Privacy policy:

Introduction

This Privacy Policy applies to any personal information we collect, handle, use or disclose. It does not apply to our employee records that are directly related to our employment relationship.

This Privacy Policy sets out the approach that we will take in relation to the treatment of your Personal Information. It includes information on how we collect, use, disclose, and keep secure, your Personal Information. It also covers how we make the Personal Information we hold available to you for access and correction by you in the event that such information is inaccurate or incomplete.

When a word used in this Privacy Policy starts with a capital letter it has a special meaning which is defined in the Glossary at the end of this Privacy Policy.

What information do we collect and hold?

The kinds of personal information we may collect and hold can vary depending on the services we are providing, but generally can include:

your name, email address or postal address;
your date of birth and gender;
your username and password which you use to access our Application in order for you to receive the benefit of the Application services;
any relevant billing or account information (including but not limited to bank account details, direct debit, credit card details, billing address);
information relevant to our Application or services;
other information such as your opinions, statements and endorsements collected personally or via surveys and questionnaires, including but not limited to your views on the Application or services provided by us;
identification information in order to comply with our obligations under law to verify your identity; and
any other information that you may provide in the course of communication with us.

We will not usually collect any type of Sensitive Information.

Contacting Us

If you require further information regarding our Privacy Policy, you can contact us on:

info@connect2coach.com.au

1. Collection

1.1 We will only collect Personal Information by lawful and fair means and where the information is reasonably necessary for us to perform one or more of our functions or activities. Normally we will collect information from you directly via the Application unless it is unreasonable or impracticable for us to do so. In some instances, we may collect your Personal Information indirectly from or through a third party such as a Club that is registered with our Application.

1.2 We collect your Personal Information primarily to provide you with the services available via our Application which connects users in accordance with its Terms and Conditions. Collection purposes include to:

• share such Personal Information provided by you with any person you communicate it to using the communication tools in the Application;

• send you emails, text messages, push notifications and other alerts on behalf of us or the Club for purposes such as confirming your Application booking, providing booking reminders, facilitating User surveys and providing you with your password to access the Application;

• amend, review and improve the performance of the Application;

• business planning and development or for any proposed or actual acquisition of our business.

If there are additional purposes for which we propose to collect your Personal Information which are not specified in this Privacy Policy, they will be disclosed at the time we collect that Personal Information and we will ask for your consent to that collection.

We will always give you the option to decline to provide your Personal Information or to decline to allow us to use that Personal Information for the purposes for which we have proposed to use it. However, if you choose not to provide us with the information we have requested, we may not be able to provide you with our products or services or properly manage and administer products or services provided to you or others.

1.4 We will not collect Sensitive Information from individuals except with consent and only where it is necessary for us to collect such information to provide our services to you.

2. Use

2.1 We use Personal Information primarily to provide you with the services available via our Application which connects users in accordance with its Terms and Conditions.

2.2 We will obtain your consent for use of Personal Information for specific secondary purposes at the time of collection, unless such use is identified in this Privacy Policy or is a related secondary purpose which would be within your Reasonable Expectations.

2.3 Regardless, we will only use or disclose Personal Information about you:

(i) in accordance with this Privacy Policy;

(ii) for any other purpose communicated to you at or near the time your Personal Information is collected;

(iii) as permitted or required by law (this includes use to avoid an imminent threat to a person's life health or safety or a threat to public health or safety). It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities;

(iv) if we believe it necessary to provide you with a product or service you have requested;

(v) to implement our services;

(vi) in the event of a corporate sale, merger, re-organisation, dissolution or similar event of all or part of our business; or

(vii) if you have provided your consent to such use or disclosure.

2.4 With your consent, we may also use your personal information to send you Direct Marketing to notify you of special offers or promotions or ask you to participate in customer surveys or to provide information about our goods or services. If you do not wish to receive such communications from us, you may elect to Opt Out (see glossary) from further Direct Marketing by selecting the "UNSUBSCRIBE" or "OPT OUT" option in the Direct Marketing communication or, asking that you be removed from our Direct Marketing list by contacting us via the contact details above.

2.5 We will not, if collected, use Sensitive Information for Direct Marketing.

2.6 We will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

3. Disclosure

3.1 We may Disclose Personal Information to related or unrelated third parties if you have consented to that Disclosure. This can include our professional advisors, agents and other advisers.

3.2 We may Disclose Personal Information between Related Bodies Corporate. Where information is Disclosed to a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.

3.3 We also use service providers to help us maximise the quality and efficiency of our services and our business operations. This means individuals and organisations outside of us, such as information technology service providers, website hosts and back-up service providers, and professional advisors such as lawyers and accountants will sometimes have access to Personal Information held by us and may use it on our behalf. We ensure that our contracts with our service providers require them to adhere to strict privacy guidelines and to only use your Personal Information for authorised purposes, except to the extent noted under – 7. Transferring information overseas.

3.4 We may Disclose Personal Information to law enforcement agencies, government agencies or regulators, dispute resolution providers, courts or external advisers and any other parties where permitted or required by law.

3.5 We may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.

3.6 Except for Disclosure for a Primary Purpose or for a related Secondary Purpose or where your consent has been obtained to such Disclosure, we will not Disclose your Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.5 above.

