Privacy Policy

INTRODUCTION

Welcome to the Coaching Advocates’ Privacy Policy.

Coaching Advocates Pty Ltd (ACN 646 753 906) (“Coaching Advocates”, “we”, “us”, “our”) respects, and is committed to safeguarding, your privacy.  We believe that information received by us that can be used to identify an individual user (“you”, “your”, “User”) should be taken very seriously. We are committed to the security and confidentiality of your personal information, and are transparent in how we manage it.  Unless given consent to do otherwise, we will only collect and use personal information as set out below.

We follow the spirit of the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the “Privacy Act”). However, until such time (if at all) as we are subject, in whole or in part, to the Privacy Act, we have chosen not to opt in to be treated as an organisation for the purposes of the Act.

This Privacy Policy sets out our commitment to protecting the privacy of your personal information that we collect through our website and/or services.  Our website and/or services includes any websites, applications or platforms operated by us or associated business names registered by us.

  1. IMPORTANT INFORMATION AND WHO WE ARE  

    1. PURPOSE OF THIS PRIVACY POLICY

      This Privacy Policy aims to give you information on how Coaching Advocates collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our email list, sign up for any other free information or competition on the website, submit a question or comment to Coaching Advocates via the website or purchase a product or service on the website.

      This website is not intended for children and we do not knowingly collect data relating to children.

      It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

    2. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

      We keep our Privacy Policy under regular review.
      It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    3. THIRD-PARTY LINKS

      This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  2.  THE DATA WE COLLECT ABOUT YOU

    1. IF YOU FAIL TO PROVIDE PERSONAL DATA

      Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

       

  3. HOW IS YOUR PERSONAL DATA COLLECTED?  

    We use different methods to collect data from and about you including through:

    1. Direct interactions.

      You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes, but is not limited to, personal data you provide when you:


      1. sign up for and/or participate in our marketing materials, questionnaires, promotions, competitions, surveys and free offers;
      2. apply for and/or purchase our products or services;
      3. create an account on our website;
      4. complete registration forms, surveys, user profiles, or comments and public interactions, when you provide your name, email address or other information to us voluntarily;
      5. subscribe to our service or publications;
      6. complete feedback communications or customer service requests, where you may supply or we may ask for your name and contact details;
      7. request marketing to be sent to you;
      8. download software and/or mobile applications, where you may provide your name and contact details and other information for the purposes of signing up to the application and obtaining its services; and submit your curriculum vitae, where you provide your personal information to us.

    2. Automated technologies or interactions.

      As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

    3. Third parties or publicly available sources.

      We may receive personal data about you from various third parties and public sources including:
      1. analytics providers, such as Google, based outside the EU;
      2. contact, financial and transaction data from providers of technical, payment and delivery services;
      3. data from social media, list brokers, referral agents and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so;
      4. Identity Data and Contact Data from publicly available sources such as Companies House in the United Kingdom, ASIC or the Australian Business Registry.

      We may monitor and record calls and other electronic communications that you make to us in certain circumstances. For example, calls to us may be monitored and recorded for training and customer service purposes.

      We use social networking services such as Twitter, Facebook, Instagram, Clubhouse and LinkedIn to communicate with the public about us. When you communicate with us using these services we may collect your personal information. The social networking service will also handle your personal information for its own purposes. These sites have their own privacy policies.

  4. HOW WE USE YOUR PERSONAL DATA

    We will only use your personal data when the law allows us to as provided for in this Privacy Policy. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal obligation.

    Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

    1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

      We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

      Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

      Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
      To register you as a new client

      (a) Identity

      (b) Contact

      Performance of a contract with you

      To process and deliver your order including:

      (a) Manage payments, fees and charges

      (b) Collect and recover money owed to us

      (a) Identity

      (b) Contact

      (c) Financial

      (d) Transaction

      (e) Marketing and Communications

      (a) Performance of a contract with you

      (b) Necessary for our legitimate interests (to recover debts due to us)

      To manage our relationship with you which will include:

      (a) Notifying you about changes to our terms or Privacy Policy

      (b) Asking you to leave a review or take a survey

      (a) Identity

      (b) Contact

      (c) Profile

      (d) Marketing and Communications

      (a) Performance of a contract with you

      (b) Necessary to comply with a legal obligation

      (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

      To enable you to partake in a prize draw, promotion, competition, free offer, free download, or complete a survey

      (a) Identity

      (b) Contact

      (c) Profile

      (d) Usage

      (e) Marketing and Communications

      (a) Performance of a contract with you

      (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

      To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

      (a) Identity

      (b) Contact

      (c) Technical

      (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

      (b) Necessary to comply with a legal obligation

      To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

      (a) Identity

      (b) Contact

      (c) Profile

      (d) Usage

      (e) Marketing and Communications

      (f) Technical

      Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
      To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

      (a) Technical

      (b) Usage

      Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
    2. MARKETING

      We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

    3. PROMOTIONAL OFFERS FROM US 


      We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

    4. THIRD-PARTY MARKETING  


      We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

    5. OPTING OUT


      You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

    6. COOKIES 


      You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.

    7. CHANGE OF PURPOSE

      We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

      If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

      Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  5. DISCLOSURES OF YOUR PERSONAL DATA

    We may share your personal data with external third parties for the purposes set out in the table Purposes for which we will use your personal data above.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

  6.  DATA RETENTION & SECURITY
    1. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

      We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


      To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

      In some circumstances you can ask us to delete your data: see your legal rights below for further information.

      In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

      We take measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all personal information that we collect. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps.

      We are committed to ensuring that the information you provide is secure. We use reasonable technical, administrative and physical measures to safeguard personal information. However, no personal information shared on the internet can be 100% guaranteed to be secure. Users are responsible for the access and security of their own computers.

  7. YOUR LEGAL RIGHTS

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. As stated below in this Privacy Policy that you have the right to:Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    If you wish to exercise any of the rights set out above, please contact us.

    1. NO FEE USUALLY REQUIRED

      You will not have to pay a fee to access your personal data (or to exercise any of the other rights) pursuant to this Privacy Policy or otherwise. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

    2. WHAT WE MAY NEED FROM YOU

      We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    3. TIME LIMIT TO RESPOND

      We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  8. WHEN YOUR INFORMATION LEAVES AUSTRALIA

    Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia. We will only transfer personal information to a foreign country for the purpose of providing you with our services and for carrying out any request you make when you use and interact with our website and services (e.g., if we outsource data storage to a cloud service provider).

    In the event that we are required to disclose your personal information to overseas third parties, we will take reasonable steps to ensure that such disclosures are subject to reasonable confidentiality terms.

    Privacy Data breaches

     

    Australian laws provide that an eligible data breach arises when the following three criteria are satisfied:

    • there is unauthorised access to or unauthorised disclosure of personal information, or a loss of personal information, that we hold;
    • this is likely to result in serious harm to one or more individuals; and
    • we have not been able to prevent the likely risk of serious harm with remedial action.

    We are required to take all reasonable steps to ensure an assessment of an eligible data breach is completed within 30 days. If an eligible data breach is confirmed, as soon as practicable we must provide a statement to each of the individuals whose data was breached or who are at risk, including details of the breach and recommendations of the steps individuals should take. A copy of the statement must also be provided to the Office of the Australian Information Commissioner.

  9. GLOSSARY

    Comply with a legal obligation
    means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    Legitimate Interest
    means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

  10. HOW TO CONTACT US ABOUT YOUR PRIVACY

    If you want to send us notices or service of process, or have any questions about our Privacy Policy, please contact us:

    • by email at: info@www.coachingadvocates.com;
    • by mail at: PO Box 275, Frenchs Forest, NSW, 1640, Australia;
    • or online via our contact us page


    Privacy Complaints

     

    If you have a complaint, please email us at info@www.coachingadvocates.com. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

    If you have any complaints about our privacy practices, please feel free to send details of your complaint to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001 Phone 1300 363 992 or oaic.gov.au.

    If you have any questions, please don’t hesitate to contact us.