Your privacy

Protecting your privacy and keeping your personal information confidential is very important to us. We’re bound by the Privacy Act 1988, including the Australian Privacy Principles (APPs) set out in the Act, when we handle your personal information.

This Privacy Policy outlines how we maintain your privacy when handling your personal information if you’re a client or a visitor to one of our websites, in Australia.

In this Policy, we use the terms, “we”, “us”, “our” or “CL360” to refer to The Coherence Group Pty Ltd. “Your” and “you” refer to clients and other members of the public who have an interaction with CL360.

What is personal information?

Personal information means information or an opinion that identifies you, or could reasonably identify you as an individual, whether the information or opinion is true or not.

Personal information may come:

  • directly from you;
  • from other persons acting on your behalf;
  • from third parties;
  • from publicly available sources.

We use your personal information:

  • to provide you with the products and services you’ve asked for;
  • where we have legitimate interests to process the personal data and they’re not overridden by your rights, or
  • in accordance with a legal obligation, or
  • where we have your consent.

What personal information we may collect

We collect information directly from you or from other persons acting on your behalf when you use our websites and/or sign up to our services.

We only collect personal information from you that is necessary to do business with you and to perform the service you have contracted us to do.

The personal information that we collect about you includes your name, business name, postal address, email address, telephone number, profession/role, personal correspondence and various personal preferences. When you purchase a service from us, we also collect your payment information, such as your credit card or direct debit information and ABN.

We also collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible (e.g., by personalising the content you see).

We collect most personal information directly from you, when you:

  • order and/or register for our service;
  • use our service;
  • interact with our client support and sales teams;
  • use our website or social media sites;
  • register for marketing events, training and newsletters;
  • interact with members of our authorised sales partner/affiliate network;
  • complete our surveys or product testimonials; or
  • apply for a job with us.

We may also collect personal information about you:

  • from our third party sales partner/affiliate network;
  • that is publicly available from sources such as social media websites; and
  • from third parties that provide us with marketing leads.

If we don’t collect your personal data, we may be unable to provide you with all our services, and some functions and features on our websites may not be available to you.

Some of the activities we will do once we have your personal information include:

  • verify your identity (including completion of a credit check where required);
  • operate, protect, improve and develop our products and services;
  • provide technical support to you and your authorised contacts;
  • keep you informed about our products and services and those of our relevant business partners, and tailor this information to your needs and interests;
  • enable secure access to our websites and service;
  • participate in any third party acquisition or potential acquisition of an interest in us or our assets;
  • analyse, aggregate and report on your usage of the service which we may share publicly or with third parties.
  • respond to any feedback, queries or complaints; and
  • fulfil any legal and regulatory obligations; and
  • process a job application that you’ve submitted.

Our websites and the use of cookies

Your personal information gives you authorised access to our websites so that you can update your details, access online help or perform financial transactions. You may be able to authorise other people (such as your employees) to access, add and manage information on your behalf.

Our websites may contain links to third party websites, which don’t belong to us and are beyond our control. Please note we’re not responsible for and can’t guarantee the privacy of these third party websites.

We use Internet Protocol (IP) addresses to analyse trends, administer our websites, track your navigation among CL360 web pages and gather broad information for aggregate use. Our web servers may also send a small data file known as a “cookie” to your internet browser or hard drive. We use cookies to track your onsite behaviour to ensure our website pages work correctly.

We also use cookies to personalise and improve your experience with us. Most cookies don’t collect personal information and only contain coded information that can’t be used by third parties to access your confidential information. Most web browsers allow you to adjust settings to erase cookies, disallow cookies, or receive a warning before a cookie is set. Please note that some parts of our websites may not function fully if you disallow cookies.

In some cases we or third parties may use cookies and other technologies such as web beacons and JavaScript on our websites in connection with online services like banner advertising, website analytics and surveys. These technologies enable information to be collected about your use of our websites (including your computer’s IP address), which may be stored in the United States, Singapore, New Zealand or other countries. The information collected by these technologies give us and third party collectors the ability to deliver customised advertising content, measure advertising effectiveness, evaluate the use of our websites and other websites and provide other services relating to website activity and internet usage. We and third parties may also transfer collected information to others if required by law, or where those other parties process the information on our behalf. The services we may use from time to time include Google Analytics, Google AdSense, DoubleClick, Yahoo, Adobe, Bing, Kenshoo, Microsoft, Segment and Keen.

How we can share your data

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:

  • other companies in the CL360 group of companies and affiliates;
  • third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you;
  • regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;
  • an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business;
  • other people where we have your consent.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

Holding your personal information and keeping it safe

We typically hold the personal information that we collect either on electronic databases or as hard copy documents.

The security of your personal information is fundamental to the way that we do business. We take all reasonable steps to protect the personal information that you give us from unauthorised access, use or disclosure, in line with industry standards.

Whilst we take all reasonable measures to protect your personal information when it’s in our hands, it’s important to note that we’re unable to guarantee the security of the internet as a whole. If you’re using your product and services online, please ensure that you’re doing so in a secure environment. In addition, if you use email to send and receive your personal information, please be aware that the information may be less secure in transit.

International data management

When we share data, it may be transferred to, and processed in, countries other than the country you live in – such as to the United States, where our data hosting provider’s servers are located. These countries may have laws different to what you’re used to. Rest assured, where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.

How long do we keep your information for

The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested).

We’ll retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymised.

Your rights

It’s your personal data and you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication, or send your request to programs@thecoherencegroup.com.

You also have rights to:

  • know what personal data we hold about you, and to make sure it’s correct and up to date
  • request a copy of your personal data, or ask us to restrict processing your personal data or delete it
  • object to our continued processing of your personal data

You can exercise these rights at any time by sending an email to programs@thecoherencegroup.com.

If you’re not happy with how we are processing your personal data, please let us know by sending an email to programs@thecoherencegroup.com. We will review and investigate your complaint, and try to get back to you within a reasonable time frame. You can also complain to your local data protection authority. They will be able to advise you how to submit a complaint.

If you’re someone who doesn’t have a relationship with us, but believe that a CL360 client has entered your personal data into our websites or services, you’ll need to contact that CL360 client for any questions you have about your personal data (including where you want to access, correct, amend, or request that the user delete, your personal data).

Questions, concerns and complaints

If you have a complaint about how we’ve handled your personal information, you can make a complaint by contacting us using the details at the bottom of this Policy.

Once we have received your complaint, we will investigate and respond to you as quickly as possible. We’ll try to resolve your complaint as quickly as possible, and in any event within 30 days of hearing from you. If your complaint takes longer to resolve, we’ll keep you informed of our progress with the investigation.

If you need further information about our privacy complaints process or the progress or outcome of any investigation, please contact the Privacy Officer using the details at the bottom of this Policy.

If you aren’t satisfied with our handling or resolution of your complaint, you can lodge a complaint with the Office of the Australian Information Commissioner (“OAIC”). For more information please visit the OAIC website.

Changes to this Privacy Policy

We may make changes to this Policy from time to time. Please check our website regularly for any updates to this Policy. You can also get a copy of the most current version of this Policy by either emailing or writing to the Privacy Officer using the contact details set out below.

By continuing to use our website and otherwise deal with us, you accept this Policy as it currently applies.

Contact us

Email: programs@thecoherencegroup.com

Post:
Privacy Officer
The Coherence Group Pty Ltd
696 Bourke Street
Melbourne
VIC 3000
Australia