1. About this Policy
We are a not-for-profit virtual business incubator for people living with a disability.
We are committed to protecting your privacy and understand the importance of protecting your personal information. This Policy outlines the types of personal information that we usually collect, the purposes for which we collect it, to whom we disclose it, how we hold and keep it secure, and your rights in relation to your personal information, including how to complain and how we deal with complaints.
We will handle your personal information in accordance with this Policy and all applicable legislation including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles.
In this Policy, personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified (anonymous data).
By using our websites, applications and services, or otherwise providing us with your personal information, you consent to us collecting, holding, using and disclosing your personal information as described in this Policy.
If you do not consent to provide, or we cannot otherwise collect, all the personal information we request, we may not be able to provide you with our services or with access to our websites or applications.
2. General policy
Types of personal information we collect
The types of personal information we collect about you depends on the dealings you have with us, and may include:
· your name, contact details (including email addresses, phone numbers and mailing addresses), date of birth, gender, occupation, employment history, education, qualifications and proof of identification
· in some cases 'sensitive information' including information about your membership of any professional association, whether you are of Aboriginal or Torres Strait Islander origin, and your health information including disability information
· information collected about your disability may include:
ü your type of disability and associated symptoms
ü your NDIS plan type
ü your NDIS number
ü the name and email of your NDIS plan manager
Dealing with us anonymously or using a pseudonym
Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question, we will not record your name unless we need it to adequately handle your question.
However, for many of our functions and activities we usually need your name, contact information and other details to enable us to assist you.
Ways we collect your personal information
We may collect personal information about you in different ways, including:
· when you provide it by telephone or email
· through your interactions with us on our website and social media channels
· when you publish content in publicly accessible areas of our website such as forums, bulletin or discussion boards, comment sections, or similar
· through third party charities who we collaborate with
· through other publicly available sources
We may also be required or authorised by law to collect some of your personal information, such as under a court or tribunal order.
Collection of personal information via websites
When you visit our website we may use 'cookies' or other similar tracking technologies that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and browsing sessions. You can disable cookies through your internet browser, but our website may not work as intended for you if you do so.
Whilst we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit, search engine referrals and the internet protocol address assigned to your computer.
Our webpages may contain electronic images, known as web beacons. These electronic images enable us to count users who have visited certain pages on our website. Web beacons are not used by us to access your personal information, they are simply a tool we use to analyse which web pages are viewed, in an aggregate number.
Using and disclosing personal information
We collect your personal information for the following purposes:
· to provide you with our services including access to certain Enabled VIP web content and applications.
· to facilitate your registration and attendance at Enabled VIP's events such as educational seminars and webinars
· to verify your identity
· to bill for your Enabled VIP membership
· to communicate with you in relation to providing or promoting our products or services
· to help us manage, develop, and enhance our services including our websites and applications
· to administer, maintain, support, and provide upgrades to, our services and applications.
We may disclose your personal information to other parties, including:
· for the purpose for which it was collected or for a related purpose which you may reasonably expect
· for use by third party researchers who are partnered with us, only in an aggregated and de-identified form
· the National Disability Agency in connection with payments processing
· where you provide your consent for us to disclose your personal information
· where we are required or authorised to do so under law
· to third party service providers such as cloud hosting and data storage providers to assist us in managing our data
We may also disclose your personal information to overseas recipients including:
· to third parties who assist us in providing services or who perform functions on our behalf (including cloud hosting and data storage providers), including those located in the USA and the United Kingdom
· where you authorise us to disclose it or we are required or authorised to do so by law.
We may use your personal information to identify a product or service you may be interested in or to contact you about our events and other activities. We may, with your consent, use your personal information to contact you from time to time by phone, post, email or SMS to tell you about new products or services, promotions, events and special offers that we believe may of interest to you.
You can withdraw your consent to receive direct marketing communications from us at any time by unsubscribing from the mailing list or by writing to us at [email protected].
We store your personal information in hard copy and electronically. We will take reasonable and appropriate steps (including organisational and technological measures) to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by applicable laws. If we no longer need to hold your personal information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.
Access and correction
We will endeavour to ensure that the personal information collected from you is up to date, accurate and complete.
You may request access to, or correction of, the personal information we hold about you at any time by contacting us at [email protected]. We will need to verify your identity.
Subject to any applicable exceptions or requirements, we will process your request within a reasonable time and usually within 28 days. If we decide to refuse your request, we will tell you in writing why and how you can complain. If a fee is charged for providing access, you will be advised of the likely cost in advance.
You can make a complaint in writing to us at [email protected]. We will need to verify your identity. We will respond to you within a reasonable period of time and usually within 28 days to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at www.oaic.gov.au.
3. Contact us
If you have a question or comment regarding this Policy or wish to make a complaint or exercise your privacy rights, please contact us at [email protected].
4. Review details
This policy was adopted by Enabled.VIP as V1.1 | 1 November 2021
Last updated: 1 November 2021
Next review date: 1 November 2022