Privacy Policy

This is the privacy policy of Essemy also referred to this document as “we”, “us”, “our company”, Essemy PTY LTD or www.essemy.com.au

We are committed to protecting your privacy and will handle your personal information in accordance with this privacy policy and in accordance with our obligations under the Privacy Act 1988 (Cth); We also comply with the: Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth) as amended from time to time.

What is personal and sensitive data?

Personal information is broadly, any information about or relating to you which can be used to identify you. Sensitive information is a special subset of personal information which includes your health information.

For the purposes of this privacy policy, any references to “personal information” includes “sensitive information”.

What personal data will we collect?

The personal information that we collect about you will be relevant to effectively marketing products and services and managing our relationship, such as your:

  • name, residential and business postal, email addresses, telephone and/or mobile number and other relevant contact or business details;
  • family and marital status, date of birth, gender, employment details;
  • marketing preferences;
  • facilitator police checks;
  • facilitator PTY LTD insurances protected by 2FA authentication;
  • facilitator bank account details, protected by 2FA authentication;
  • facilitator secondary contact person;
  • usage of and data supplied to mobile applications and materials delivered on-line

How do we collect your personal information?

We collect personal information from you (or persons authorised by you):

  • in person, via mail, email, mobile applications, our website or other internet applications (e.g. Facebook, Twitter)
  • by phone for verification and training purposes
  • from forms, claims and other correspondence
  • by registering to use our services or by participating in surveys
  • from comments, photos and/or videos submitted by participants under our promotional terms and conditions.

We also collect Personal Information from “Partner” organisations with whom we have established business relationships and from third parties such as referees, software companies, financial, government or regulatory agencies and research companies.

How we store your data?

Depending on your relationship with us your data may be stored in multiple systems. For example, if you are a facilitator, contact, lead or prospect, your data will be stored in our CRM system, Pipedrive, hosted in their servers. Your data will also be stored in our Sales and Finance system, Xero, hosted in their servers.

How long will we keep your data for?

The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

We will retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing legal need to retain it. Following that period, we’ll make sure it is deleted within 1 month.

How do we use your personal information?

We use the personal information we collect, under our contract with you, to market or provide our products and services to you (some of which may be provided by third party providers on our behalf) including but not limited to the delivery of Training and Consulting Services. It is also used to record the effectiveness of our service delivery models and in managing our relationship with you.

We may also use your personal information for related purposes which you would reasonably expect for our legitimate interest in complying with applicable laws, developing products and services that may better serve our clients, assessing your possible interest in any such products or services and with your consent, telling you about these, improving our service delivery, resolving any legal and/or commercial complaints or issues and performing other functions and activities relating to our business.

Marketing

If you have agreed to receive marketing from us, we may, from time to time, use the data we have collected about you to let you know about our products and services and that of our Partners.

We may communicate with you by telephone, electronically or mail, about our current and new products and services, including participation in any programs we develop.

How to stop marketing activities?

You are free to request us to stop marketing to you at any time and from giving your data to our Partners or 3rd Parties. You can do this without any detriment to you by:

What happens if you do not give us this information or do not wish us to use or disclose it for a purpose?

It is your right not to give us any information and not to identify yourself to us (interact anonymously or using a pseudonym) or to tell us that you do not wish us to use or disclose your personal information for a particular purpose or in a particular way. However, if you choose not to give us the personal information we request, or do not identify yourself to us or ask us not to use or disclose your information for a particular purpose, we may not be able to provide you with relevant services.

Do we disclose information to third parties?

We may share or disclose your personal information, for the purposes of collection described above, to third parties or individuals, some of which may be located overseas in certain circumstances, including:

  • Corporate partner organisations that deliver services with us or on our behalf; third party vendors who placed targeted online ads for us on their sites and mailing houses.
  • Other service providers, for example, our advisors for the purposes of obtaining legal advice or our technology providers.
  • Facilitators delivering services you have purchased
  • Fraud prevention agencies, government bodies and regulators including law enforcement bodies such as the Police, professional associations and industry bodies.
  • Where disclosure is otherwise authorised or required by or under applicable laws or any other legal or regulatory process.

We may disclose your personal information with your consent (if so required by applicable laws), to prevent and detect fraud and/or to protect and defend Our rights and property.

Any third parties to whom we disclose or permit access to your personal information, in the course of providing services on our behalf, will be subject to strict contractual restrictions to ensure that they protect personal information and keep it confidential, consistent with relevant privacy and data protection laws.

