As at December 2023
1. Commitment to privacy:
- Anna Cohen & Co [ABN 33 094 270 149, ACN 094 270 149 (The Company) (“us”, “we” or “our”) is committed to safeguarding the privacy of our clients, staff, facilitators and participants both the clinical and non-clinical online parenting services in addition to those who visit the website or engage with the Company or the service on our social media platforms.
- The Company is bound by the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles, and other laws governing how health service providers handle your Personal Information and Sensitive Information (including information about your health).
- This Privacy Policy (Policy) sets out how we collect and treat your Personal Information and Sensitive Information. The Policy applies to our website annacohenandco.com.au, social media platforms on [Facebook, YouTube, and Instagram] operated by the Business, and to the products and services provided by us in-person and online, including the online non-clinical parenting programs.
2. Definitions
In this Policy:
- “Personal Information” is categorised as information held by The Company, that may identify you, or by which your identity might be reasonably determined. The information you provide us may include, amongst other things, your name, address, email address and phone number. It does not include “Sensitive Information”.
- “Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliation, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information.
3. Collection of Your Data
- To provide our services to you, The Company may receive and store Personal Information and Sensitive Information (together, ‘your Data’) that you enter onto our website, provide to us directly or give to us in any other form or by any other means.
Your Data may include your:
- Contact details including name, phone number, address and email address;
- Payment and billing information, which we may use to bill you for our services and to process your payments (including credit card details);
- Other information voluntarily provided by you.
- Your Data is collected to ensure your safety and wellbeing, to send information, provide updates and process purchases of services and products provided by the Company.
- Sensitive Information, which includes the definition of your Data relating to your health, will not be collected unless you consent to the collection of that information.
- The Company collects your Data from you in a variety of ways, including when you interact with us electronically or in person, when you access our [website] and social media, and when we provide our services to you.
- We may collect additional personal Data at other times, including but not limited to, when you provide feedback, when you provide information about your personal affairs, change your contact or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with us in any other way.
- We may receive your Data from third parties. Those third parties may include your medical practitioners, hospitals, clinics, lawyers and/or family members. If we do, we will protect and use this information as set out in this Policy.
4. Use of Your Data
- Personal Information collected by us will only be used and disclosed for the purpose for which it was collected as set out below. This includes maintaining your account and contact details, providing you with our products and services, and processing payments.
- The Company may use Personal Information collected from you to provide you with information and updates on our services, additional products, or opportunities available to you.
- We may use your Personal Information to improve our products and services and better understand your needs.
- We may from time to time use your Personal Information for another purpose where it would be reasonably expected by you or if permitted by the Privacy Act. This includes to effect or enforce a transaction, or procure advice from legal and accounting firms, auditors and other consultants.
5. Disclosure of Your Data
- The Company may disclose your Personal Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
- Personal Information is only supplied to a third party when it is required for the delivery of our services.
- We may from time to time need to disclose Your Data 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 use Your Data to protect the copyright, trademarks, legal rights, property or safety of The Company, the Program, its clients or third parties.
- We will not disclose, sell, share or trade your Personal Information to any third parties unless we first receive your consent, except as set out in this Policy.
- We may provide health information (Sensitive Information) to other medical service providers, such as your general practitioner or specialist medication practitioners. We will only supply this information with your consent, or in circumstances where it is required for the delivery of health services, such as referral to a health service provider and billing, where it is necessary to prevent or lessen a serious threat to a individual’s life, health or safety, or other reason as permitted by law.
- Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.
- 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, Sensitive 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.
- By providing us with your Data, you consent to the terms of this privacy policy and the types of disclosure covered by this policy. Where we disclose your Personal Information to third parties, we will request that the third party follow this policy regarding handling your personal information.
6. Security of Your Data
- The Company is committed to ensuring that your Data is secure.
- The Company will take reasonable steps to protect your Data from misuse, loss, unauthorised access and modification or disclosure.
- We use commercially reasonable physical, technical and administrative measures to protect Data that we hold, including, where appropriate, password protection, encryption and SSL to protect our website.
- Despite taking appropriate measures to protect your Data used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. The transmission and exchange of information is carried out at your own risk.
- We cannot guarantee the security of your Data that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of your Data, we cannot assure you that your Data we collect will not be disclosed in a manner that is inconsistent with this privacy policy.
- You are solely responsible for maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services.
7. Access to your Information
- You may request details of your Data that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth).
- A small administrative fee may be payable for the provision of your Data. If you would like a copy of your Data which we hold about you or believe that any of your Data we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected]
- We reserve the right to refuse to provide you with your Data that we hold about you, in certain circumstances set out in the Privacy Act.
8. Website
- When you visit the website of The Company 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, such that we can improve our service.
9. Marketing Emails
- We may send you direct marketing emails and information about products and services that we consider may be of interest to you. [If your business is communicating with clients by email, then it is bound by other laws including the Spam Act 2004 (Cth). These communications should be sent pursuant to restrictions and we recommend seeking independent legal advice with respect to this clause].
- If, at any time, you would like to stop receiving these promotional emails, you may follow the opt-out instructions contained in any such email. Please note that it may take up to 7 business days for us to process opt-out requests. If you opt-out of receiving emails or promotions from us, we still may send you emails about your account, any services you have requested or received from us, or for other customer service purposes. We do not provide your personal information to other organisations for the purposes of direct marketing.
- If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided below.
10. Complaints about privacy
- If you have any complaints about our privacy practices, please feel free to send in details of your complaints to: [email protected]
- We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
12. Changes to privacy policy
- Our Privacy Policy is subject to change.
- The Company may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website, or through distribution by email. Please check back from time to time to review our privacy policy.
