Privacy Policy

We respect your Privacy

Claire Bibby Pty Ltd ATF Claire Bibby Trust (ACN 636 200 738) (“Claire Bibby”, “we”, “us”, “our”) respects, and is committed to safeguarding, your privacy.  We believe that information received by us that can be used to identify an individual user (“you”, “your”, “User”) should be taken very seriously. We are committed to the security and confidentiality of your personal information, and are transparent in how we manage it.  Unless given consent to do otherwise, we will only collect and use personal information as set out below.  We follow the spirit of the Australian Privacy Principles in the Privacy Act 1988 (Cth). However, until such time (if at all) as we are subject, in whole or in part, to the Act, we have chosen not to opt in to be treated as an organisation for the purposes of the Act.

This Privacy Policy sets out our commitment to protecting the privacy of your personal information that we collect through our Website and/or Services.  Our Website and/or Services includes any websites, applications or platforms operated by us or associated business names registered by us.

By providing us with personal information, you indicate that you have had sufficient opportunity to access this Privacy Policy and that you have read and accepted it. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis.  If you do not wish to provide personal information to us, then you do not have to do so, however it may affect your use of our Website and/or Services.

We may update this Privacy Policy from time to time.  We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of personal information. Your continued use of our Website and/or Services or any other content, products or services covered by this Policy constitutes your agreement to this Policy and any updates.

By using our Website and/or Services and providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information and usage.

If you link to or use other websites, services or software, please review the privacy policies posted at those websites. This policy does not apply to, and we are not responsible for, any third party websites which may be accessible through links from our Website and/or Services.\

Collection of Personal Information

“Personal information,” as used in this Policy, is personally identifiable information, such as your first and last name, mailing address, email address, billing information, IP addresses, demographics, passwords, telephone numbers and/or other online contact information. “Personal Information” can also include data that is usually non-personally identifiable (such as location data, data about personal attributes or online identifiers) but that, taken together with other collected data, identifies a natural person, either directly or indirectly.

We collect personal information, as well as non-personally identifiable information on our Website and/or Services.  We try only to collect personal information about you that we need for the operation of our Website and/or Services, and to market and promote our Website and/or Services. The kinds of personal information that we collect and hold about you may depend on the circumstances in which the information is collected. In the process of running our Website and/or Services, there is a range of personal information collected about our current and prospective subscribers and users, current and prospective clients, as well as contractors, employees and other service providers.  This information can include name, email address, mailing and street address, phone number, age, profession, occupation, job title and more.

“Sensitive Information” includes information about a person’s racial or ethnic origin, religious beliefs or affiliations, political opinions, philosophical beliefs, health or genetic information, sexual preference or information about whether an individual is a member of a professional or trade association or union. Sensitive information might be collected by us during the course of surveys administered by Claire Bibby or affiliated third parties, but only if volunteered by Users with their consent.

You can choose not to actively volunteer information to Claire Bibby. However if you do provide information to us when asked or prompted, including sensitive information you are also providing consent for Claire Bibby to collect, store and use that information as necessary for the purpose of collecting it.  Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy).

If your personal information is collected by us from a third party, we are under no obligation to inform you of the collection, but such information will be subject to this policy and will be accessible by you on request, subject to any limitations or exceptions in the law.

How we collect your personal information

We will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been collected by or provided to us in accordance with this Privacy Policy or has been provided to us lawfully by third parties, including our clients, customers and service providers.

We collect information you provide to us in optional, voluntary submissions, including but not limited to:

• registration forms, surveys, user profiles, your comments and public interactions, when you provide your name, email address or other information to us voluntarily;

• subscriptions, when you sign up to our newsletters, updates, alerts or news and media releases by providing your name and email address;

• feedback communications or customer service requests, where you may supply or we may ask for your name and contact details;

• software and mobile application downloads, where you may provide your name and contact details and other information for the purposes of signing up to the application and obtaining its services; and

• curriculum vitae submissions, where you provide your personal information to us.

