The Positivity Institute Pty Limited ACN 123 446 113 (“TPI” or “we”) acknowledges and takes seriously its obligations under the Privacy Act 1988 (Cth) and is committed to the protection of personal privacy. TPI has adopted a set of privacy principles based on the Australian Privacy Principles contained in Schedule 1 of the Privacy Act.
This policy sets out TPI’s privacy protection principles. These are principles that TPI has adopted in order to protect information about individuals. These principles deal with the collection, use and disclosure of personal information as well as access to information.
3. WHAT INFORMATION WE COLLECT
We may collect personal information about you (and if you are an organisation, your officers, employees, consultants, subcontractors, agents and/or students (“Personnel”) including your name, address, age, email address and telephone number. We also collect information provided to us by you or your Personnel so that we may provide you with our positive psychology coaching and related services, including information in relation to your wellbeing and character traits.
4. HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect most personal information directly from you or your Personnel. For example, we will collect personal information when you or your Personnel when you/they fill enter into an agreement with us, deal with us over the telephone, send us a letter, send us an email, meet with us in person or when you/they complete questionnaires, assessments and other forms for purposes of providing you/them with our services.
5. HOW WE KEEP YOUR INFORMATION
We protect any personal information that we hold about you from misuse or loss. We also protect it from unauthorised access, modification and disclosure. Your personal information can only be accessed by people authorised by us, and for the purpose for which we hold the information. Your personal information may be stored in hard copy documents or electronically in our systems. We maintain physical security, such as locks and security systems, over our paper and electronic data store and premises. We also maintain computer and network security. For example, we use security measures for the Internet and other security measures such as identification codes and passwords to control access to computer systems.
6. HOW WE USE INFORMATION
If you do not provide us with certain information, we may not be able to deal with you, or provide you with our products and services. The primary purpose for TPI collecting your and your Personnel’s personal information is usually to establish a commercial agreement with you and supply our services to you. We may also use your personal information we collect about you for other purposes including:
• Helping us to identify goods and services that may interest you;
• Maintaining our relationship with you;
• Conducting market or customer satisfaction research including obtaining feedback from you or your Personnel;
• Performing our internal administration and operations including accounting, risk management, record keeping, archiving, systems development and staff training; and
• Debt recovery.
To the extent that the personal information is sensitive information, we will only use it or disclose it for the purpose of providing our services to you or your Personnel.
7. DISCLOSING TO THIRD PARTIES
We only disclose your personal information to third parties with your consent, where it is required in order for us to provide you with our services or where we are otherwise entitled or required to do so. The types of third parties we may disclose your personal information to include:
• Debt collection agencies to initiate debt collection services;
• Regulatory bodies, government agencies, law enforcement bodies, Courts or other parties we are authorised or required by law to disclose information to;
• Our agents, contractors and external advisers who we engage to carry out our functions and activities from time to time or who assist us to carry out our functions and activities. For example, we may provide names and addresses to a mailing house to mail account statements to you and other customers, to our legal advisers in the event of a dispute or to our accountants for purposes of them providing accounting services to us. In these situations, we prohibit third parties from using your personal information except for the specific purpose for which we supply it; and
• Service providers who we retain for purposes of generating and storing reports and assessments and other ancillary results or documents based on information you and your Personnel have provided us with during the course of our engagement with you. These are likely to be entities in the United Kingdom or the United States of America;
• Our related entities.
8. MARKETING AND PRIVACY
Serving customers well is fundamental to our business. As part of this service we may use personal information we have collected to identify products and services that may benefit you. We may contact you from time to time to tell you about new or existing products or services or special prices available on products or services. You can contact us at any time if you do not want to receive marketing information from TPI. We will process these instructions as soon as practical. TPI does not disclose names and addresses to third parties for purpose of allowing them to market their products and their services.
9. KEEPING YOUR INFORMATION UP TO DATE
If we have accurate information about you, it enables us to provide you with the best possible service. We take reasonable steps to ensure that your personal information is accurate, complete and up to date at the time of collecting, using or disclosing the information. If you learn that current personal information we hold about you is inaccurate, incomplete or out of date, you should contact us using the contact details below. We will promptly update any personal information that is inaccurate, incomplete or out of date.
10. REQUESTING DETILS ABOUT YOUR PERSONAL INFORMATION
You can find out what personal information TPI holds about you. Your Personnel can also find out what personal information TPI holds about it. You/your Personnel should contact us if you wish to find out about such personal information that we hold by using the contact details below. We will need to verify your identity or your Personnel’s identity before giving access. We will normally be able to deal with your request immediately. If the request is complex we will ask you to put the request in writing. We may not be able to tell what personal information we hold about you in certain circumstances including where the law prevents us from disclosing the information. If we are unable to tell you what personal information we hold about you, we will give the reasons why.
11. AMENDMENTS TO POLICY
12. CONTACTING US AND HOW TO MAKE A COMPLAINT
You are entitled to complain if you believe that your privacy has been compromised. If you wish to make a complaint, please send an email or letter to us using the contact details below.
You may also make a complaint to the Office of the Australian Information Commissioner (OAIC) in writing through its online privacy complaint form or by mail, fax or email (subject to certain conditions prescribed by the OAIC). The OAIC’s contact details are set out at www.oaic.gov.au/about-us/contact-us. We ask that you allow us a period of 30 days to consider and respond to your email or letter of complaint before making a complaint to the OAIC, and that if you do not receive a response from us within 30 days of your email or are dissatisfied with the response, you then take steps to make a complaint to the OAIC should you so wish.
If you wish to make contact with TPI concerning your personal information whether it be for access, modification or for complaint you may contact the Privacy Officer via the form below or mail to:
The Positivity Institute PO Box 918. DOUBLE BAY NSW 1360