In the event that we or any part of our business undergoes re-organisation or is sold or licensed to a third party, any personal information we hold about you may be transferred to that re-organised entity, licensee or third party.

Overseas disclosures

Some organisations to which we disclose personal information may be located outside Australia. We will not disclose your personal information to an overseas recipient without taking such steps as are reasonable in the circumstances to ensure that the overseas recipient will not breach the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

If you are a resident in the European Economic Area (EEA) we may use service providers based outside the EEA. We will take steps to ensure that your personal information will be afforded the level of protection required of us, under and in accordance with this Privacy Policy and applicable data protection laws and in accordance with current legally recognised data transfer mechanisms, such as appropriate European Commission approved standard contractual clauses (see https://ec.europa.eu/info/law/law-topic/data-protection_en).

How is information from our websites and other applications collected and used?

We collect information when you:

  • complete an online form
  • give us your email address
  • access and use any of our services through our website and other applications.

We collect data from our website and other applications to help us understand which are the most popular items and when the peak usage times are, along with other information that helps us improve the content and make the navigation easier. Some of this information may be used to develop new services or enhance existing services provided to our prospects and customers.

Cookies

When you visit our website, it will send a cookie to your computer. This is a small piece of information stored on your hard drive which tells us that your computer has accessed our website. The cookie by itself will not be able to identify you. If you do not want to use cookies, you can set your browser to reject them. However, by doing this, some website features may not work.

Mobile Application Data

Data from mobile applications may include information that you supply to the application as well as location information provided by the device location services, where you have given permission for the application to access these location services. This enables us to provide you with useful services such as finding facilitators and training services close to your location.

Analytics

We may use remarketing and web based analytics with Google Analytics to advertise online. Third-party vendors, including Google, show our advertisements on website sites across the Internet. We, and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on someone’s past visits to our website(s).

What about linked websites?

We provide links to third party sites. Since we do not control these websites, we encourage you to review the privacy policies posted on these third party sites. We are not responsible for any practices on linked websites that might breach your privacy.

Storage and security of your personal information

We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and unauthorised access, modification or disclosure and to destroy or de-identify personal information we no longer need, wherever possible.

We will keep member personal information for as long as we maintain our relationship with you or otherwise as required for our business operations or by applicable laws, including to enforce our rights, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes.

How to access and correct your personal information

We take reasonable steps to ensure that the information we hold about you is accurate, up-to-date, complete and relevant when we use it or disclose it. You should contact us if you think your personal information is wrong.

If you have a question about this privacy policy or want to access or otherwise correct your personal information you can:

A request for access needs to include a full description of the personal information requested. If making a request in person, you will be asked for two forms of identification, one of which must have a photograph on it. If you request information over the phone, we will ask you identity-related questions so we can verify you.

Your request for access to your personal information will be documented, as will details of the request and the identity of the person giving it to you. We will generally give access unless an exemption applies to certain information.

If you believe that the information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you can request its correction. If we are satisfied that the information needs to be corrected, we will take reasonable steps to ensure that information is corrected and notify you of the correction. However there may be circumstances in which we may have to refuse a request for correction. In such a case you can request that we associate a statement, with that personal information, that you made a request for correction.

You will not be charged for accessing or correcting your information. We might have to charge for the reasonable cost of processing your access request, including photocopying, supplying written reports, administration and postage.

How we will respond to your request

We will acknowledge receipt of your request within 2 business days of receiving your request. We will do our best to deal with your request within 5 business days.

If we cannot help with your request, you will receive a written explanation as to why and details of what you can do to take the matter further if you are not satisfied with our response.

We will do our best to resolve your complaint as quickly as possible. However, if you are not satisfied with the result of your complaint to us, you can refer your complaint to the:

Office of the Australian Information Commissioner

  • Online privacy complaint form gov.au
  • call 1300 363 992
  • mail GPO Box 5218, Sydney NSW 2001

Need further information?

For more information about privacy in general, you can visit the Office of the Australian Information Commissioner’s website at oaic.gov.au.

Updating our Privacy Policy

We may review, amend or revise our Privacy Policy and the way we handle personal information from time to time. We will post the updated Privacy Policy on our website(s) and its terms will take effect from the date of posting.

Privacy Policy – Effective 22/07/2019

Provided by www.cohesis.com.au