Should there be any inconsistency between this policy, the Privacy Act and other Acts mentioned above, this policy shall be interpreted to give effect to and comply with the legislation.
This policy includes examples but is not intended to be restricted in its application to such examples. Where the word ‘including’ is used, it shall mean ‘including without limitation’.
Our websites contain links to non-Command Coaching websites. Command Coaching is not responsible for the privacy policies of those other websites. We recommend you review the privacy policies of each site you visit.
COLLECTION OF PERSONAL INFORMATION
Generally, we will collect personal information directly from you, and only to the extent necessary to provide the product or service you requested or to carry out our internal administrative operations.
We may collect personal information from you when you:
- fill in an enrolment form
- deal with us over the telephone
- purchase a product or service from us
- e-mail us
- create an account with us
- ask us to contact you after visiting our web site.
We will collect personal information from you by lawful and fair means and not in an unreasonably intrusive way.
If you choose to not provide your personal information when requested, we may not be able to deliver the product or service that you have requested. We will endeavour to make this as clear as possible for each service.
In some cases, where it makes sense and is lawful, you can interact with us anonymously or by using a pseudonym (an alias). We will endeavour to make this option clear when it is available to you.
As noted above, we will only collect personal information from you that’s necessary to provide the product or service or to carry out internal administrative functions. We collect different personal information depending on the product or service that you have requested.
“Unsolicited” personal information is personal information about an individual that an organisation has unintentionally received. This is an uncommon occurrence for Command Coaching, but when it does happen, we will protect your personal information with the same rigour as we treat personal information that we intended to collect. If we could not have collected this information through our normal processes, we will de-identify that information as soon as we can.
Direct Marketing from Command Coaching generally takes the form of Direct Mail or Electronic Marketing (email). In rare cases, we may use Telemarketing. Each of these channels is handled as follows:
- Direct mail – Where we use your personal information to send you marketing information via the post we may do so with your implied consent or, if this is impracticable, we will ensure that you are provided with an opportunity to opt out of receiving future such communications. By not ticking a clearly displayed “opt out” box, we will assume we have your implied consent to receive similar marketing communications in the future. We will always ensure that our opt out notices are clear, conspicuous and easy to take up.
- Electronic marketing – Where we use your personal information to send you marketing information by e-mail, SMS, MMS or other electronic means we may do so with your express or implied consent. You may give us your express consent by, for example, ticking a box on an electronic or paper form where we seek your permission to send you electronic or other marketing information. Consent may be implied from our existing business relationship or where you have a reasonable expectation of receiving an electronic marketing communication.
- Telemarketing – Command Coaching does not usually engage in telemarketing activities to our customers. Should any telemarketing be undertaken or authorised by Command Coaching, we will, to the extent that it applies, comply with the relevant legislation (see below).
Every directly addressed marketing contact sent or made by Command Coaching will include a means by which customers may unsubscribe (or opt out) of receiving further marketing information.
Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Requests should be directed to the Command Coaching Administration Team via the contact details provided under ‘How to contact us’.
ACCESSING YOUR PERSONAL INFORMATION
Command Coaching will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we ask that you identify, as clearly as possible, the type (or types) of information requested. Command Coaching will deal with your request in a reasonable time – usually within 30 days.
Depending on the breadth of your request, we may recover from you our reasonable costs incurred in supplying you with access to this information.
Your right to access your personal information is not absolute. In some circumstances, the law permits us to refuse your request to provide you with access to your personal information, such as circumstances where:
- access would pose a serious threat to the life or health of any individual
- access would have an unreasonable impact on the privacy of others
- the request is frivolous
- the information relates to a commercially-sensitive decision-making process
- access would be unlawful
- access may prejudice enforcement activities, a security function or commercial negotiations.
UPDATING YOUR INFORMATION
Where your information has been disclosed to a third party, Command Coaching will take reasonable steps to notify the third party of the correction.
Where we are unable to update your information, we will provide an explanation in writing as to why the information cannot be corrected.
