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PRIVACY POLICY
PURPOSE & INTRODUCTION
At The Baby Coach recognise the importance of privacy and protecting personal information. The purpose of this APP Privacy Policy is to summarise how we collect, use, hold, disclose and manage personal information. We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles.
CONSENT
By accessing The Baby Coach website and/or submitting your personal information to The Baby Coach through any means, you consent to the use of your information as set out in the Policy. If you do not agree with any term of the Policy, please do not use The Baby Coach's services or website.
TYPES OF PERSONAL INFORMATION COLLECTED AND HELD
We only collect information that is reasonably necessary for the proper performance of our activities or functions.
For Mothers the type of personal information we collect and use will depend on various factors such as the type of services you request or use and any applicable legal and regulatory obligations. This may include, but is not limited to, collection and use of the following kinds of information:
▪ Contact – information that allows us to communicate with you (e.g. e-mail, social media contact details, address, telephone number).
▪ Identity – information that allows us to identify you (e.g. name, date of birth, occupation, and government-issued identification).
▪ Professional – information that helps us to understand more about you including your overall health and that of your child, your experience with mothering and the like.
▪ Other individuals – information we request, or that you provide, about an individual other than yourself (e.g. your GP or Gynaecologist).
If you do not provide information, or the information provided is insufficient or inaccurate, The Baby Coach will be limited in its ability to provide its services to you.
While providing our services, we may collect a special category of personal information known as sensitive information such as your racial or ethnic origin, cultural norms you observe, religious beliefs/affiliations, philosophical beliefs, and health or disability information (including history). In accordance with the Privacy Act, sensitive information can, in most cases, only be disclosed with your consent. Any sensitive information will be used solely for the purposes of performing the services engaged by you and for no other purpose and will not be disclosed unless required by law.
HOW PERSONAL INFORMATION IS COLLECTED
This Policy relates to personal information collected by any means. It is The Baby Coach's usual practice to collect this personal information directly from you. However, often your personal information is collected through the use of The Baby Coach's website or in response to The Baby Coach's printed or online advertisements.
Information will be collected through
▪ Communications with The Baby Coach via phone, email or other means); and
▪ A range of other publicly available sources including newspapers, journals, directories, the Internet and social media sites. If and when we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the APPs and our Privacy Policy.
Photos and Images
We will not request that you supply photographs, scan photo ID, or capture and retain video image data of you in cases where simply sighting photographs or proof of identity documents would be sufficient in the circumstances.
USE OF PERSONAL INFORMATION
The Baby Coach collects your personal information so that The Baby Coach may use this information to:
▪ Send you marketing communications and information relating to our services which we think may be of interest to you;
▪ Statistical purposes and statutory compliance requirements
▪ Directly market recruitment services to you (you have a right to opt-out from receiving direct marketing emails); or
▪ Provide you with The Baby Coach’s services.
By accessing The Baby Coach websites and/or submitting your personal information to The Baby Coach through any means, you consent to the use of your information as set out above.
USE BY/DISCLOSURE TO THIRD PARTIES
The Baby Coach may use and disclose your personal information to third parties for the purposes it was collected, or for a related or ancillary purpose such as providing you with our services.
The Baby Coach will never give your information out to third-party marketing firms. The Baby Coach complies with the requirements of the anti-spam legislation and any electronic marketing will have the option for you to "opt out".
DATA QUALITY
The Baby Coach takes reasonable steps to ensure that the personal information it collects is accurate, up to date and complete.
In circumstances where your personal information has changed please contact us and we will endeavour to update and correct the information in accordance with applicable privacy law. The Baby Coach may also contact you from time to time to check the information is still correct.
DATA SECURITY AND STORAGE
Personal information is held in our information recording system. It is held in paper files or electronic files. The information record systems used by The Baby Coach include Microsoft 365.
The Baby Coach takes reasonable steps to protect the personal information we hold from loss, unauthorised access, and misuse. The use of locks and security systems assist The Baby Coach in protecting your personal information. Your personal information may be stored in hard copy documents, or electronically on The Baby Coach's software or systems. When no longer required, personal information is destroyed in a secure manner or deleted.
ACCESS TO INFORMATION
Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold.
Important exceptions include evaluative opinion material obtained confidentially in the course of our performing our services for you. Any evaluative material contained in references that we obtain will be collected under obligations of confidentiality.
If you wish to obtain access to your personal information you should contact The Baby Coach. The Baby Coach will take all reasonable steps to respond to such requests subject to any exemptions including where the provision of the requested information breaching another party’s privacy entitlements.
You may be required to verify your identity to the satisfaction of The Baby Coach which may include providing photographic proof of identity. Any request needs to be made in writing, in signed letter format sent to Privacy Officer, The Baby Coach, 5/2 Gary Street Morningside 4170 QLD.
The Baby Coach will complete your request as early as practicable, not later than 14 days from receiving the written request and proof of identify.
CORRECTION AND DELETION OF INFORMATION
If you find that personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to correct it
.
We will take such steps as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.
If you notify us that you are no longer seeking to utilise our services, you will be marked as ‘Inactive’ in our database which does not remove your information. Should you wish us to remove/delete your information entirely, please advise us of this in writing and we will do so unless otherwise permitted or required by law not to do so.
You may be required to verify your identity to the satisfaction of The Baby Coach which may include providing photographic proof of identity.
INFORMATION COLLECTED VIA ELECTRONIC MEANS
Users are advised that there are inherent risks in transmitting information across the internet. The Internet is an open system and The Baby Coach cannot guarantee that the personal information you submit will not be intercepted by others. Our website may include links to external websites operated by other organisations. They may collect personal information from visitors to their site. The Baby Coach cannot guarantee the content or privacy practices of any external websites and does not accept responsibility for those websites.
When you access The Baby Coach's website, The Baby Coach gathers information about users collectively. Such information may include sites that users visit most frequently and the services users access the most. The Baby Coach will only use such data anonymously and in the aggregate. By doing so, The Baby Coach can optimise the services it provides to you.
The Baby Coach may also collect personal information that individuals choose to provide via online forms or by email. Any personal information provided online is treated in the same manner as any personal information collected through other means (unless specifically outlined in this Policy).
It is important that you take all appropriate steps to protect your personal information.
CHANGES TO THIS POLICY
The Baby Coach may change this Policy from time to time for any reason and will update the Policy accordingly.
CONTACTING THE BABY COACH
Please contact The Baby Coach if you have a request relating to any of the following:
▪ if you would like to access, or correct, your personal information held by The Baby Coach;
▪ if you would like your personal information removed from the The Baby Coach database;
▪ if you would like to opt-out from receiving direct marketing e-mails; or
▪ any general queries relating to this Policy.
You may contact The Baby Coach by email or by telephone.
PRIVACY COMPLAINTS
If you have a privacy related complaint, you may contact The Baby Coach at the email address set out above. Your email should set out sufficient details of your complaint, including any alleged breach of applicable privacy law.
▪ The Baby Coach will consider your complaint and will contact you within a reasonable time to advise you of their determination and/or to request further details;
▪ In the event that The Baby Coach determines that there has been a breach of this Policy, we will take appropriate steps to rectify that breach, and will keep you informed of both the nature of the breach and the steps taken to rectify the breach.
▪ The Baby Coach will keep a secure record of all complaints.
▪ We may require reasonable time to consider and respond to any complaints (typically 30 days).
You may be required to verify your identity to the satisfaction of The Baby Coach which may include providing photographic proof of identity.
If we are unable to resolve your complaint, you can also make complaints to the Office of the Australian Information Commissioner.
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