Privacy Policy

The Jonah Group Pty Ltd ABN 27 106 685 429 (we, us or our) works with businesses to help create a physically and mentally safe workplace and improve culture and performance.

We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our consulting services, workshops, webinars, hotlines, website and any other services we provide (collectively, our Services).

Personal information

We may collect information directly from you (such as when you use the contact us form on our website) or from a third party such as your employer where it is not practicable to collect the personal information directly from you (such as when your employer engages us to provide a workshop).

The types of personal information we may collect about you include:

  • your name;
  • your contact details, including email address, mailing address, street address and/or telephone number;
  • your job details, including your employer’s details and your job title;
  • your preferences and/or opinions;
  • information you choose to share with us about your work (such as your management challenges) and any assistance you request from us (such as tips for tackling your management challenges);
  • information you provide to us through surveys we carry out (usually in an anonymous format);
  • your sensitive information as set out below;
  • details of products and services we have provided to you and/or that you have enquired about, and our response to you;
  • when you visit our website, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
  • when you visit our website, information about your access and use of our online Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
  • additional personal information that you provide to us, directly or indirectly, through your use of our Services and associated applications from which you permit us to collect information; and
  • any other personal information requested by us and/or provided by you or a third party.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

  • to enable you to access, attend, participate in and use our Services and any associated applications;
  • to contact and communicate with you about our Services;
  • for internal record keeping, administrative, invoicing and billing purposes;
  • to provide, operate and improve our Services and associated applications;
  • in a de-identified format for analytics, market research and business development;
  • if you are a customer of ours or the customer of our business partner, for advertising and marketing, including to send you promotional information about our products and services and information about third parties (including our business partners) that we consider may be of interest to you;
  • to comply with our legal obligations and resolve any disputes that we may have; and
  • if you have applied for employment with us; to consider your employment application.

Disclosure of personal information to third parties

We may disclose personal information to:

  • third party service providers for the purpose of enabling them to provide their services to us, including (without limitation)
    • Zoom Video Communications Inc (for video calls);
    • Dropbox International Unlimited Company (for internal storage of our files);
    • Acuity provided by Squarespace Ireland Limited (for time scheduling);
    • Microsoft Outlook via Microsoft Pty Ltd (for emails);
    • com Pty Ltd (for emails);
    • Servcorp Limited (for virtual receptionist services);
    • Telstra Corporation Limited (for our phone services);
    • Survey Monkey Inc (where we perform surveys);
    • WordPress provided by Aut O’Mattic A8C Ireland Ltd (for our website and cookies); and
    • professional advisors such as our accountant and lawyer (as required to run our business or receive professional advice related to our business);
  • our employees, contractors and/or related entities;
  • our existing or potential agents or business partners;
  • our banking and payment providers;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; and
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.

Disclosure overseas: We may disclose personal information overseas where reasonably required to provide our Services. For example, many of the above listed service providers store data in the United States of America.

The countries to which we send personal information for the purposes listed above may not have the same privacy laws as Australia. If we disclose your personal information to third parties in other countries:

  • we will perform the disclosure in accordance with the requirements of the Australian Privacy Principles; and
  • we will protect the transferred personal information in accordance with this Privacy Policy.

How we treat personal information that is also sensitive information

Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

We will not collect sensitive information about you without your consent, unless permitted, required or authorised by law.

We do not provide a health service. However, we may collect sensitive information about you if you choose to share sensitive information with us when receiving our Services. For example, if you choose to speak with us about a mental health concern you are experiencing.

Your sensitive information may only be used and disclosed for:

  • the primary purpose for which it was collected;
  • any purposes you consent to;
  • for reasonably expected secondary purposes directly relating to the primary purpose for which the sensitive information was collected, such as when using third parties to directly assist us in providing our Services (e.g our file storage provider where we record a file note of our conversation about your mental health concern); and
  • for referring you to medical or health service providers in circumstances where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impractical for us to obtain your consent.

Sensitive information may also be used or disclosed if required or authorised by law.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us. For example, if you make a general enquiry, you may choose to use a pseudonym.

Access: You may request details of the personal information that we hold about you.  An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. We will respond to your request in writing within 30 days and we will tell you if we cannot provide access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date. Please note, in some situations, we may be legally permitted to not correct your personal information. We will respond to your request in writing within 30 days and we will tell you if we cannot correct your information.

Complaints: If you wish to make a complaint about how we have handled your personal information, please contact us using the contact details at the end of this Privacy Policy and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. If your complaint is not satisfactorily handled by us, you may choose to lodge a formal complaint with the Office of the Australian Information Commissioner by phone on 1300 363 992, online at http://www.oaic.gov.au/privacy/making-a-privacy-complaint or by post to: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW 2001.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures (such as password protection and anti-virus software) to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies and web beacons

We use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

We may use web beacons on our online Services from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

Links to other websites

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact our Privacy Officer at:

The Jonah Group Pty Ltd ABN 27 106 685 429

Email: robert.wentzel@jonahgroup.com.au

Address: 2/61 Centennial Circuit, Byron Bay, NSW 2481

Phone: +61 (2) 8324 1421

Last update: 01 June 2020

© LegalVision ILP Pty Ltd

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