We may monitor and record calls and other electronic communications that you make to us in certain circumstances. For example, calls to us may be monitored and recorded for training and customer service purposes.

We use social networking services such as Twitter, Facebook, Instagram and LinkedIn to communicate with the public about us. When you communicate with us using these services we may collect your personal information. The social networking service will also handle your personal information for its own purposes. These Sites have their own privacy policies.

We create and record information automatically when you visit our website. We use cookies (or files sent directly to your computer or device) and other similar technology to collect information such as your IP address, the site you visited immediately prior to our website, the frequency and duration of your visit to our website, how you interact with our website, (including the pages you visit, your preferences and settings that you choose), device information and other information such as your IP address, access dates and times, browser type and pages visited when you interacted with us.  We may track activity relating to your interaction with our email communications and with links contained within our email communications and our website.  Some cookies may be associated with personal information about you and some may not. This information is generally collected, used and stored to deliver relevant messaging and enhance your experience when visiting our website.

We may also obtain your personal information from legitimate third party sources including social media, our Website, list brokers, referral agents and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so.

We may use analytics tools and other third party technologies, to collect non-personally identifiable information in the form of various usage and user metrics when you use our Website and/or Services. These third party analytics companies may combine the information collected for us with other information they have independently collected across their network of websites, products and services. For example, we have implemented Google features to collect data about your traffic via Google advertising cookies and identifiers.

Personal information will not be collected by any person who is known by us to be under the age of eighteen (18) without the consent of a parent or legal guardian. Persons under age eighteen (18) may only use our Website and/or Services with the involvement and consent of a parent or legal guardian.

Security, Integrity and Storage

We take measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all personal information that we collect. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps.

We will destroy or de-identify your information if we no longer require the information to provide you with access to our Site/s or Services and if the information is not required to be saved under Australian law or other Commonwealth records.

We are committed to ensuring that the information you provide is secure. We use reasonable technical, administrative and physical measures to safeguard personal information. However, no personal information shared on the internet can be 100% guaranteed to be secure. Users are responsible for the access and security of their own computers.

How we use your personal information

We will only use your personal information where we are permitted to do so by applicable law.  We collect and use personal information for purposes including to contact and communicate with you, for internal record keeping, marketing, for our email newsletters and other activities associated with our business.

The main reason we collect personal information is to share news and stories that are relevant to you, to obtain opinions or comments about products and/or services, to conduct other research and development and to enhance your experience of our Website and Services, including to develop new products and services and to personalise and display advertisements and other content for you.

We also use this personal information for statistical purposes – for example to analyse how many users are using our platforms and where they are mostly coming from etc – and to enable us to share more relevant advertising and partner content on our platforms.

We also use this personal information to personalise and display advertisements and other content for you, and we may drop a cookie on your browser linked to data that is known about you so that third party advertisers can show you more relevant ads.  You are entitled to opt out of personalised marketing and advertising at any time.

In some instances, the non-personally identifiable information collected from our Site and/or Services may be linked with information collected by a third party source, such as Google, to become personally identifiable. We will not link or merge non-personally identifiable information collected by us with personally-identifiable information collected by a third party organisation, such as Google, without your informed, express consent. Google may merge or link your information with the non-personally identifiable information collected from our Site and/or Services if you have expressly provided your consent for them to do that.

By using our Website and Services, you consent to the collection of data by Claire Bibby’s ad servers or third party affiliates, or the transfer of information to them, wherever necessary, for our performance optimisation and in order to tailor the content and advertising that appears on our Website and Services.

Unless you have provided us with express, informed consent to collect your personal information for targeted marketing and advertising purposes, the information that is collected is not personally identifiable, and is pseudonymous or aggregated data that does not identify any individual user.

Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we may use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

Ability of others to view information

We may provide areas on our Site and Services where you can upload user-generated content, post or provide information about yourself, contribute comments, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Website and Services, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our Website and Services. We are not responsible for the conduct of others who may read, collect and use this information.

Our system automatically captures the IP address of those who post comments on our website. We reserve the right in circumstances such as attempts to mislead other users about a comment poster’s identity through statement or omission, to disclose that information.

