Effective date: 1 July 2018
Peak Persona Pty Ltd (referred to in this document as we, us or our) recognises that your privacy is very important and we are committed to protecting the personal information we collect from you. This policy sets out how we collect, use, disclose and otherwise manage personal information about you.
Types of information collected
We may collect and hold personal information about you, that is, information that can identify you, and is relevant to providing you with the personal coaching and other services provided by us. In particular, we may collect your: name; age; date of birth; contact details; and payment method and details.
We may also collect and hold sensitive information about you, including information shared by you during your reflection videos about your health, religious beliefs or affiliations, racial or ethnic origin, criminal record, political opinions, relationships and sexual preferences or practices.
Purpose of collection
The personal information that we collect and hold about you, depends on your interaction with us. Generally, we will collect, use and hold your personal information if it is reasonably necessary for or directly related to the performance of our functions and activities and for the purposes of:
- providing personal coaching or other services to you;
- providing you with information about other goods and services that we and other organisations that we have affiliations with, offer that may be of interest to you;
- facilitating our internal business operations, including the fulfilment of any legal requirements;
- analysing our services and customer needs with a view to developing new or improved services; and
- to apply machine-based learning practices to the information you provide to develop insights and trends in connection with our services.
Except as otherwise permitted by law, we only collect sensitive information about you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions, as set out above.
Method of collection
Personal information will generally be collected directly from you through the use of any of our standard forms, over the internet, via email or a video submission, or through a telephone conversation with you. There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
Failure to provide information
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you with the services you are seeking.
If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
Use and disclosure
Generally, we only use or disclose personal information about you for the purposes for which it was collected (as set out above). We may disclose personal information about you to:
- our related entities and other organisations with whom we have affiliations so that those organisations may provide you with information about goods and services and various promotions.
Third Party Services
Disclosure of personal information overseas
We are not likely to disclose your personal information overseas, except as permitted by the Privacy Act, unless we otherwise advise you in writing.
We store your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from interference, misuse, loss, unauthorised access, modification or disclosure, including electronic and physical security measures.
Access and correction
You may access the personal information we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access).
We may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
Complaints and feedback
If you wish to make a complaint about a breach of privacy, please contact us using the details below and we will take reasonable steps to investigate the complaint and respond to you.
For more information about privacy in general, you can visit the Office of the Information Commissioner’s website at www.oaic.gov.au.
If you wish to make a complaint about the collection, use or disclosure of your personal information, please contact our privacy officer, and we will work with you to resolve the issue.
If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Information Commissioner. To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.