In this policy, COHUTT Pty Ltd is we, our or us:
For the purposes of this policy, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
We review this policy periodically to ensure it is kept relevant and up to date and we may make changes at any time by publishing the amended version on our website.
Last updated: January 2019
1 .Information we collect
In the process of conducting our business, we may collect a range of personal information from current and prospective members, service providers, job applicants and other individuals where it is necessary in order to operate our business. The kind of information collected will depend on the nature of your dealings with us, but may include:
contact information and identification such as your name, date of birth, contact number, e-mail address, residential and/or business address, demographic information (such as your postcode, age and gender) and driver’s licence or other identification document details;
security records or CCTV footage when your visit premises operated by us;
payment details (such as account or credit card details) and payment related information in connection with your purchase of our services; or
information collected from marketing campaigns, member surveys and your interactions with us, including via social media.
If you do not provide us with the personal information we request, we may be unable to provide you with the full range of our services and, depending on the information withheld, you may be ineligible to become a COHUTT member.
We will only collect sensitive information about you with your consent (unless we are otherwise allowed or required by law to collect that information). If you provide us with sensitive information, such as health information, information about your race, ethnic origin and religious beliefs, on your own accord, we will treat it with the highest confidence and only disclose it as instructed by you.
2. How we collect information
Information collected from you
Most of the personal information we collect will be collected directly from you. This may occur when you:
contact or interact with us in person, by e-mail, phone or other forms of communication, or via forms on our website or social media accounts;
sign up to purchase any of our services;
visit premises operated or managed by us;
attend events hosted or operated by us; or
respond to any of our job advertisements.
Information collected from third parties
We may sometimes collect your information from third parties such as:
where you are employed or engaged by an entity that purchases services from us, from an authorised representative of that entity;
contractors that we engage to provide services to us;
marketing agencies or providers of similar lists or information which have been legally acquired by us
parties you refer us to, or who refer us to you, including personal referees when you apply for a job with us; or
third party recruitment agencies you have provided your details to.
Information collected automatically
When you access our network or visit or interact with our website, our online member platform, or any other online platform operated by us (Platforms) we, as well as any third party service provider and/or advertiser, may use a variety of technologies that automatically or passively record information about how the Platform is accessed and used (Usage Data). Usage data may include your IP address or other unique identifier for the device used to access a Platform, browser type, device type, date and time of visit, pages viewed and your use of features or applications on the Platform. Usage Data helps us to keep the Platforms relevant for our guests and members. Usage Data is usually non-identifying, but if it can be used to identify you, we will treat it as personal information.
We may use “Cookies” (data files placed on a device when it is used to visit a Platform) to keep track of personal preferences and compile aggregate data about Platform traffic and interaction with us, so that we can offer you better experiences and tools in the future. “Cookies” may be used by us or our service providers for security purposes, or to facilitate site navigation and personalise your experience on the Platform. You should be able to configure your computer or other web browsing device so that it disables cookies or does not accept them. However, if you reject all cookies, you may not be able to use our products or services that require you to “sign in” and you may not be able to take full advantage of our services provided via the Platforms.
COOKIES, WEB BEACONS, AND SIMILAR TECHNOLOGIES
The Services — as well as certain third parties that provide content and other functionality on the Services — use a variety of technologies to learn more about how people use the Services and the Internet. This section provides more information about some of those technologies and how they work.
Mailchimp: If you submit information via one of our forms than your data will be stored with and via Mailchimp. You will always have the option of unsubscribing should you wish. https://mailchimp.com/ .
Other local storage. Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage are similar to cookies in that they are stored on your computer and can be used to store certain information about your activities and preferences. These objects are stored in different parts of your computer from ordinary browser cookies, however. Many Internet browsers allow you to disable HTML5 local storage or delete information contained in HTML5 local storage using browser controls.
Web beacons. Web beacons can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the Web beacon, the IP address of your computer, and the URL of the web page from which the Web beacon was viewed.
