service providers (including Cloudflare, Google Analytics 4, and Discord) store or process data on servers located outside Australia, including in the United States. Where personal information is disclosed to overseas recipients, we take reasonable steps to ensure those recipients handle personal information consistently with the Australian Privacy Principles, including by relying on the data processing terms and security commitments of established global providers.

By using our website and services, you acknowledge that your personal information may be processed outside Australia as described above.

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure, including:

• Encryption of all data in transit via HTTPS (Cloudflare SSL, Full (Strict) mode)
• Limiting access to personal information internally to personnel who require it for legitimate business purposes
• Regular review of third party service provider security practices

No method of transmission or storage is completely secure. While we take reasonable steps to protect personal information, we cannot guarantee absolute security.

In the event of a data breach involving personal information that is likely to result in serious harm, Hawk will comply with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth). This includes:

• Promptly investigating any suspected or actual data breach
• Taking immediate steps to contain the breach and mitigate harm
• Assessing whether the breach meets the threshold of an "eligible data breach"
• Notifying the Office of the Australian Information Commissioner (OAIC) and affected individuals as soon as practicable where an eligible data breach has occurred
• Providing affected individuals with recommendations on steps they can take in response

We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, or as required by law. Enquiry and application data that does not result in an ongoing relationship is retained for a reasonable period to allow for follow-up, after which it is securely deleted or de-identified. We will take reasonable steps to destroy or de-identify personal information once it is no longer needed for any purpose permitted under the Privacy Act.

You may request access to the personal information we hold about you, and request that we correct any information that is inaccurate, out of date, incomplete, irrelevant, or misleading. To make a request, contact us using the details in Section 13. We will respond within a reasonable period, generally within 30 days. We may need to verify your identity before processing a request. In some circumstances permitted by the Privacy Act, we may decline a request for access or correction, and if so, we will provide reasons.

If you believe we have breached the Australian Privacy Principles or mishandled your personal information, you may lodge a complaint with us using the details in Section 13. We will acknowledge your complaint promptly and aim to resolve it within a reasonable period.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992

For questions about this Privacy Policy, or to make a request or complaint regarding your personal information, contact:

Hawk Trading Education Pty Limited
Level 1, 470 St Pauls Terrace, Brisbane, Queensland 4006, Australia
Email: contact@hawktradingeducation.com

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to review this policy periodically.