4. Data security

4.1 We are committed to the protection of your data. We will take all reasonable steps to ensure that the transmission of data occurs according to accepted industry standards, however you accept that the internet is not a fully secure environment and we cannot accept responsibility for misuse or loss of, or unauthorised access to or disclosure of, information where the security of the information is not within our control. If you provide us with information via the internet, you do so accepting this risk

4.2 We may limit the amount of data that you can store in the Application and will advise you of such limitation. Data that is stored with us will be stored according to accepted industry security standards which are implemented and updated in accordance with the manufacturer's or licensor's recommendations.

4.3 We will also perform backups of the Application in a reasonable manner at such times and intervals as are reasonable for our business purposes. We do not warrant that we are able to backup or recover specific Personal Information from any period of time, unless so stated in writing by us.

4.4 We will review, on an ongoing basis, its collection and storage practices to ascertain how improvements to security and protection of Personal Information can be achieved.

4.5 We will, to the extent technically practicable, destroy or de-identify Personal Information once it is no longer required by us for use, within as short a time as is reasonably possible (taking into account any specific requirements of its clients), unless the law requires otherwise.

4.6 We will only allow our employees and contractors access to your Personal Information in order to perform their duties and obligations and we will take all reasonable steps to ensure that those employees and contractors handle your Personal Information in a manner that is consistent with this Privacy Policy and our legal responsibilities in relation to privacy.

4.7 You should note that whilst our website may link to other websites, those other websites are not under our control and we are not responsible for the conduct of the operator of those websites including how they handle and protect your Personal Information. Before accessing those websites, we recommend you review the terms and conditions of or access to such websites including the relevant privacy policy or provisions.

5. Complaints or questions

5.1 Individuals wishing to make an inquiry or complaint regarding privacy should do so by contacting us using the contact details that appear at the beginning of this Privacy Policy. If you make a complaint or if we become aware of any concern or problems concerning our privacy practices, we will contact you about the issue, investigate the issue, and take all reasonable steps to work with you to resolve that issue.

5.2 If you are not satisfied with our response we will tell you about any external dispute resolution avenues which may be available to you.

6. Access and correction

6.1 We will allow you to have access to its records containing your Personal Information in accordance with the Privacy Act. This will usually take the form of us providing you with a copy of the information held. Any request for such information should be made via our contact details set out at the beginning of this Privacy Policy.

6.2 In most cases we do not charge for receiving a request for access to personal information or for complying with a correction request. A reasonable fee may be charged for providing access however we will advise you of the likely cost in advance and will aim to supply the information within a reasonable period.

6.3 If your Personal Information is inaccurate, out of date, incomplete, irrelevant or misleading, you may contact us using our contacts details set out at the beginning of this Privacy Policy and we will correct our records containing your Personal Information as soon as practicable unless there is a reason why we cannot amend it. If you would like your Personal Information deleted, please let us know using our contacts details set out at the beginning of this Privacy Policy and we will take all reasonable steps to delete it unless we need it for legal, auditing or internal record keeping.

6.4 We may refuse access where the:

information may have an unreasonable impact on the privacy of others;
request is frivolous or vexatious;
information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings;
information would reveal our intentions in relation to negotiations in such a way as to prejudice those negotiations.

6.5 Where providing access would reveal evaluative information generated by us in connection with a commercially sensitive decision-making process, we will provide an explanation for the decision rather than direct access to the information.

6.6 If we refuse access or to give access in the manner requested by you we will let you know why in writing and provide you with details about how to make a complaint about the refusal.

6.7 If we make a correction to your personal information we may retain a copy of the previous information for our records or as required by law.

7. Transferring information overseas

7.1 We will take reasonable steps to limit the amount of Personal Information we send to unrelated parties overseas but may need to disclose your Personal information outside of Australia to service providers as noted in 3.3 above.

8. Glossary

Application means Connect2Coach application.

Direct Marketing means the marketing of products or services to you through means of communication including written, verbal, physical or electronic means. The products or services which are marketed may be those of us, a Related Body Corporate, a business partner or an independent third party organisation.

Disclosure means the release of information by us to another party, including a Related Body Corporate or under a contract to carry out an outsourced function of ours.

Health Information means:

(a) information or an opinion about:

(i) the health including an illness, disability or injury (at any time) of an individual; or

(ii) an individual's expressed wishes about the future provision of health services to the individual; or

(iii) a health service provided or to be provided to an individual,

that is also Personal Information; or

(b) other Personal Information collected to provide, or in providing, a health service to an individual; or

(c) other Personal Information about an individual collected in connection with the donation or intended donation by the individual of his or her body parts, organs or body substances; or

(d) genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual.

We means Connect2Coach PTY LTD

Opt Out means a mechanism by which an individual requests not to receive Direct Marketing.

Personal Information is 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 is recorded in a material form or not.

Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.

Reasonable Expectation means a reasonable individual's expectation that their Personal Information might be used or Disclosed for a particular purpose.

Related Body Corporate means a body corporate that is:

(a) a holding company of another body corporate;

(b) a subsidiary of another body corporate; or

Sensitive Information means:

(a) information or an opinion about an individual's:

(i) racial or ethnic origin; or

(ii) political opinions; or

(iii) membership of a political association; or

(iv) religious beliefs or affiliations; or

(v) philosophical beliefs; or

(vi) membership of a professional or trade association; or

(vii) membership of a trade union; or

(viii) sexual orientation or practices; or

(ix) criminal record,

that is also Personal Information; or

(b) Health Information about an individual; or

(d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or

(e) biometric templates.

We, us or our means