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Privacy Policy 

This Privacy Policy of Adaptive Behaviour Pty Ltd ACN 658 666 721 (us, we, our) sets out how we treat the personal information that we collect, use and disclose and our procedures regarding the handling of personal, including the collection, use, disclosure and storage of information, as well as the right of individuals to access and correct that information. We operate the Adaptive Behaviour with domain name and ancillary platforms which facilitate the operation of the Adaptive Behaviour applications (Platform). 

From time to time, we may revise or update this Privacy Policy or our information handling practices. If we do so, the revised Privacy Policy will be published on the Platform. We may collect personal and/or sensitive information in order to conduct our business, to provide and market our services and to meet our legal obligations. 

By using the Platform or our services, or by providing any personal information to us, you consent to the collection, use and disclosure of your personal information as set out in this Privacy Policy.

The types of personal information we collect and hold

The types of personal information we may collect and hold includes (but is not limited to) personal information about:

  • your name, address, contact telephone number and other contact details such as your email address;
  • payment information (such as credit card or bank details);
  • other personal information required to provide our services in specific cases; and
  • details of your use of our products or services.

You are not obliged to provide personal information to us. However, in many cases, if you do not provide personal information to us, we may not be able to supply the relevant functionality of the Platform. 

We may collect sensitive information from you where the collection of such information is necessary to the ongoing development and improvement of the Platform, to better understand our user base, or for other reasons that will be disclosed to you prior to collecting the sensitive information. Sensitive information means, among other things, information relating to your race or ethnicity, gender or sexual orientation. However, we will only collect sensitive information from you if you voluntarily provide it to us, you authorise us to obtain it from a third party, where the collection of the information is required or authorised by or under an Australian law or a Court/Tribunal order, or otherwise where the collection is not prohibited under Australian law. 

In some circumstances, you may provide to us, and we may collect from you, personal information about a third party. Where you provide the personal information of a third party, you must ensure that the third party is aware of this Privacy Policy, understands it and agrees to accept it. If you are providing us with personal or sensitive information on behalf of a person who is under the age of 18 that you are the parent or guardian of, you understand that you are consenting to this Privacy Policy on their behalf as their legal guardian. 

How personal information is collected and held by us

We collect personal information in the following ways:

  • when you fill in and return to us a signed client form;
  • when you submit personal information through the Platform (such as when you send us a message or fill out an online form);
  • in person, for example, when you engage with our employees, agents, or customer service representatives; and
  • in the course of providing services to you.

We store personal and sensitive information in computer storage facilities and paper-based files. We take steps to protect your personal information against loss, unauthorised access, use modification or disclosure. Some examples of the steps we take to protect your personal information include:

  • ensuring there are suitable password protection measures and access privileges in place to monitor and control access to our IT systems;
  • imposing restrictions on physical access to paper files;
  • requiring any third parties engaged by us to provide appropriate assurances to handle your personal information in a manner consistent with Australian law; and
  • taking reasonable steps to destroy or de-identify personal information after we no longer need it for our business or to comply with the law.

Collection of personal information through activity

Information that may identify you as a user may be gathered during your access with the Platform.

The Platform may include pages that use ‘cookies’. A cookie is a unique identification number that allows the server to identify and interact more effectively with your computer or device. The cookie assists us in identifying what our users find interesting on the Platform.

A cookie may be allocated each time you use the Platform. The cookie does not identify you as an individual in our data collection process, however it does identify your Internet Service Provider.

You can configure your access to the Platform to refuse cookies. If you do so, you may not be able to use all or part of the Platform.

Analytics and Anonymisation

We may use Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses cookies (see above), to help us analyse how users use the Platform. Although Google Analytics records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you with us.

The information generated by the cookie about your use of the Platform will be transmitted to and stored by Google on servers in your country of residence. Google will use the information on behalf of us for the purpose of evaluating your use of the Platform, compiling reports on activity for us and providing us with other services relating to activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of these cookies. You can also opt out of being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser:

We may use other analytics services by third parties that are not Google which uses cookies to analyse how users use the platform. Although these services may record data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you with us. You can opt out of being tracked by these services providers, you can contact us through the contact information listed below. 

The purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal, and where relevant sensitive, information for a variety of business purposes including:

  • to provide the products or services you have requested from us;
  • to improve our business, products and services;
  • to promote our business to you;
  • to market our other services or products to you;
  • to handle and respond to your enquiries, complaints or concerns; and
  • to provide personal information to third parties as set out in this Privacy Policy. 

Direct marketing

We also collect, hold, use and disclose your personal information to:

  • notify you about the details of new services and products offered by us;
  • send you our newsletters and other marketing publications;
  • administer our databases for client service, marketing and financial accounting purposes; and
  • to comply with our legal requirements regarding the collection and retention of information concerning the products and services that we provide.

If you do not wish to disclose your personal information for the purpose of direct marketing or you would like to opt-out of receiving direct marketing communications, you can do so by contacting us using the contact details set out below, or by following the instructions to unsubscribe which are contained in a communication that you receive from us.

We will not use any sensitive information provided by you for the purposes of direct marketing. 

Third Party Service Providers

We may disclose your personal information to third parties who work with us in our business to promote, market or improve the services that we provide, including:

  • providers of customer relations management database services and marketing database services;
  • marketing consultants, promotion companies and website hosts
  • partnered businesses; and
  • consultants and professional advisers.

We may also combine your personal information with information available from other sources, including the entities mentioned above, to help us provide better services to you.

Where we do share information with third parties, we require that there are agreements or other mechanisms in place to ensure that your personal or sensitive information is dealt with in a manner that is consistent with this Privacy Policy and Australian privacy law. Otherwise, we will disclose personal information to others if you’ve given us permission, or if the disclosure relates to the main purpose for which we collected the information and you would reasonably expect us to do so.

We may share your personal or sensitive information with third parties that are in overseas jurisdictions. When doing so, we only share information with third parties that are either in jurisdictions that have privacy laws that are materially similar to Australia’s, or that have entered into an agreement with us agreeing to comply with Australian privacy law. 

How we handle requests to access your personal information

You have a right to request access to your personal information which we hold about you and to request its correction. You can make such a request by contacting us using the contact details set out in this policy.

We will respond to any such request for access as soon as reasonably practicable. Where access is to be given, we will provide you with a copy or details of your personal information in the manner requested by you where it is reasonable and practicable to do so.

We will not charge you a fee for making a request to access your personal information. However, we may charge you a reasonable fee for giving you access to your personal information.

In some cases, we may refuse to give you access to the information you have requested or only give you access to certain information. If we do this, we will provide you with a written statement setting out our reasons for refusal, except where it would be unreasonable to do so.

How we handle requests to correct your personal information

We will take such steps (if any) as are reasonable in the circumstances to make sure that the personal information we collect, use or disclose is accurate, complete, up to date and relevant.

If you believe the personal information we hold about you is inaccurate, irrelevant, out of date or incomplete, you can ask us to update or correct it. To do so, please contact us using the contact details listed below.

How to contact us or make a complaint

If you have any questions about this Privacy Policy, if you wish to correct or update information we hold about you or if you wish to request access or correction of your personal information or make a complaint about a breach by us of our privacy obligations (including the way we have collected, disclosed or used your personal information), please contact:

Andrew Reilly
Unit 2 20 French St, Footscray

We will acknowledge and investigate any complaint about the way we manage personal information as soon as practicable. We will take reasonable steps to remedy any failure to comply with our privacy obligations.