Collective courage leadership coaching (2)

Privacy

Policy

Collective Courage Pty Ltd ACN 641 116 743 as trustee for the Collective Courage Trust ABN 76 512 832 269 (‘we’, ‘our’ and ‘us’) is committed to protecting the personal information that we collect and hold about you. This Privacy Policy (Policy) sets out how we collect, use and share your personal information and how to contact us with any queries or concerns. Although we are not bound by the Privacy Act 1988 (Cth) (Privacy Act), we adhere to the Australian Privacy Principles (APPs) as far as practicable.

By enrolling or participating in our courses or by voluntarily supplying us, including in the course of enrolling or participating in our courses, with your personal information you are agreeing to be bound by this Policy. While we may update our Policy from time to time, the most recent version of this Policy will always be available on our website. If we change the Policy in any material way we will post a notice on our website along with the updated Policy. We may also contact you via your contact information on file, for example by email, notification or some other equivalent measure.

If you have any queries, concerns or complaints about how we handle your personal information, please contact out Privacy Officer in the first instance:

Privacy Officer Contact:

Anna Ranaldo
Email: anna@collectivecourage.com.au
Postal address 9 Windsor Avenue, Burnside, SA 5066, Adelaide
Attention: Privacy Officer
Collective Courage
[Address]

Our website contains links to other websites. When a user clicks on a link to another site they are no longer subject to this Policy.

1. What types of information do we collect and why?

In the course of providing our services to you, we collect personal and other information about our customers and how they interact with us and our services. We collect personal information through a number of mechanisms, including:

1.1 Collection from you: we collect and store information you provide directly to us (either in person, through your organisation, by email, by phone, or by any other direct means) in order to deliver our services. This includes:

  • Contact information: such as your name, address, email address, telephone number;
  • Financial and credit information: such as your payment information (credit card, bank account, etc);
  • Business details: such as your Australian Business Number; Employer, Job Title and/or
  • Credit information: such as type and amount of credit sought, default information, repayment history information, payment information relating to overdue payments.

1.2 Third Parties: we collect and store information you provide through a third party organisation (such as a booking provider, including Eventbrite) or through an organisation you are a member of or employed by (such as your employer or you school). This includes:

  • Contact information: such as your name, address, email address, telephone number;
  • Financial and credit information: such as your payment information (credit card, bank account, etc);
  • Business details: such as your Australian Business Number; Employer, Job Title and/or
  • Credit information: such as type and amount of credit sought, default information, repayment history information, payment information relating to overdue payments.

 

1.3 Automatic: we use cookies (small text files stored on your devices that provide us with information such as your internet protocol (IP) address, server information, internet service provider, and information on how you interact with our website) and other services that allow us to understand how you use our online media. This information is not linked to you personally.
We use Word Press and Mailchimp which tracks and measures user interaction and provides data to help improve our services. Please see these links (https://wordpress.org/about/privacy/ and https://mailchimp.com/legal/privacy/) for how your data is collected. If you opt-out of third party tracking technologies or elect to prevent the use of cookies, this may result in the loss of website functionality, restrict your use of the website or delay or affect the way in which the website operates.

1.4 Device: if you use our services or interact with us through a mobile device, we receive technical information about your device, numbers that identify the device and you location information. This information [is/is not] associated with you.

1.5 Communications: when you communicate with us, we collect information such as your contact details (such as email address or phone number). We also engage third party services that provide us with information about how you interact with some communications we distribute. You can elect to not receive communications from us by contacting our Privacy Officer.

1.6 Digital platforms: if you access our goods or services by connecting a social media login (such as Facebook, Google, LinkedIn, Eventbrite) we collect information derived, associated or connected with that platform where permitted by the platform’s terms of service. Any information we collect from social media, or other online, platforms is collected in accordance with that platform’s terms and conditions.

