Privacy Policy

Privacy Policy - www.espyconnect.com.au

This document describes how by The Put Institute Ltd trading as Espy Connect (ABN 24 609 980 510) (we or us or our) complies with the requirements of the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), and any other applicable privacy laws in Australia in respect of the website www.espyconnect.com.au (including all related mobile applications) (Sites) and the Services, as described in more detail in the Terms for the Sites.

This Privacy Policy sets out how we handle personal information to comply with our obligations.

Collection of personal information

What kinds of personal information do we collect, use and hold?

The kinds of personal information that we collect, use and hold include names, contact details and all other personal information provided by our members when they post or otherwise provide their personal information to the Sites and other information that is relevant to our functions and activities.

When you create a profile (Profile) on the Espy Connect directory on our Sites (Directory), we collect the personal information that you may choose to provide or post to your Profile, such as, your educational background, employment history, information relating to your skills and any comments, photos, videos or materials that you upload to your Profile including any sensitive information such as your membership of professional or trade associations or trade unions or health information.

We refer to all information, documents, postings, messages, text, files, images, photos, video, audio or other materials containing personal information (including any sensitive information) which you upload to your Profile or transmit to other users of the Sites via the Directory or otherwise on or through the Sites as "Your Content".

We may also collect such other personal information that you provide through the Sites when you communicate with other registered users (Users) of the Sites through the Services.

We do not use government related identifiers as our own identifiers.

How do we collect personal information?

We usually collect personal information directly from individuals, such as when you provide Your Content via the Services.

We collect personal information about service providers (Providers), such as names and contact details, directly from the National Disability Insurance Agency (NDIA) for inclusion in the Directory.

We review, check and update such information to ensure that it is as accurate and up to date as possible, before including it in the Directory.

When you provide us with personal information about other individuals, you should make them aware of this Privacy Policy and obtain their consent to you providing their details to us.

We may collect your personal information when you communicate with us, such as when you:

make inquiries about us or our Services or contact us for any other reason so that we can process, deal with and respond to your queries or other issues including any complaints; or

apply to register for membership with us or subscribe for any of our Services; or

create a Profile and when you upload Your Content to the Sites;

seek information on Providers through the Sites; or

use our Sites; or

subscribe to a newsletter, fill out a form or survey, enter or participate in any promotions or competitions; or

call our call centre. Calls may be recorded by us for quality review purposes; or

otherwise communicate with us.

What happens if you do not provide your personal information to us?

If you do not provide personal information that we request in connection with our activities, we may not be able to provide our products or services to you. For example, if you do not provide your name and contact details to become a member of the Sites, you will not be able to search for Providers on the Directory.

Why do we collect, use, hold and disclose your personal information?

We collect, use, hold and disclose your personal information as necessary for purposes directly related to our functions and activities or as otherwise described to you at the time of collection.

We also collect, use, hold and disclose such personal information as described below.

Type of personal information collected

Purpose

Names and contact details

To allow you to create an Account with us and so that we can provide our Services to you and information about our Services and to communicate with you.

Any personal information contained in Your Content

To allow you to:

advertise your goods or services on the Directory;

communicate with other Users; or

provide Reviews via the Directory; or

any other purpose related to your use of the Sites and the Services.

Names, contact details, transaction and experience information such as information on your transactions and our communications with you and your use of, or interest in, our products, the Services, or content of the Sites, or products, services or content offered by others via the Services

For market research and direct marketing including promotions and newsletters;

to send you any promotional information from us or about or from third parties that we think may be of interest to you;

to develop and display content and advertising tailored to your interests on our Sites and other sites;

to verify your eligibility and deliver prizes in connection with any competitions, promotions or sweepstakes.

Names, contact details, qualifications, credit card information for payments, membership of professional or trade associations of Providers appearing in the Directory

To:

manage your Account;

provide you with customer support;

include, update or correct Providers' details in the Directory;

pre-qualify Providers to participate in the Directory;

protect against or identify possible fraudulent transactions;

perform background screening, if necessary, which may include the use of third parties and otherwise as needed to manage our business

Where we have collected personal information relating to Providers from the NDIA, which we later update to ensure that it is as up to date and accurate as possible, we disclose such information to NDIA to ensure that its records are also updated accordingly.

Do we use cookies or other web tracking systems?

We track traffic patterns throughout the URLs registered to us.

We use "cookies" on our Sites. A "cookie" is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser, but not you. If you want, you can disable your web browser from accepting cookies. If you do so, you can still access our Sites, but not all Services may be available.

We may automatically collect general statistical information on our Sites about visitors to our Sites, such as IP addresses, browsers used, dates visited, pages visited and number of visitors.

However, such information does not refer to individuals by name or their contact details. We use this data in aggregate to improve our Sites and our Services. We may provide such aggregated de-identified data to third parties, but in so doing, we do not provide personal information without the individual's consent.

We may also provide aggregated, de-identified information to third parties to develop and deliver targeted advertising on our Sites and on websites of third parties.

We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis.

For Providers, we may share your business contact information with third parties, including but not limited to, business name, address, telephone number, email address and name of owner or proprietor of the business.

We use third party providers to provide us with web analytics services. These providers collect information on how individuals use our Sites and our services. These providers may use cookies and other technology such as clear gifs or web beacons to obtain such information. This allows us to improve our Sites and our Services.

Your Content

Any of Your Content may appear on other websites or when searches are executed on the subject of your posting.

When you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others.

For example, if you post your email address, you may receive unsolicited messages.

We cannot control who reads Your Content or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

Once you have posted information, you may not be able to edit or delete such information.

Will we disclose personal information to anyone else?