We employ appropriate technical, administrative and physical procedures to protect personal information from unauthorised disclosure, loss, misuse or alteration.
We limit access to personal information to individuals with a business need consistent with the reason the information was provided. We keep personal information only for as long as it is required for business purposes or by the law.
Command Coaching protects your personal information by complying with Information Security Standards, Industry Schemes and Statutory obligations
WEBSITE SECURITY AND PRIVACY
Accordingly, we have systems in place to ensure our online dealings with you are as secure as your dealings with us in person, or on the telephone.
In those instances where we secure your personal information in transit to us and upon receipt, we use the industry standard encryption software, Secured Socket Layer (SSL) 128 bit encryption. The URL in your browser will change to “HTTPS” instead of “HTTP” when this security feature is invoked. Your browser may also display a lock symbol on its bottom task bar line to indicate this secure transmission is in place.
For site security purposes and to ensure this service remains available to all users, we employ software programs to monitor network traffic in order to identify unauthorised attempts to upload or change information, or otherwise cause us damage. Except for authorised law enforcement investigations, no other attempts are made to identify individual users or their usage habits other than those uses identified in this policy. Unauthorised modification or misuse of information stored in this system will be investigated and may result in criminal prosecution.
Information collected on this website
We may collect non-personal information from you such as browser type, operating system, and web pages visited to help us manage our web site.
Our internet server logs the following information which is provided by your browser for statistical purposes only:
- the type of browser and operating system you are using
- your Internet Service Provider and top level domain name (for example – .com, .gov, .au, .uk etc)
- the address of any referring web site (for example – the previous web site you visited)
- your computer’s IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet).
All of this information is used by Command Coaching for aggregated statistical analyses or systems administration purposes only. No attempt will be made to identify users or their browsing activities, except where required by law.
A “cookie” is a packet of information stored on your computer that allows the Command Coaching server to identify and interact more effectively with your computer.
Our websites use two different kinds of cookies:
- Session cookies – temporary cookies that only last until you close your browser.
- Persistent cookies – cookies that are stored for a longer term on your computer.
When you access our web site, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use our website. Cookies do not identify individual users, although they do identify a user’s internet browser type. When you close your browser the cookie is deleted and no longer exists on your computer.
You are free to disable cookies in your browser (see details below). If you have disabled cookies you may not be able to take full advantage of all of our website features.
We use session cookies in the following manner:
- Log-on and log-off administration – Session cookies help with the log-on and log-off processes for those users who have decided to register to use one of our online services. The cookies enable us to recognize your user ID when you log on so that we do not establish a duplicate registration record for you.
- Transactions and site usability – We use session cookies to improve how you navigate through our website and conduct transactions. As examples, session cookies are used to maintain your online session as you browse over several pages; to store and pre-populate information so that you do not have to re-enter the same information twice. Session cookies may also be used to collect referral statistics when you click on a link or ad banner to or from auspost.com.au.
Command Coaching may also use “persistent cookies”. A persistent cookie is a small piece of text stored on your computer’s hard drive for a defined period of time, after which the cookie is erased. Command Coaching will not collect or link to personal information through persistent cookies without your express consent.
We use persistent cookies as follows:
- Site usage measurement – Our site measurement tool uses a persistent cookie to assist us in measuring how and when our web site and its various components are used. It functions as a “visit cookie,” so we can determine if you are a repeat visitor to our site. This allows us to know if we are attracting new visitors and what aspects of the site seem most useful. The cookie will expire 30 days after your last visit.
- Longer-term cookies – Persistent cookies allow us, at your request, to recognise you when you return to auspost.com.au or to remember certain information that you have provided us. The recognition feature allows you to log on to certain Command Coaching sites automatically, without having to enter your name and password each visit. The cookie assigns a random number to you, and allows us to track your site activity, but this is not linked to personal information. This allows us to personalise the site for you and tailor the content to your needs, for instance to show you banner ads about other products you may be interested in.
Other cookies allow us to remember certain information related to prior transactions, such as package tracking numbers, or mailing or address lists, so we may pre-populate those fields for you on return visits.
