This Policy is written in simple language. The specific legal obligations of Coach’s Companion when collecting and handling your personal information are outlined in the Privacy Act 1988 (“Privacy Act”) and in particular in the Australian Privacy Principles found in that Act.
We may revise this Policy from time to time by updating this document. The revised Policy will take effect when it is posted on our website or distributed through our email lists.
Coach’s Companion collects, holds, uses and discloses personal information to carry out Coach’s Companion activities, services and functions under the Privacy Act 1988.
These functions, services or activities include, but are not limited to the provision of a cloud technology platform that allows “you”, “your”, “user”, “registered user” to:
- Create and manage learning, personal development, career and messaging information.
- Register and maintain your email address, password and user profile.
- Upload, download and delete documents against your user profile.
- De-activate your user profile.
- Establish and maintain your privacy settings.
Coach’s Companion also collects personal information through our website and social networking services such as Facebook, Instagram, Linkedin and Twitter. Coach’s Companion uses this information to improve our website and to receive feedback from the community.
WHAT IS PERSONAL INFORMATION?
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- Whether the information or opinion is true or not; and
- Whether the information or opinion is recorded in a material form or not.
The types of personal information we collect may include, but is not limited to your name, date of birth, gender, contact information, or your relationship with Coach’s Companion.
WHOSE PERSONAL INFORMATION DO WE COLLECT?
We collect personal information from people who are connected to Coach’s Companion’s operations and activities – including, but not limited to employees, clients and service providers.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Where possible, we will collect your personal information directly from you. This may be in person (for example, where you attend a meeting or an event), on the telephone or via email (for example, if you contact Coach’s Companion by phone or email) or online via our website www.coachsompanion.com.
We also obtain personal information from third parties such as contractors and list vendors. If we collect personal information about you from a third party and it is unclear that you have consented to the disclosure of your personal information to us, we will take reasonable steps to contact you and ensure that you are aware of the circumstances surrounding the collection and purposes for which we collected your personal information.
WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
We may collect your personal information for a number of purposes, including, but not limited to:
- Marketing: Communicate with you about our products, services, campaigns and events.
- Support: Provide you with information and support services, and to report on these services and
- Other: Communicate with you in relation to our operations, activities and objectives, to verify your identity, to improve and evaluate our programs and services and to comply with relevant laws.
Where we collect your personal information for a specific purpose not outlined above, we will endeavor to provide you with a collection notice which explains the primary purpose and any related secondary purposes for which we are collecting your personal information.
OTHER SENSITIVE INFORMATION
As part of administering our services, we may collect other information and other sensitive information. Sensitive information includes the following type of information: racial or ethnic origin; political opinions; membership of a political association; religious beliefs or associations; philosophical beliefs; memberships; sexual orientation; genetic information; biometric information; biometric templates. We will limit the collection of sensitive information to the minimum amount required to perform our services.
WHAT HAPPENS IF YOU DON’T PROVIDE ALL THIS INFORMATION?
If you do not provide some or all of the personal information requested, we may not be able to offer you our services or provide you with information about our causes, events, programs, projects or products.
USING A PSEUDONYM OR ENGAGING WITH US ANONYMOUSLY
Where practicable, you will be given the opportunity to engage with us on an anonymous basis, or using a pseudonym.
WEBSITE USAGE INFORMATION AND HTTP COOKIE
A HTTP Cookie does not identify individuals personally, but it does identify computers. You can set your browser to notify you when you receive a HTTP Cookie and this will provide you with an opportunity to either accept or reject it in each instance.
We may gather your IP address as part of our business activities and to assist with any operational difficulties or issues with our services. This information does not identify you personally.
OPTING OUT OF DIRECT MARKETING COMMUNICATIONS
Where we use your personal information to send you marketing and promotional information by for example post, email or telephone, we will provide you with an opportunity to opt-out of receiving such information. By electing not to opt-out, we will assume we have your implied consent to receive similar information and communications in the future. We will always ensure that our opt-out notices are clear, conspicuous and easy to initiate.
TO WHO DOES COACH’S COMPANION DISCLOSE YOUR PERSONAL INFORMATION TO?
We may need to disclose your personal information to other parties or associated group companies in order to carry out our activities. This may include:
- Business Providers: Professionals and/or businesses that provide support services to us.
