Privacy Policy
1. INTRODUCTION
This
document sets out the privacy policy of SYSTEMIQ GROUP
PTY LTD ACN 623 894 002 (referred to in this privacy policy as 'we', 'us',
or 'our').
This privacy policy
applies whenever we collect your personal information (or personal data). This
includes between you, the visitor to this website (whether directly as our
customer or as personnel of our customer), and us, the owner and provider of
this website and also where we are directed by a third party to process your personal
information. This privacy policy applies to our use of any and all data
collected by us or provided by you in relation to your use of the website and
the provision of our services to you.
We take our privacy
obligations seriously and we've created this privacy policy to explain how we
collect and treat your personal information. Personal information is that
information which is identifiable as being about you.
We comply with:
(a)
the
Australian Privacy Principles established by the Privacy Act 1988 (Cth); and
(b)
to the
extent the European Union's General Data
Protection Regulation 2016/679 ('GDPR')
applies to us and our use of your information, the GDPR.
The personal information
we collect may include the following:
(a)
name;
(b)
mailing or
street address;
(c)
email
address;
(d)
social
media information;
(e)
telephone
number and other contact details;
(f)
age;
(g)
date of
birth;
(h)
credit
card or other payment information;
(i)
information
about your business or personal circumstances;
(j)
information
in connection with client surveys, questionnaires and promotions;
(k)
your
device identity and type, I.P. address, geo-location information, page view
statistics, advertising data and standard web log information;
(l)
information
about third parties; and
(m)
any other
information provided by you to us via this website or our online presence, or
otherwise required by us or provided by you.
We endeavour to ensure
that information we collect is complete, accurate, accessible and not subject
to unauthorised access.
We may collect personal
information either directly from you, or from third parties, including where
you:
(a)
enrol in
any of our Online Courses, Subscriptions, Coaching Sessions or Affiliate
Program;
(b)
contact us
through our website;
(c)
communicate
with us via email, telephone, SMS, social applications (such as LinkedIn,
Facebook or Twitter) or otherwise;
(d)
use our
automated referral system or manual referral service;
(e)
interact
with our website, social applications, services, content and advertising; and
(f)
invest in
our business or enquire as to a potential purchase in our business.
We may also collect
personal information from you when you use or access our website or our social
media pages. This may be done through use of web analytics tools, 'cookies' or
other similar tracking technologies that allow us to track and analyse your
website usage. Cookies are small files that store information on your computer,
mobile phone or other device and enable and allow the creator of the cookie to
identify when you visit different websites. Cookies may be used
to serve relevant ads to website visitors through third party services such as
Google Adwords. These ads may appear on this website or other websites you
visit. If you do not
wish information to be stored as a cookie, you can disable cookies in your web
browser.
We may use Google
Analytics to collect and process data, including when you use third party websites
or apps. To find out more see How Google uses data when you
use our partners’ sites or apps.
We collect and use
personal information for the following purposes:
(a)
to provide
services or information to you, including our Online Courses;
(b)
for record
keeping and administrative purposes;
(c)
to provide
information about you to our contractors, employees, consultants, agents or
other third parties for the purpose of providing services to you;
(d)
to improve
and optimise our service offering and customer experience;
(e)
to comply
with our legal obligations, resolve disputes or enforce our agreements with
third parties;
(f)
to send
you marketing and promotional messages and other information that may be of
interest to you and for the purpose of direct marketing (in accordance with the
Spam Act 2003 (Cth)). In this regard,
we may use email, SMS, social media or mail to send you direct marketing
communications. You can opt out of receiving marketing materials from us by
using the opt-out facility provided (e.g. an unsubscribe link);
(g)
to send
you administrative messages, reminders, notices, updates, security alerts, and
other information requested by you; and
(h)
to
consider an application of employment from you.