When We Disclose Personal Information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, financiers, suppliers or subcontractors and other users as permitted by the functionality of our Website and Services insofar as reasonably necessary for the purposes set out in this policy.

Any personal information that you submit, display, or publish on a forum, blog, channel, bulletin board, chat room, user commenting feature or other interactive sharing or social feature offered through our Website and/or Services, is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us and other third parties without restriction, except to the extent limited access features are available.

In order to ensure that our various Website and Services work together optimally, as described above, we share information (including your information) between our multiple online networks.

We may provide Personal Information to our third party service providers for their use in performing internal business functions or collecting information on our behalf.  Whenever possible, we require such third-parties to only collect and use personal information in accordance with this Policy, and for no purpose other than providing us with our requested services.

We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.  We may also use your personal information to protect our copyright, trademarks, legal rights, property or safety of us, our customers or third parties.

Claire Bibby will not sell, license or otherwise disclose your personal information to third parties unless such disclosure is for the purposes set out in this Privacy Policy.  From time to time, users of our Website and Services may be invited to respond to specific offers from third-party organisations or to provide additional information when opting into information, services, and offers from – or in partnership with – third party organisations. In these cases only the personal information a user has agreed to provide for this purpose will be made available to third parties.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

Your Privacy Choices

Users have a general right to access, edit and manage the collection, processing and use of their personal information. You may request access to any personal information we hold about you by contacting us as per the details below. Whenever you are entitled to access such information, we will provide such information to you via email or post without charging you for such access.  You may, at any time, update, correct, or delete certain personal information that you have provided to us by contacting us as per the details below. You are entitled to request that your personal information is dealt with by us either anonymously or under a pseudonym. If we are not able to remove your personal information for any reason, we will notify you of this with an accompanying explanation.

Users may opt out of any activity that involves collecting or processing their information for direct marketing purposes at any time by clicking the “unsubscribe” link in communications you receive from us. By opting out of one particular electronic communication received from us, you will be removed from the subscriber list in connection with that particular communication category or “newsletter”. However, you will continue to receive communications in relation to other newsletters to which you subscribed, and have not opted out.

When Your information Leaves Australia

Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia. We will only transfer personal information to a foreign country for the purpose of providing you with our services and for carrying out any request you make when you use and interact with our Site and Services (e.g., if we outsource data storage to a cloud service provider).

In the event that we are required to disclose your personal information to overseas third parties, we will take reasonable steps to ensure that such disclosures are subject to reasonable confidentiality terms.

Privacy Data breaches

Australian laws provide that an eligible data breach arises when the following three criteria are satisfied:

1. there is unauthorised access to or unauthorised disclosure of personal information, or a loss of personal information, that we hold;

2. this is likely to result in serious harm to one or more individuals; and

3. we have not been able to prevent the likely risk of serious harm with remedial action.

We are required to take all reasonable steps to ensure an assessment of an eligible data breach is completed within 30 days. If an eligible data breach is confirmed, as soon as practicable we must provide a statement to each of the individuals whose data was breached or who are at risk, including details of the breach and recommendations of the steps individuals should take. A copy of the statement must also be provided to the Office of the Australian Information Commissioner.

Cookies

When you come to our website we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, so that we can improve our service.  We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our Site and Services.

You are able to disable cookies on your computer. You can also opt out of Google’s use of cookies by visiting their advertising opt out page at www.google.com/privacy_ads.html. However in opting out, you may not be able to use all services offered by us.

Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit. We are not responsible for, the privacy practices of third party websites which may be linked to or accessible through this website.

How to contact us about your privacy

If you want to send us notices or service of process, please contact us:

• online at: administrator@clairebibby.com; or

• by mail at: PO Box 275, Frenchs Forest, NSW, 1640.

Privacy Complaints

If you have a complaint, please email us at administrator@clairebibby.com.  We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

If you have any complaints about our privacy practices, please feel free to send details of your complaint to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001 Phone 1300 363 992 or oaic.gov.au.