This Privacy Policy of [insert] [insert ACN] (us, we, our) sets out how we treat the Personal Information that we collect, use and disclose and our procedures regarding the handling of Personal Information, including the collection, use, disclosure and storage of information, as well as the right of individuals to access and correct that information. We operate the platform called ‘[insert]’, which includes the application and the website with domain name [insert] (Platform).

From time to time, we may revise or update this Privacy Policy or our information handling practices. If we do so, the revised Privacy Policy will be published on the Platform at [insert link]

We may collect Personal Information in order to conduct our business, to provide and market our services and to meet our legal obligations. By using the Platform or our services, or by providing any Personal Information to us, you consent to the collection, use and disclosure of your Personal Information as set out in this Privacy Policy.

The types of information

The Privacy Act 1988 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.

(a) Personal Information

Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:

(i) whether the information or opinion is true or not; and

(ii) whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this Privacy Policy.

(b) Sensitive Information

Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive Information will be used by Us only:

(i) for the primary purpose for which it was obtained;

(ii) for a secondary purpose that is directly related to the primary purpose; and

(iii) with your explicit consent or where its collection, use or disclosure is required or authorised by law.

The types of Personal Information and Sensitive Information we collect and hold

The types of Personal Information we may collect and hold includes (but is not limited to) personal information about:

• your contact details, such as name, email address, phone number and postal address;

• your enquiry and booking information;

• your marketing preferences and communications history;

• payment or billing information (such as credit card or bank details);

• other personal information required to provide our services in specific cases;

• technical and usage data, such as IP address, browser type, device information and cookies/analytics data; and

• details of your use of our products or services.

You are not obliged to provide Personal Information to us. However, in many cases, if you do not provide us with the necessary information, we may not be able to supply the relevant functionality of the Platform or our services effectively.

In some circumstances, you may provide to us, and we may collect from you, Personal Information about a third party. Where you provide the Personal Information of a third party, you must ensure that the third party is aware of this Privacy Policy, understands it and agrees to accept it.

The Platform is intended for adults aged 18 years or over.

If it is necessary to provide specific services to you, we may collect Sensitive Information about you. However, we will only collect Sensitive Information from you if you agree to provide it to us, you authorise us to obtain it from a third party or where the collection of the information is required or authorised by or under an Australian law or a Court/Tribunal order or otherwise where the collection is not prohibited under Australian law.

How Personal Information and Sensitive Information is collected and held by us

We collect Personal Information and Sensitive Information in the following ways:

• when you fill in and submit to us an online form or any other form;

• when you submit Personal Information or Sensitive Information through the Platform (such as when you send us a message) or provide it to us in any other way;

• in person, for example, when you engage with our employees, contractors, facilitators, agents, or customer service representatives; and

• in the course of providing services to you.

Collection of Personal Information through activity

Information that may identify you as a user may be gathered during your access to the Platform.

The Platform may include pages that use “cookies”. A cookie is a unique identification number that allows the server to identify and interact more effectively with your computer or device. The cookie assists us in identifying what our users find interesting on the Platform.

A cookie may be allocated each time you use the Platform. The cookie does not identify you as an individual in our data collection process; however, it does identify your internet service provider.

You can configure your access to the Platform to refuse cookies. If you do so, you may not be able to use all or part of the Platform.

Artificial Intelligence (AI) tools

We use AI tools to assist with certain functions of the Platform. We do not rely exclusively on AI tools to make decisions that may significantly affect an individual’s rights or interests. All AI-generated content is reviewed and approved by us before use. Any significant operational decision, such as account suspension or booking refusal, is subject to human review.

Where consent is required, we obtain it separately through a clear affirmative action. You may withdraw your consent at any time, subject to our ability to continue providing services.

The purposes for which we collect, hold, use and disclose Personal Information and Sensitive Information

We collect, hold, use and disclose Personal Information or Sensitive Information for a variety of business purposes including:

• to provide the products or services you have requested from us;

• to improve our business, products and services;

• to promote our business to you;

• to market our other services or products to you;

• to handle and respond to your enquiries, complaints or concerns; and

• to provide Personal Information or Sensitive Information to third parties as set out in this Privacy Policy, only where necessary, with appropriate safeguards and your consent where required by law.

We use your information only for the purpose for which it was collected, or a related purpose you would reasonably expect. Otherwise, we will ask for consent or rely on another APP exception.

Direct marketing

We also collect, hold, use and disclose your Personal Information to:

• notify you about the details of new services and products offered by us;

• send you our newsletters and other marketing publications;

• administer our databases for client service, marketing and financial accounting purposes; and

• to comply with our legal requirements regarding the collection and retention of information concerning the products and services that we provide.

All marketing emails and SMS messages include an unsubscribe facility. By using the Platform, you consent to the receipt of direct marketing material. If you do not wish to disclose your Personal Information for the purpose of direct marketing or you would like to opt-out of receiving direct marketing communications, you can do so by contacting us using the contact details set out below, or by following the instructions to unsubscribe which are contained in a communication that you receive from us.

We may use your Personal Information (but never Sensitive Information) to contact you about our services, updates, and promotions.

Third Party Service Providers

We may disclose your Personal Information to third parties who work with us in our business to promote, market or improve the services that we provide, including:

• providers of customer relations management database services and marketing database services;

• marketing consultants, promotion companies and website hosts;

• partnered businesses;

• linked service providers; and

• consultants and professional advisers.