We may disclose personal information to:

our affiliated companies, including Aftercare;

payment processors such as authorize.net;

authorised service providers that perform certain services on our behalf, including fulfilling orders, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our Sites' functionality and supporting contests, sweepstakes, surveys and other features offered through our Sites or performing background checks of Providers. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes;

business partners - when you make purchases, reservations or engage in promotions offered through our Sites or our Services, we may share personal information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant's offer or program, you authorise us to provide your email address and other information to that merchant;

Providers - We match your information and service request against our list of Providers on the Directory. When you submit a match request through our Sites, you consent to our providing your personal information and request to the Providers we match with your request. Sharing this information with Providers allows them to contact you using the e-mail address or other contact information you provided. In addition, we have other approved contractual partners that fulfil service requests, or that utilise their own providers to supplement our network, and we share your information with them, subject to contractual confidentiality restrictions, in order to attempt to provide the services requested.

collection agencies and credit reporting bodies - we may disclose personal information and credit information to collection agencies and or credit reporting bodies in respect of overdue Provider accounts;

nominated representatives authorised to act on our behalf in processing your application or providing our Services to you;

nominated third party partners used to provide services, including the services provided through the Sites such as allied health professionals;

professional service firms providing services to us, such as legal, accountancy or marketing services as well as data hosting and technology firms.

other Users - when you upload Your Content to your Profile or otherwise on the Sites, such information is available to third parties who register with the Sites or who carry out searches on the Directory. Other Users may search for, see or share Your Content in accordance with our Terms and this Privacy Policy.

Your Profile will also be indexed and displayed through internet search engines when a third party searches for your name or the name of your organisation.

We may also provide your information to others, if required or permitted to do so by law, in accordance with the APPs.

We will only disclose your personal information:

with your consent; or

for a purpose which you would reasonably expect; or

as required or permitted by law; or

in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of liquidation; or

in accordance with this Privacy Policy.

Sensitive information

We only disclose sensitive information, such as health information, to third parties for purposes which are directly related to the purpose for which you provided such information to us, such as to connect you or someone that you care for with a Provider, such as an allied health professional through the Services.

Do we disclose personal information overseas?

We use third parties overseas to assist us in providing our Services through the Sites.

These third parties are based in the United States of America. We may disclose your personal information, including your payment details, where relevant, to such third parties in order to provide our Services to you.

Where we disclose your personal information to third parties overseas, we usually require them to comply with the Australian Privacy Principles.

Third party websites

There are a number of places on our Sites where you may click on a link to access other websites that do not operate under this Privacy Policy.

These third party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites.

We recommend that you consult the privacy policies of all third party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting.

Unsubscribing from our marketing materials

Unsubscribing from email lists

At any stage, should you wish to stop receiving any of our emails that we send to you for marketing or promotional purposes, simply click on the “Unsubscribe” link within the email and follow the instructions to unsubscribe.

Unsubscribing though the Sites

You can sign up to receive our newsletters and other materials through the Sites. You can elect to receive such materials that you require through the Sites by ticking the relevant box. You can unsubscribe from receiving such materials through the Sites at any time by logging in and opting out of the receiving the relevant materials.

Unsubscribing from hard copy promotional materials

When we send you hard copy promotional materials, such materials will include instructions on how you may unsubscribe from receiving such materials.

Dealing with us anonymously or using a pseudonym

You may deal with us on an anonymous basis or by using a pseudonym when making general inquiries through our Sites, or when you make general inquiries by telephone and do not require a further response from us. However, we may need certain contact details from you to respond to inquiries.

Generally, we will require your personal information in order to transact with you.

Security

We use industry-standard methods and take such steps as are reasonable to protect your personal information from unauthorised access, modification or disclosure and from misuse, interference and loss.

Among other techniques, we usually:

store such information on a computer behind our "firewall" in a secure location;

restrict the number of employees or contractors internally who can access such data; and

keep hard copies of documents in lockable cabinets in a secure location.

Once personal information is no longer required by us for the purposes for which it was collected or held or otherwise in accordance with the APPs, we will take all steps as are reasonable in the circumstances to ensure that it is either destroyed or de-identified.

Children's privacy

Our Sites are general audience websites. We do not knowingly collect personal information from children under the age of 13.

Access, Correction and Removal of your Personal Information

You may seek to access or correct your personal information at any time by contacting the Privacy Officer by email to privacy@espyconnect.com.au or by mail to the 'Privacy Officer, The Put Institute t/- Espy Connect, Level 2 Building 125 Church St Lilyfield NSW 2040.

If we do not agree to provide you with access to your personal information or to amend or annotate the information we hold about you, you may seek a review of our decision.

If we do not agree to make the requested changes to your personal information, you may make a statement about the requested changes and we will attach it to your record.

Complaints

You can send written complaints about a breach of the APPs in relation to your personal information by email to privacy@espyconnect.com.au or by mail to 'Privacy Officer, The Put Institute t/- Espy Connect, Level 2 Building 125 Church St Lilyfield NSW 2040.

Complaints will be reviewed by our Privacy Officer and a response will usually be provided within 30 days of receipt of the complaint.

If you believe that your complaint has not been satisfactorily addressed by us, after following the procedure set out above, you can make a complaint to the Office of the Information Commissioner (OAIC). The OAIC's contact details are here.

For more information about making a complaint, contact us at privacy@espyconnect.com..

Amendments

We may amend this Privacy Policy at any time. Amendments to this Privacy Policy will be posted on our Sites and will be effective when posted. Please check our Privacy Policy regularly for updates and amendments.

*As amended 3 May 2016.