This clause applies to
personal information, other than in the European Economic Area. We may disclose
your personal information to cloud-providers, contractors and other third
parties located inside or outside of Australia. If we do so, we will take
reasonable steps to ensure that any overseas recipient deals with such personal
information in a manner consistent with how we deal with it.
Where you are a resident
of the European Union and the GDPR applies, please see below (clause 10).
We've endeavoured to
ensure that our use and collection of your data is clear and as transparent as
possible, but in the interests of keeping this policy concise it's not possible
to list every circumstance in which we will use your data.
We may use third party
service providers for disaster recovery services. To the extent necessary to
receive those disaster recovery services, we will provide your data to that
third party service provider.
We may also use third
party service providers to audit the infrastructure and applications we use to
store your data. To the extent necessary to receive those audit services, we
will provide your data to that third party service provider.
We take reasonable steps
to ensure your personal information is secure and protected from misuse or
unauthorised access. Our information technology systems are password protected,
and we use a range of administrative and technical measures to protect these
systems. However, we cannot guarantee the security of your personal
information.
Our website may contain
links to other websites. Those links are provided for convenience and may not
remain current or be maintained. We are not responsible for the privacy
practices of those linked websites and we suggest you review the privacy
policies of those websites before using them.
If you wish to request
access to the personal information we hold about you, please contact us using
the contact details set out below including your name and contact details. We
may need to verify your identity before providing you with your personal
information. In some cases, we may be unable to provide you with access to all
your personal information and where this occurs, we will explain why. We will
deal with all requests for access to personal information within a reasonable
timeframe.
Where you are a resident
of the European Union and the GDPR applies to your personal information, you
have the right to ask for 'subject access request' or 'SAR' being a copy of
your personal data held by us. Where we do hold such data about you we will provide
you with a copy of the data we hold about you. This will be in a commonly used
machine-readable file where you request us to e-mail the information to you. We
will also give you a description of the data, tell you why we are holding it
and tell you who we could have disclosed it to.
If you think that any
personal information we hold about you is inaccurate, please contact us using
the contact details set out below and we will take reasonable steps to ensure
that it is corrected. We will also stop processing data on your request and you
may also request that we delete the data held about you.
If you would like a copy
of the information which we hold about you or believe that any information we
hold on you is inaccurate, out of date, incomplete, irrelevant or misleading,
please email us using the contact details set out in the 'Contact Us' section below.
We reserve the right to
refuse to provide you with information that we hold about you, in certain
circumstances set out in the Privacy Act
1988 (Cth).
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.
If you are an EU resident
and the GDPR applies, we will wherever possible, ensure your data remains in
the EEA.
Information that we
collect in the EEA may from time to time be stored, processed in or transferred
between parties located in countries outside of the EEA which may not have as
stringent data protection laws as found in the EEA.
Some of our third party
service providers may be also located outside the EEA. If we transfer your data
outside the EEA in this way (where you are a resident of the European Union and
the GDPR applies to your personal information) we will ensure that the third
party provider we use is compliant with the GDPR and that your privacy
continues to be protected as outlined in this privacy policy.
If Article 27 of the GDPR
applies to us, we will appoint a representative within the European Union in
accordance with the GDPR. Please contact us and we will let you know the
representative's contact details.
If you wish to complain
about how we handle your personal information or information held by us, please
contact us using the details set out below including your name and contact
details. We will investigate your complaint promptly and respond to you within
a reasonable time.
For data which is subject
to the GDPR, you have the right to lodge a complaint with the local regulator
in your jurisdiction in Europe if you do not feel we have
adequately upheld your rights under GDPR.
For further information about our privacy
policy or practices, or to access or correct your personal information, or make
a complaint, please contact us using the details set out below:
By providing personal
information to us, you consent to our storage, maintenance, use and disclosing
of personal information in accordance with this privacy policy.
We may change this privacy
policy from time to time by posting an updated copy on our website and we
encourage you to check our website regularly to ensure that you are aware of
our most current privacy policy.