We use third-party payment service providers to process transactions securely. These providers may collect and store your payment details in accordance with their own privacy policies.

We may also combine your Personal Information with information available from other sources, including the entities mentioned above, to help us provide better services to you.

Where we do share information with third parties, we require that there are contracts in place that only allow use and disclosure of Personal Information to provide the service and that protect your Personal Information in accordance with Australian law. Otherwise, we will disclose Personal Information to others if you have given us permission, or if the disclosure relates to the main purpose for which we collected the information, and you would reasonably expect us to do so.

How we store, hold, and protect your Personal Information and Sensitive Information

We store Personal Information and Sensitive Information in computer storage facilities and paper-based files in Australia, with backups and disaster recovery systems also maintained there. We implement reasonable technical and organisational measures in accordance with APP 11 to protect Personal Information from misuse, interference and loss, and from unauthorised access, modification or disclosure, including encryption, access controls, multi-factor authentication, network security monitoring, incident response procedures, vendor oversight, staff training and data minimisation practices.

We take reasonable steps to protect your Personal Information and Sensitive Information against loss, unauthorised access, use modification or disclosure. Some examples of the steps we take to protect your Personal Information and Sensitive Information include:

• ensuring there are suitable password protection measures and access privileges in place to monitor and control access to our IT systems;

• imposing restrictions on physical access to paper files;

• requiring any third parties engaged by us to provide appropriate assurances to handle your Personal Information and Sensitive Information in a manner consistent with Australian law; and

• taking reasonable steps to destroy or de-identify Personal Information and Sensitive Information after we no longer need it for our business or to comply with the law.

We store, process, and retain your information only for as long as we need it for the purposes described in this Privacy Policy. When we no longer need your information, we take reasonable steps to destroy or de-identify it, unless we are required or authorised by law to retain your information for a longer period.

We retain Personal Information for the periods required by applicable law.

The Australian Privacy Principles (APP):

• permit you to obtain access to the Personal Information or Sensitive Information we hold about you in certain circumstances (APP 12); and

• allow you to correct inaccurate Personal Information or Sensitive Information subject to certain exceptions (APP 13).

Where you would like to obtain such access, please contact Us in writing on the contact details set out at the bottom of this Privacy Policy.

Data Breach Response

We maintain a written data breach response plan that complies with the Privacy Act. Where we have reasonable grounds to suspect that an eligible data breach may have occurred, we will promptly contain and investigate the incident, take reasonable steps to mitigate harm and preserve evidence, and carry out an assessment in a reasonable and expeditious manner and, where required by law, within 30 days.

If we become aware of reasonable grounds to believe an eligible data breach has occurred, we will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as soon as practicable, in line with the Privacy Act. If direct notification is not practicable, we will publish a notification. We will keep records of the incident, our assessment, and our response, and take reasonable steps to prevent a recurrence.

Cross-border disclosure

We generally store Personal Information in Australia but may disclose it to overseas service providers from outside Australia. Before disclosing Personal Information to an overseas recipient, we will comply with APP 8 by taking reasonable steps in the circumstances to ensure the recipient does not breach the APPs in relation to the information, unless an exception under APP 8.2 applies, including where you have provided informed consent to the disclosure or the disclosure is required or authorised by law.

Where we rely on your consent to an overseas disclosure, you acknowledge and agree that APP 8.1 will not apply and that we will not be accountable under section 16C of the Privacy Act for the overseas recipient’s handling of the Personal Information.

How we handle requests to access your Personal Information or Sensitive Information

You may request access to your Personal Information or Sensitive Information under the Privacy Act, or request deletion of your Personal Information or Sensitive Information in accordance with our data retention policies. You can make such a request by contacting us using the contact details set out in this Privacy Policy.

We will respond to any such request for access as soon as reasonably practicable. Where access is to be given, we will provide you with a copy or details of your Personal Information and Sensitive Information in the manner requested by you where it is reasonable and practicable to do so.

We will not charge you a fee for making a request to access your Personal Information and Sensitive Information. However, we may charge you a reasonable fee for giving you access to your information.

We may refuse access to your requested information, or provide only partial access, where required by law, including where information must be retained for legal or regulatory reasons. If access is refused, we will provide a written statement of reasons unless it is unreasonable to do so.

How we handle requests to correct your Personal Information and Sensitive Information

We will take such steps (if any) as are reasonable in the circumstances to make sure that the information we collect, use or disclose is accurate, complete, up to date and relevant for the purpose of its use or disclosure.

If you believe the information that we hold about you is inaccurate, irrelevant, out of date or incomplete, you can ask us to update or correct it. To do so, please contact us using the contact details listed below.

How to contact us or make a complaint

If you have any questions about this Privacy Policy, if you wish to correct or update information we hold about you or if you wish to request access or correction of your Personal Information or make a complaint about a breach by us of our privacy obligations (including the way we have collected, disclosed or used your Personal Information and Sensitive Information), please contact:

Attention: Privacy Officer, [insert]
Address: [insert]
Email: [insert]
Telephone: [insert]

We will acknowledge and investigate any complaint about the way we manage information as soon as practicable. We will take reasonable steps to remedy any failure to comply with our privacy obligations. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. We will take reasonable steps to remedy any failure to comply with our privacy obligations.

If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au.