The Wellbeing Project

Privacy Policy

Introduction

This privacy policy sets out how KGT Enterprises Pty Ltd as Trustee For KGT Enterprises Trust (Trading As The Wellbeing Project Co) handles your personal information.

The Wellbeing Project Co provides information, training and online training courses and reference materials on a range of behavioural challenges and evidence-based management strategies, for children, adolescents and adults with autism and ADHD.

Personal information is any information about you where your identity is apparent, or can reasonably be ascertained, from the information. Sensitive information is a sub-set of this and includes medical and health information.

Our privacy policy is based on openness. Where we request information from you, we will generally state the purpose(s) for its use and to whom it may be disclosed.

Our website may contain links to third party websites. We are not responsible for the privacy policies of any third-party websites. We recommend that you review the privacy policy of each website you visit.

Collection of Personal Information

The amount of personal information we collect about you depends on how you interact with us. We will collect personal information from you if you:

• make a product or service enquiry;
• order a product or service;
• make a product complaint or enquiry;
• contact us through our website using an online form or by telephone;
• complete an application or enter into an agreement;
• receive a visit from one of our representatives;
• subscribe to one of our mailing lists;
• correspond with us, including via email;
• participate in one of our on-line surveys;
• contact us via any of our social media forums.

The type of personal information you may typically provide us includes your name, position description, address, email address, level of knowledge, telephone, age group, mobile phone number, facsimile number, credit card particulars and bank details.

By providing your personal information to The Wellbeing Project Co in this way, including the completion of online forms and email, you agree to the collection of that information in accordance with this privacy policy.

We collect personal information from you for a number of reasons, including to:

• sell and deliver our products and services to you;
• respond to your questions or requests for information;
• manage enquiries or complaints;
• improve our services and training content;
• assist us to forecast future demand for our products and services;
• send you direct marketing material electronically or by post;
• analyse our website usage;
• enhance the content of our website and our social media platforms;
• keep a record of our dealings with each other; and
• comply with legal obligations.

If you do not provide us with your personal information, we may not be able to provide you with these services.

You can generally visit our website without telling us who you are or revealing other personal information. However, remaining anonymous or using a pseudonym is not an option if it is impractical for us to communicate with you that way or if we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.

Sensitive Information

Through participation in a course, or if relevant to the supply of goods or services, we may also collect health and medical information about you or a child or person in your care (where it is impractical to collect this information directly from them). This information will only be used in order to provide you with the goods or services you have requested.

You may also decide to share sensitive information in our training sessions, at your own election and discretion. We will not make a record of what is shared in sessions unless this is strictly relevant for the provision of our services. Other attendees will be asked to respect the confidentiality of any sensitive information shared in sessions. However, as we cannot control or be responsible for the conduct of other individuals, we recommend that you exercise common sense and care in this regard.

If you share photographs of yourself and/or your child with us, we reserve the right to post these on our website and other social media forums with a respectful commentary. If you include other persons in these photographs you should ensure they have consented to this use.

Otherwise, we will only collect sensitive information from you (e.g. relating to race, ethnic origin, membership of political bodies, religion or trade unions, sexual preferences, criminal record) if:

• you have given express consent to us to do so and the information is reasonably necessary for us to carry out our functions or activities;
• the use of this information is required or authorised under Australian law or a court or tribunal order; or
• the information is necessary for the establishment, exercise or defence of a legal claim.

Social Media

To customise your user experience on our website we may provide you with the opportunity to connect, access and/or interact with third-party social networking services, such as Facebook, Twitter, SnapChat and Instagram. If you connect to these third-party social networking services you are authorising The Wellbeing Project Co to access and use certain information from your social network profile. You adjust your privacy settings to control who has access to your information when you are not using the application and you can cancel this service at any time by deleting the application from your social network account.

Disclosure to Third Parties

The Wellbeing Project Co recognises the trust you place in us when you give us your personal information and so will not give your personal information to third parties unless:

• you have given us your consent to do so (in particular with regard to any disclosure of sensitive information including medical or health information);
• it is necessary for us to do so to fulfil the primary purpose(s) for which we collected your personal information;
• you would reasonably expect us to disclose it for a related purpose; or
• we are required to do so by law.

The third parties we will typically share your personal information with are presenters, guest speakers and facilitators at our training sessions who provide information and related services outside of The Wellbeing Project Co.

At your initial session we will circulate a list of the names and contact details of other participants attending your session. This is to encourage you to maintain contact and develop support groups. If you do not want to be included in this list please let us know in the first session.

Other organisations which may receive your personal information may be involved in or conduct ancillary services supporting our business, including:

• mailing, shipping or courier operations;
• information technology services, including website development and hosting;
• legal, auditing, accountancy or other professional services;
• our insurance services;
• website usage analysis

We take reasonable steps to ensure that these third parties respect privacy obligations in relation to the protection of your personal and sensitive information.

If you are a medical or health practitioner and have indicated willingness for us to refer members to you for medical advice, we will include your contact details in a list and provide your details to a member in response to their request.

Direct Marketing

We may use personal information about you for the primary purpose of providing you with our services. We may also use it for other purposes for which you might reasonably expect us to use that information. This includes sending you information about new developments, products, services and special offers by post, telephone or any form of electronic communication (providing you with the option to ‘opt-out’ at any time). You authorise us to use any email address or other contact information you provide to us at any time for this purpose.

Cross Border Disclosure

If we disclose personal information in countries outside Australia, we will only do so in compliance with applicable data protection and privacy laws and if we reasonably believe that the information will remain subject to principles for fair handling of the information which are substantially similar to the applicable Australian privacy laws.

Website data and cookies

When you visit our website the server may attach a "cookie" to your computer's memory. A “cookie” assists us to store information on how visitors to the site use it and the pages that may be of most interest. This information may be used to provide users of your computer with information that we think may interest them. If you choose, you could be able to configure your computer so that it disables “cookies” or does not accept them.

Security

The security of your personal information is of great importance to us, and we will use all reasonable endeavours to:

• keep your personal information secure in a combination of secure computer storage, hard copy files and other access-controlled records; and
• ensure your personal information is protected from misuse, interference, loss and from unauthorised access, modification or disclosure.

We will endeavour to destroy or de-identify your personal information when it is no longer needed for the purpose for which it was provided, unless a legal exception applies.

Access and Correction

We will take all reasonable steps to ensure that your personal information which we collect, use or disclose is relevant, accurate, complete and up-to-date. We appreciate you assisting us by letting us know if your personal information has changed.

You have a right of access to most personal information we hold about you and the right to correct or update your personal information. This right is subject to certain exceptions allowed by law. To request access, please contact our privacy officer, whose contact details are set out below. We will need to verify your identity before meeting your request, which we may require in writing, and we will process it in a reasonable time.

Queries and Complaints

If you have any queries relating to our privacy policy, would like more detail as to our privacy practices or believe that a breach of this privacy policy may have occurred, you may contact our privacy policy by email, post or telephone as follows:

The Privacy Officer
 KGT Enterprises Pty Ltd, PO Box 2152, Hampton East, Victoria 3188
 P: 0422 056 888
E: [email protected]

If we become aware of any ongoing concerns or problems, we will take these issues seriously and work to address these concerns with you. If, however, you are not satisfied with our response, you may contact the Office of the Privacy Commissioner on 1300 363 992.

Updates

From time to time, The Wellbeing Project Co’s policies will be reviewed and may be revised. We reserve the right to change this privacy policy at any time and notify you by posting an updated version on our website at www.thewellbeingproject.com.au You will be deemed to have consented to such variations by your continued use of the site or our services following such changes being made.