Our display advertising partner, AdRoll, then enables us to present you with retargeting advertising on other sites based on your previous interaction with [company website]. The techniques our partners employ do not collect personal information such as your name, email address, postal address, or telephone number. You can visit this page to opt out of AdRoll’s and their partners’ targeted advertising.
- Microsoft Internet Explorer (External link)
- Mozilla FireFox (External link)
- Google Chrome (External link)
- Apple Safari (External link)
Links to other sites
The Command Coaching site contains links to other sites. We are ultimately not responsible for the privacy practices or the content of such web sites. We encourage you to read and understand the privacy policies on those websites prior to providing any information to them.
Some of the content appearing on the Command Coaching website may be supplied by third parties, for example, by framing third party web sites or the incorporation through “framesets” of content supplied by third party application service providers. In such cases Command Coaching will ensure that our contractual arrangements with these third parties protect your personal information in compliance with privacy laws.
Search terms that you enter when using our search engine are collected, but are not associated with any other information that we collect. We use these search terms for the purpose of aggregated statistical analyses so we can ascertain what people are looking for on our website, and to improve the services that we provide.
We may use external companies to provide us with detailed aggregate statistical analyses of our website traffic. At no time is any personal information made available to these companies, nor is the aggregate information ever merged with personal information such as your name, address, email address or other information you would consider sensitive or would compromise your privacy.
LOSS OF PERSONAL INFORMATION
- seek to rapidly identify and secure the breach to prevent any further breaches
- engage the appropriate authorities where criminal activity is suspected
- assess the nature and severity of the breach including the type of personal information involved and the risk of harm to affected individuals
- notify the affected individuals directly if appropriate and where possible
- if appropriate, put a notice on our website advising our customers of the breach
- notify the Privacy Commissioner (at the OAIC) if the breach is significant.
When we provide a product or service that intentionally collects personal information from children, we will give a notice specifying what information we are requesting, how we will use it, whether it will be shared with a third party, and a contact at Command Coaching for questions. We will utilise the information only for the particular purpose for which it was given to us.
We will use reasonable efforts to verify parental consent prior to the collection and use of personal information from children under 16. The method of verification may vary according to the information, product, service or event in which the child wishes to participate. Consent may take a variety of forms including offline consent such as printing and submitting a permission form by mail or fax, or online consent such as by ticking an online check box that parental or guardian consent has been obtained.
We do not require parental or guardian consent in order to collect and use online or offline contact information to:
- respond directly to a child’s request on a one-time basis, or to answer a specific request, where the information is not intended to be used to re-contact the child for other purposes
- request the name or on-line contact information of a parent/guardian for the sole purpose of obtaining verifiable parental consent or providing parental notification
- respond directly more than once to a specific request from a child and the information is not intended to be used to recontact the child beyond the scope of the request.
Command Coaching will allow parents or guardians to review any personal information collected from their children, subject to verifying the identity of the consenting parent/guardian.
Parents/guardians may revoke their consent and delete information collected from their children at their discretion.
HOW TO CONTACT US
To contact us with a compliment or complaint or a privacy question, you can:
- write to us at:
Privacy Contact Officer
PO Box 1812
Cleveland DC QLD 4163
- call our Customer Contact Centre on 07 3459 0045 between 10.00am and 2.00pm AEST Monday to Friday
FURTHER INFORMATION ON PRIVACY
- Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (External link)
- Australian Direct Marketing Association (ADMA) Code of Practice (External link) in relation to how we market to our customers
- Spam Act 2003 (External link) in relation to electronic marketing
- Do Not Call Register Act 2006 (External link) where we engage in telemarketing
- Telecommunications Industry Standard 2007 (External link) (PDF) where we engage in telemarketing.
You can obtain further general information about your privacy rights and privacy law from the Office of the Australian Information Commissioner by:
- calling their Privacy Hotline on 1300 363 992
- visiting their web site at http://www.oaic.gov.au/ (External link)
- writing to:
The Australian Information Commissioner
GPO Box 5218
Sydney NSW 1042