Privacy Policy

This document describes how The Put Institute Ltd trading as Professional Practice Academy (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.profpracc.com (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.

When you provide information to other parties through the Sites, on the member directory on our Sites (Directory), such as when you register for an online course or purchase a Service Provider's materials, you should also review the relevant privacy policy of such parties.

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, credit card details, date of birth, employment history, educational qualifications, government related identifiers such as tax file numbers and all other personal information provided by our registered members (PPA Members) when they post or otherwise provide their personal information through the Sites and the Directory and other information that is relevant to our functions and activities.

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

We also collect your contact details/payment details so that you can make payments to us, where relevant such as when you pay a membership fee or when you pay a booking fee to register for a Service Provider's courses or materials. Such information is not publicly available on the Sites.

• Profiles and Your Content 

When you create a profile on the Sites (including on the Directory) (Profile), to provide information about you or to promote you or your organisation's goods or services, we collect the personal information that you may choose to provide, upload or post to your Profile or to any other PPA Member's profile, such as, your educational background, employment history, information relating to your skills and any comments, photos, videos or materials that you upload to any 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 PPA Members users of the Sites via the Directory or otherwise on or through the Services as "Your Content".

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

• Online Meetings and Webinars 

When you participate in a web-conference through the Sites for the purpose of attending a meeting with another PPA Member of the Sites (Online Meetings), such Online Meetings are protected by the use of end to end encryption. 

The Online Meetings are only accessible by the authorised users of the Online Meetings, organisers and other participants. 

We do not view Online Meetings or any personal information submitted during Online Meetings except as necessary for us to support the service to provide the Online Meeting or as otherwise required by law. 

Any personal information that you submit during an Online Meeting can be read or collected by the organiser of the Online Meeting or by other participants. 

When you participate in an online webinar or course hosted by a third party, such as a learning provider, registered training organisation or other service provider (Service Provider) through the Sites (Webinar), such Webinars may be retained on the Sites by the organiser, shared by third parties or made available by us through the Sites for third parties. If you contribute to the Webinar, such as by way of text chat (which may contain personal information) for instance, then such contributions may be made available to third parties or shared as part of the Webinar. 

As with Online Meetings, we generally do not view Webinars or any personal information submitted during Webinars except as necessary for us to support the service to provide the Webinar, make the Webinar available on the Sites or as otherwise required by law. 

• How do we collect personal information?

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

In some instances, we may collect personal information about individuals from third parties such as the Service Providers or from an individual's employer or contractor.

We may also collect your personal information from your authorised agent who registered for a Service Provider's course or materials available through the Sites on your behalf.

We may collect personal information about Service 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:

(a)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

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

(c)apply for any course or materials provided by a Service Provider through the Services or where you participate in any course or Webinar through the Services; or 

(d)use our Sites or the Directory; or

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

(f)seek information on Service Providers or other PPA Members through the Sites; or 

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

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

(i)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, such as, you may not be able to register for a course that is available through the Sites. 

If you do not provide your name and contact details to become a PPA Member, you will not be able to search for Service Providers on the Directory or communicate with other PPA Members through the Services.

• 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.

• 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.

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 the Directory 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 Service 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. They 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:

(b)payment processors such as PayPal or Stripe;

(c)authorised service providers that perform certain services on our behalf, in processing your application or providing our Services to you, including fulfilling orders, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our Sites' and the Directory's functionality and supporting contests, sweepstakes, surveys and other features offered through our Sites or performing background checks of Service Providers. These authorised 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;

(d)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; 

(e)Service Providers - we match your information and service request against our list of Service 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 Service Providers we match with your request. Sharing this information with Service 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; 

(f)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 accounts;

(g)nominated third party partners used to provide services, including the services provided through the Sites such as the Service Providers providing courses or materials to you through the Sites - we recommend that you review the privacy policies of such organisations before you register for any courses or purchase such materials; 

(h)professional service firms providing services to us, such as legal, accountancy or marketing services as well as data hosting and technology firms; or 

(i)other PPA Members - when you upload Your Content to your Profile or otherwise through the Services or provide a review of any Service Provider, such information is available to third parties who are PPA Members. Other PPA Members 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:

(a)with your consent; or 

(j)for a purpose which you would reasonably expect; or 

(k)as required or permitted by law; or 

(l)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 

(m)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 with a Service Provider through the Services. 

Third party websites

There are a number of places on our Sites or the Directory 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.

Do we disclose personal information overseas? 

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

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.

Unsubscribing from our marketing materials

(a)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.

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. 

(n)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:

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

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

(p)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@profpracc.com or by mail to the 'Privacy Officer, The Put Institute Ltd t/- Professional Practice Academy, Level 2, Building 125, Church St, (Cnr Glover St), Old Rozelle Hospital, 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@profpracc.com or by mail to 'Privacy Officer, The Put Institute Ltd t/- Professional Practice Academy, Level 2, Building, 125 Church St, (Cnr Glover St), Old Rozelle Hospital, 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@profpracc.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 27 May 2016.