- Researchers: To conduct research.
- Third Parties for Marketing: We may provide your contact details to contact you with information that may be of interest to you. From time to time, we may participate in data collectives where we share your personal information (other than sensitive information) with other organisations.
- Contractors and Service Providers: Who perform services on our behalf, such as mailing houses, printers, information technology services providers (including offshore cloud hosting/ computing service providers), database contractors and telemarketing agencies.
Wherever we propose to disclose your personal information to a third party not outlined above, we will endeavor to provide you with a collection notice which explains the circumstances in which we might disclose your personal information.
CROSS-BORDER DISCLOSURES OF YOUR INFORMATION
We use cloud data hosting facilities and third party service providers to assist us with providing our goods and services. As a result, your personal information may be transferred to, and stored at, a destination outside Australia, including but not limited to New Zealand, Netherlands, China, Singapore, Hong Kong, Ireland, Canada, United States of America and the United Kingdom.
Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents or partners. We take such steps as are necessary in the circumstances to ensure that any overseas third-party service providers we engage are aware of the Privacy Act and Australian Privacy Principles, including through contractual arrangements where this is possible.
If your personal information is collected using our services, you have as a result consented to the disclosure, transfer, storing or processing of your personal information outside of Australia. You also acknowledge and understand that by providing such consent that we will not be required to take such steps as are reasonable in the circumstances to ensure such third parties comply with the Privacy Act and the Australian Privacy Principles.
WHERE IS YOUR PERSONAL INFORMATION STORED?
We take reasonable steps to protect all of the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. Your personal information will be stored on a password protected electronic database, which may be on our database, a database maintained by a cloud hosting service provider or other third party database storage or server provider. Backups of electronic information are written to drives which are stored with our hosting partner of choice.
Hard copy information is generally stored in our office(s), which are secured to prevent entry by unauthorised people. Any personal information not actively being used is archived, usually after 7 years, with a third party provider of secure archiving services.
Where personal information is stored with a third party, we have arrangements which require those third parties to maintain the security of the information. We take reasonable steps to protect the privacy and security of that information, but we are not liable for any unauthorised access or use of that information. Your personal information will stay on the database indefinitely until you advise you would like it removed, unless we de-identify it or destroy it earlier in accordance with privacy law requirements.
ACCESS TO YOUR PERSONAL INFORMATION
We will, upon your written request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we request that you identify, as clearly as possible, the type(s) of information requested.
We will deal with your request in writing to provide access to your personal information within 30 days and you agree we may charge you our reasonable costs incurred in supplying you with access to this information.
Your rights to access personal information are not absolute and privacy laws dictate that we are not required to grant access in certain circumstances such as where:
- Access would pose a serious threat to the life, safety or health of any individual or to public health or public safety.
- Access would have an unreasonable impact on the privacy of other individuals.
- The request is frivolous or vexatious.
- Denying access is required or authorised by a law or a court or tribunal order.
- Access would be unlawful, or
- Access may prejudice commercial negotiations, legal proceedings, enforcement activities or appropriate action being taken in respect of a suspected unlawful activity or serious misconduct.
If we refuse to grant you access to your personal information, we will provide you with reasons for that decision (unless it is unreasonable to do so) and the avenues available for you to complain about the refusal.
UPDATING YOUR PERSONAL INFORMATION
You may ask us to update, correct or delete the personal information we hold about you at any time. We will take reasonable steps to verify your identity before granting access or making any corrections to or deletion of your information.
We have obligations to take reasonable steps to correct the personal information we hold when we are satisfied that it is inaccurate, out- of-date, incomplete, irrelevant or misleading for the purpose for which it is held.
If you require access to, or wish to update your personal information, please contact our Privacy Champion.
Postal: P O Box 688, Mooloolaba, Queensland, 4557, Australia
COMPLAINTS & CONTACT US
If you want to contact us, have any queries or would like to make a complaint in relation to our Policy or the manner in which we handle your personal information, please contact our Privacy Champion at:
Postal: P O Box 688, Mooloolaba, Queensland, 4557, Australia
We endeavor to respond to complaints and queries within thirty days of their receipt.
If you are dissatisfied with our response, you may refer the matter to the Australian Information Privacy Commissioner (see www.oaic.gov.au).