3. Purpose of use or disclosure
We collect, use and disclose your personal information for a variety of purposes, including:
to provide you with our services;
to foster business relations between our members;
to provide various business support services to our members;
for security and safety purposes;
to process or verify payments authorised by you;
to respond to your enquiries, concerns or complaints;
to notify members of news and event information;
to distribute promotional material and inform you about products, services, special offers and events;
for any purpose which we notify you about when we collect your information, or to which you have provided your consent;
to customise, measure and improve our services;
to improve your experience with us and our marketing, including through data analytics, product planning and research;
to consider and assess your application for as a potential job applicant or contractor; and
other purposes related to the provision of our services.
We may from time to time publish (including by posting on social media) testimonials which contain personally identifiable information. We will obtain your consent prior to publishing the testimonial along with your name.
4. Disclosing your personal information
We may disclose your information to third parties, including:
our agents or contractors who perform a particular function or service on our behalf;
your employer or former employer (for example to conduct a reference check).
Examples of our third party agents or contractors include:
mail distribution providers;
secure data storage providers;
information technology service providers;
debt collection agencies;
accountants, lawyers and other professional advisors.
We may also disclose your information to third parties where required or authorised by or under law.
We will not sell or provide your information to a third party for the purposes of direct marketing without your informed consent.
5. Direct marketing
Direct marketing is the promotion of goods and services directly to you including through emails, SMS, phone calls and the post. We will only send you direct marketing materials if you would reasonably expect to receive them, or you have consented. If it is impractical to gain your consent, we will always provide a simple and easy means for you to request not to receive the material.
6. Cross-border disclosure
Our preference is to use third party service providers who are based in Australia, however we may use overseas service providers to process your personal information if we reasonably believe that the overseas entity is subject to the same or similar privacy laws to those found in Australia, or you have otherwise consented to us disclosing your personal information to the overseas entity.
7. Holding your personal information
The security of your personal information is important to us and we take reasonable steps to protect your information from unauthorised access or disclosure and to ensure the accuracy and proper use of your personal information. We use a range of physical, technical and administrative measures such as:
hosting of our Platforms on servers located in secure third party centres, who we use reasonable measures to ensure employ best practice procedures in relation to the security of data;
undertaking reasonable due diligence in relation to the adequacy of technical and physical security measures used by any third party suppliers who will be processing or storing your personal information;
provision of an enterprise-level password management and encryption software to protect the passwords of staff who have access to our Platforms.
While we take all reasonable steps to ensure that your personal information is protected from misuse, interference or loss, no method of transmission over the internet, or method of electronic storage, is 100% secure. If a data breach occurs, and there is a real risk of harm to you as a result of such breach, we will notify you as soon as possible.
In addition to the measures we take to protect your personal information, you should ensure that you keep secret and regularly change any access passwords to any accounts on our Platforms and always logout of any secure pages.
When we no longer need your personal information for a permitted purpose and we are not required to keep it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy your personal information or to ensure that the information is de-identified.
9. Access and Correction
If you are a member, you can update your personal information at any time via your account on our Platform.
Upon your written request we will provide you with a copy of your personal information that we hold, unless there is a legitimate reason at law not to do so. We will take reasonable steps to correct your personal information if we are satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading. This extends to third parties that we have provided your personal information to unless it is impracticable or unlawful to do so.
10. Resolving concerns
If you have a concern or complaint relating to our handling of your personal information or if you feel that we have breached the privacy laws, please send a written note to us using the contact details provided below, outlining the nature of the complaint. We will endeavour to respond to your complaint within 30 days of receipt.
If your complaint is not satisfactorily resolved, you can contact us to discuss your concerns or the complaint may be taken to the Office of the Australian Information Commissioner.
11. Contact Us
If you have questions or suggestions please contact us at:
Mailing address: COHUTT, 29/232 Hutt St, Adelaide, SA 5000