1.7 Through other sources: where necessary, we also collect your information from publicly available records.. Where appropriate and necessary to do so we use collect information from public records such as those maintained by the Australian Securities and Investments Commission, Australian Financial Security Authority (PPSR), and land titles offices in each state. We may do this where it is unreasonable or impractical to collect this information from you.
If you have previously applied for a position with us we may have received your personal information from third parties such as recruiters or external websites. We use the information we receive to contact you about any potential opportunities or to evaluate your candidacy.

1.8 Sensitive Information:
We collect information considered to be sensitive information in the Privacy Act. In order to provide you with certain services we may collect information about your mental and physical wellbeing (health information) in order to ensure that you able to safely undertake our courses and confirm you have adequate support networks if you find the content of our services difficult. This will be in the form of a consent form.
We will only collect this information directly from you or where we have consent to collect the information from a third party (such as an organisation you are a part of or employed by).You have the option of not identifying yourself or interacting with us using a pseudonym. However, this may not be practicable when engaging our services or purchasing our goods.

2. How do we use your information?
We will only use your information for the purposes for which it was collected (primary purpose) or a purpose related to that primary purpose if it would be reasonably expected by you or where we have separately obtained your consent.
We use personal information for the primary purpose of providing you with our consulting, training and development services.
How we use the information we collect depends, in part, on which services you use, how you use them and any preferences you have communicated to us. If you would like to restrict how your personal information is handled beyond what is outlined in this Policy, please contact our Privacy Officer.

2.1 Disclosure of personal information to third parties
We may disclose your information to third parties who assist us in providing, managing and administering our services. We will also disclose your personal information where such disclosure is required by law.
We do not sell or license your information to third parties.

2.2 Disclosure of credit information to third parties
We do not disclose your credit information to any credit reporting bodies.

3. How do we store and secure the information we collect?
We store your personal and credit information on our secure cloud facilities, protected by two factor authentication with appropriate back and security systems. Credit card information is stored and processed via our third party provider Xero. Please use this link to learn how your credit information is collected and stored. https://www.xero.com/au/about/legal/privacy/.

3.1 Security and management of personal information
We will take reasonable steps to protect the personal information we hold from misuse, loss, and unauthorised access, modification or disclosure. We do this by:

  • Putting in place physical, electronic and procedural safeguards in line with industry standards;
  • Requiring any third party providers to have acceptable security measures to keep personal information secure;
  • Limiting access to the information we collect about you;
  • Imposing confidentiality requirements on our employees;
  • Only providing access to personal information once proper identification has been given.

 

While we take all steps reasonable in the circumstances to protect your information, in the unlikely event a data breach occurs, we will notify you in accordance with our obligations under the Privacy Act.
If we no longer require your personal information, and are not legally required to retain it, we will take reasonable steps to destroy or de-identify the personal information.

3.2 Sending information overseas
We do not disclose or store personal information overseas.

4. How to access and control your information?

4.1 Accessing the information we hold about you
Under the APPs you may be able to obtain a copy of the personal information that we hold about you. To make a request to access this information please contact us in writing. We will require you to verify your identify and specify what information you wish to access. If eligible, we will grant you access to the information within 30 days.
We may charge a fee to cover the costs of verifying your application, and retrieving, reviewing and copying any material requested.

4.2 Updating your personal information
We endeavour to ensure that the personal information we hold about you is accurate, complete and up-to-date. Please contact us at the details above if you believe that the information we hold about you requires correction or is out of date. We endeavour to process any request within 30 days and will provide written reasons if your request is rejected, as well as providing details for making a complaint about the refusal if necessary.
For corrections to credit information we will provide, where practicable, written notice of the correction to any entity we have disclosed this information to previously.

5. Complaints
If you are concerned that we have not complied with your legal rights or the applicable privacy laws, contact our Privacy Officer in the first instance. Please contact our Privacy Officer (contact details above) with a thorough description of your concerns and a response will be provided within a reasonable period. All complaints must be in writing.

When processing a compliant, we will require you to provide us with information to confirm your identity before processing a request related to information we may hold about you.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:
Director of Compliance Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
For more information on privacy see the Australian Information Commissioner’s website.

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