Growing Strong Ideas P/L trading as Steps to Change is committed to complying with the Privacy Act 1988, the Australian Privacy Principles 2014 and the privacy provisions of all applicable legislation.
This privacy policy covers all personal information we hold. That is information, or an opinion about an individual, whose identity is apparent, or can be reasonably ascertained, from that information or opinion. This includes information we have collected from people through our office, over the phone and over the internet. Collecting information When we collect personal information from an individual, we will ensure that we do so in a fair manner and that we let the individual know where and how to contact our organisation. We will only collect information that is necessary for one or more of our functions or activities. The personal information that we collect will depend on your relationship with us and the service you have requested. It may include:
If we collect sensitive information (as defined under the Act), we will treat it with the utmost security and confidentiality. We will ensure that it is not collected for any purposes, other than those for which we have obtained the individual’s consent, unless the law requires otherwise, or other exceptional circumstances prevail as described under the Act. We may collect information about you which is considered sensitive under applicable privacy and data protection laws. This information may include:
Where an individual chooses not to provide requested information, we will advise that individual of what consequences this non-disclosure may have. For example, withholding certain information may limit our ability to provide relevant offers or services to individuals in a safe manner, or tailored to their individual needs. We will not use your health or other sensitive information for marketing purposes. How we collect your personal information We collect your personal information in a number of ways. We may collect your personal information directly from you or in the course of our dealings with you, for example when you:
Why we collect personal information We collect your personal information for a variety of purposes and on different legal grounds. Most of the time, we collect your personal information so that we can provide you with our services and any products that you may have requested and to enter into and perform our contract with you. This may include:
Disclosing information We will only disclose personal information in accordance with the Privacy Act. This means that personal information may be disclosed:
What would happen if we did not collect your personal information? If we cannot collect your personal information as described above, we may not be able to process your booking, organise support products or persons or other requests made by you. We also may not be able to fully investigate an incident, complaint or claim, or provide you with all or some of our other products and services. You may not need to provide some of the information that we use on the basis of our legitimate interests. For example, you can disable cookies in your browser. How long do we keep your personal information? We will keep your personal information for as long as we reasonably require your personal information for any valid and lawful purpose. These purposes include to provide you with our services and any products that you have requested, exercise our rights and perform our obligations under a contract, investigate and defend actual or potential claims, comply with our legal obligations and other purposes permitted by law. When it is no longer reasonably necessary for us to keep your personal information, your information will be destroyed or put beyond use. However, we may de-identify data and retain such data for statistical purposes only. Overseas disclosures We are based in Australia, so your personal information will be processed in Australia. However, we may disclose your personal information to organisations or persons located outside of Australia. The countries in which these organisations or persons are located will depend on the circumstances, but in the course of our ordinary operations, we generally disclose personal information to third parties located in the countries where:
How we use cookies and web-tracking tools Cookies are tiny files sent to your browser and stored by your browser on your computer or other device that you're using to access our website or use our mobile applications. Our cookies collect your IP address or MAC address, the city associated with your IP or MAC address, the date and time of your visit to our website, pages or advertisements viewed, the URL of the website that you viewed before our website and the type of browser you use. We also use web tracking/analytic tools that generate detailed statistics about traffic to our websites, traffic sources and how you interact with advertisements on our websites and third party websites. These tools can also measure and record conversions and sales. The cookies and web-tracking tools allow our websites and mobile applications to interact more efficiently with the device you are using and to help us improve the content and functioning of our websites and mobile applications. We also use cookies to help us and our third party service providers present targeted and customised advertising to you on our website and on third party websites. Please see our Cookie Policy for more information on our use of cookies and web-tracking tools. Our marketing and your personal information We use personal information that we hold about you to identify services and products that may be of interest to you. We may contact you by email, text message or other digital service (such as through our applications that you install on your device such as mobile or iPad), phone or post to let you know about services, offers and promotions, for new or existing products or services that may be of interest to you. You can contact us at any time if you no longer wish to receive marketing materials from us. If you receive a marketing email from us, you can opt-out from that particular category of marketing email by clicking on the "Manage Preferences" link or the “Unsubscribe” link at the bottom of the email. Storage and security of your personal information Our systems
Rights in respect of your personal information General – access to and correction of personal data
11.2 Specific rights for EU residents only If you are located in the European Union, then you may have additional rights. Some of these rights will only apply in very limited circumstances.
If you have a complaint about how we have handled your personal information, you can make a complaint by contacting us using the details below. Once we have received your complaint, we will investigate and respond to you within a reasonable period of time. We take any privacy complaint seriously and will deal with your complaint fairly and promptly. However if you are not satisfied with our response or how we handled your complaint, you may complain to the Office of the Australian Information Commissioner at: Office of the Australian Information Commissioner (OAIC) GPO Box 5218 Sydney NSW 2001 Phone: 1300 363 992 TTY: 1800 620 241 email: enquiries@oaic.gov.au If you are located in the European Union, you have the right to complain to the local data protection authority within the EU. You can find the details of your local DPA here. Changes to our Privacy Policy We may update our Privacy Policy from time to time. Our Privacy Policy was last updated in May 2019. By continuing to use our website or otherwise continuing to deal with us, you accept this Privacy Policy as it applies from time to time. We will post all updates to our privacy page. Unauthorised disclosure or access As Growing Strong Ideas P/L trading as Steps to Change s is committed to protecting the privacy of individuals, we will view unauthorised disclosure of, or access to, personal information by our employees or contractors, as a serious breach of this policy. Appropriate action (which may include disciplinary or legal action) will be taken in such cases.
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