PEOPLE PURPOSE TIME GROUP PRIVACY POLICY

1. ABOUT THIS POLICY

1.1  This Privacy Policy (Policy) applies to People Purpose Time Pty Ltd (ACN 695 614 754), MHR Lindfield Investments Pty Ltd (ACN 684 862 511) as trustee for MHR Lindfield Trust, Snow East Investments Pty Ltd (ACN 684 862 253) as trustee for Snow East Trust, and any other company identified by us from time to time as forming part of the group (People Purpose Time Group, we, our or us).

1.2  We are committed to protecting your privacy and understand the importance of protecting your personal information. This Policy outlines the types of personal information that we usually collect, how we collect and hold your personal information, the purposes for which we collect it, whether we are likely to disclose your personal information to overseas recipients, and your rights in relation to your personal information, including how to access or seek correction of your personal information, or make a complaint and how we deal with such complaints.

1.3  We will handle your personal information in accordance with this Policy, as well as relevant legislation including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

1.4  In this Policy, personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified.

1.5  This Policy does not apply to the personal information of our employees.

1.6  We may amend this Privacy Policy from time to time by posting an updated version of this Policy on our website.

2. TYPES OF PERSONAL INFORMATION WE COLLECT

2.1  The types of personal information we collect about you depends on the dealings you have with us, and may include:

(a)  identity information, such as your full name, company name, job title, marital status, gender, date of birth and signature;

(b)  contact information, such as your email address, phone number, postal or physical address and social media accounts;

(c)  financial information, such as payment information (including bank details and credit card details);

(d)  government identifiers, such as tax file numbers, driver licence details, Medicare or health fund details and passport details;

(e)  audio and visual information, such as photographs, videos, CCTV recordings and telephone recordings; and

(f)  technical data, such as login information, IP addresses, date and time of webpage visits, landing and exit webpages, webpages viewed, information downloaded and the site that linked you to our webpage.

2.2  If you are applying for a job with us, we may also collect your:

(a)  education history and qualifications;

(b)  employment history;

(c)  references;

(d)  results of police checks, working with children checks and right to work checks; and

(e)  health information.

3. DEALING WITH US ANONYMOUSLY OR USING A PSEUDONYM

3.1  Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question we will not record your name unless we need it to adequately handle your question.

3.2  However, for many of our functions and activities we usually require your name, contact information and other details to enable us to provide our services or products to you.

4. WAYS WE COLLECT YOUR PERSONAL INFORMATION

4.1  We may collect personal information from or about you in different ways, including:

(a)  directly from you, including through contact or other interactions with us (such as via email, telephone, live chat, social media, an application or online enquiry via our website), newsletter or mailing list sign-ups, online purchases or payment processing, your posts on publicly available sources, and job applications;

(b)  through automated means, including cookies and tracking technologies (such as Google Analytics and Google Ads), and CCTV;

(c)  from third parties, including third-party integrations (such as social media platforms and analytics platforms); and

(d)  from our affiliates.

4.2  If you apply for a job or contract position with us, we may also collect personal information about you from third parties and publicly available sources, including:

(a)  recruiters;

(b)  your current and/or previous employers;

(c)  government departments (including to verify your entitlement to work);

(d)  academic institutions; and

(e)  your nominated referees.

5. COLLECTION OF INFORMATION VIA OUR WEBSITE

5.1  When you visit our website, we may use ‘cookies’ or other similar tracking technologies that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our website may not work as intended for you if you do so.

5.2  We may also use analytics tools, including Google Analytics, to collect information about how visitors use our website.

5.3  Whilst we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit, search engine referrals and the internet protocol address assigned to your computer.

5.4  Our web pages may contain electronic images, known as web beacons. These electronic images enable us to count users who have visited certain pages on our website. Web beacons are not used by us to access your personal information – they are simply a tool we use to analyse which web pages are viewed, in an aggregate number.

6. PURPOSES FOR WHICH WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION

6.1  The purposes for which we collect, use and disclose your personal information depends on the dealings you have with us, and may include:

(a)  responding to your enquiries;

(b)  providing our goods or services to you;

(c)  marketing and promotional communications;

(d)  improving our website functionality and user experience;

(e)  conducting research and analytics;

(f)  internal business operations and administration;

(g)  complying with our legal obligations; and

(h)  considering employment applications.

7. DIRECT MARKETING

7.1  We may use your personal information to identify a product or service that you may be interested in. We may, with your consent, use the personal information we have collected about you to contact you from time to time by various means of communication including email, SMS or through social media advertising (including via Google Ads and Facebook) to tell you about new products or services and special offers that we believe may be of interest to you.

7.2  You can withdraw your consent to receiving direct marketing communications from us at any time by unsubscribing from the mailing list by using an electronic address set out in the marketing communication to send an unsubscribe message or contacting us using the details provided in this Policy.

8. SECURITY AND STORAGE

8.1  We may store your personal information electronically using cloud-based storage provided by Microsoft Azure. We take reasonable steps (including organisational and technological measures) to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. These measures include software security controls and limiting access to personal information to authorised staff who require it for their role.

8.2  We only keep your personal information for as long as it is required for the purpose for which it may be used or disclosed, or as otherwise required or authorised by applicable laws. If we no longer need to hold your personal information for any reason or we are no longer required or authorised by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.

9. OVERSEAS DISCLOSURES

9.1  In the course of providing our products and services to you, we may disclose your personal information to overseas recipients, including our cloud-based storage provider if they are located overseas.

10. ACCESS TO AND CORRECTION OF YOUR INFORMATION

10.1  We will take reasonable steps to ensure that the personal information