In handling your personal information, Salty Girls Surf School will comply with the Australian Privacy Act 1988, including the 13 Australian Privacy Principles), and all other relevant laws, regulations and codes relating to privacy and personal information (‘Privacy Law’).
What kind of personal information do we collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual.
The kinds of personal information Salty Girls Surf School collects and holds vary according to the specific product or service being provided and may include, but is not limited to, your:
- contact and identification information, such as your name, address, email address, telephone number, gender and date of birth;
- government identifiers and related information, such as your driver’s licence, passport and visa particulars obtained, for example, to verify your identity or eligibility at the time you request a product or service;
- other details relating to your relationship with us, including if we deal with you in a capacity other than a customer (for example, information about agreements or other arrangements or transactions you may have with us, billing information including your credit card details, your purchasing preferences and history, and any information contained in correspondence between us); and
- any other information lawfully obtainable under relevant Privacy Law.
In some circumstances, Salty Girls Surf School may collect sensitive information about you, for example in relation to insurance claims. Sensitive information is a type of personal information and includes health information and information about racial or ethnic origin, political opinions, membership of a trade union or political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences and criminal record. We will only collect sensitive information about you where we are permitted to do so by law.
How do we collect your personal information?
Where practicable we aim to collect your personal information directly from you. The circumstances in which we may do so will vary depending on the context in which we are dealing with you (for example, if you are a customer, according to the specific product or service we are providing) but can include, for example, when you are:
- registering for one of our websites or services or logging in to use one of our websites;
- bookings or requests for information through our online services, by email, verbally and/or in hard copy;
- subscribing to receive alerts/e-brochures and filling in surveys or research, or participating in promotions and competitions we offer;
- contacting us for any reason including, but not limited to, reporting a problem with one of our services or websites, requesting further services, updating your personal information or otherwise seeking our assistance;
- posting or contributing material on our websites or social media; and
- using our products and services and any service provided by us in connection with those.
There may be occasions when we collect your personal information from other sources, such as:
- public or commercial information services provider (such as providers of government, business or credit information);
- social media platforms, if you choose to interact with us via your social media account;
- a third party assisting us to process a booking or other transaction, confirming information or other request or assisting us to locate or communicate with you;
- travel service providers, transfer companies, hotels and other businesses involved in dealings with you and us; and
- your next of kin, should an emergency occur.
Generally, Salty Girls Surf School will only collect your personal information from sources other than you if:
- it is unreasonable or impracticable to collect personal information from you; and
- the collection of that personal information complies with all relevant Privacy Laws.
How we use your personal information
We collect, hold, use and disclose your personal information where it is reasonably necessary for the purposes of providing our products and services, for our other business purposes and for any necessary related purposes. These purposes include, but are not limited to:
- registering you to use one of our websites;
- processing a product, service or purchase request;
- managing our products and services or other relationships and arrangements;
- processing receipts, invoices and payments and servicing customer accounts, including determining liability for payment;
- responding to customer enquiries about applications, accounts, products or services;
- understanding customer needs and offering products and services to meet those needs;
- assessing, processing and investigating insurance risks or claims;
- accounting, billing and other internal administrative purposes;
- identifying and informing customers of products and services that may be of interest;
- notifying you about changes to our products and services;
- considering, and contacting you about, any application you make for a job with us;
- any other legal and regulatory requirements. Various laws may expressly require us to collect your personal information, or we may need to do so in order to be able to comply with other obligations under those laws:
- enforcing our rights, including undertaking debt collection activities and legal proceedings; and
undertaking business funding and development activities.
Where personal information is used and disclosed, we take steps reasonable in the circumstances to ensure the personal information is relevant to the purposes for which it is to be used and disclosed. You are under no obligation to provide your personal information to us. However, without certain information from you, we may not be able to provide our services to you or any other relevant customer.
Disclosures of your personal information
We may disclose your personal information for purposes such as those listed above and we will always do so consistently with our privacy obligations.
Third parties to whom we may disclose your personal information include:
- administrative services providers, such as mailing houses, printers and call centre operators;
- legal, settlement, valuation and recruitment service providers;
- data processing and market research service providers;
- regulatory bodies and law enforcement authorities in Australia and overseas;
- any person who is considering whether to acquire or who has acquired any part of our business, or the rights or obligations under our contract with you;
- financial and other advisors; other participants in financial and payment systems, such as banks, credit providers, clearing entities and credit card associations;
- account information aggregation service providers, to assist in the transfer of your account data to us in connection with a booking, service or purchase;
- insurers, travel service, transport and accommodation providers;
- affiliated partners, sponsors, promotional partners and other distributors; and
- debt collectors and investigators.
We may disclose your personal information to overseas recipients in order to provide our services and products and for administrative, data storage or other business management purposes. It is not practicable to list all of the countries to which your information may be transmitted from time to time, but we transfer information between Australia and New Zealand, and it is likely that other such countries will include the United States of America, the United Kingdom, the Philippines, Japan, Singapore and Hong Kong.
Before disclosing any personal information to an overseas recipient, we take steps reasonable in the circumstances to ensure the overseas recipient complies with relevant Privacy Laws or is bound by a substantially similar privacy scheme to that which is in place in Australia unless you specifically consent to the overseas disclosure taking place without such steps being taken, or the disclosure is otherwise required or permitted by law.
We may use and disclose your personal information (including by sharing it between Salty Girls Surf School partners and/or affiliates) in order to inform you of products and services that may be of interest to you.
In the event that you do not wish to receive such communications, you can opt-out by following the instructions for doing so in the communications we or they send to you.
Security of your personal information
We may hold your personal information (including your credit-related personal information) in physical form or in electronic form on our systems or the systems of our service providers.
We take steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. We hold personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff, and follow procedural safeguards that meet or exceed relevant Privacy Laws.
We require third parties handling personal information on our behalf to follow equally compliant standards of security and confidentiality.
We will destroy or de-identify personal information in circumstances where it is no longer required unless we are otherwise required or authorised by law to retain the information.
Access and correction to the personal information that we hold about you
We take steps reasonable in the circumstances to ensure that the personal information we hold is accurate, up-to-date, complete, relevant and not misleading.
You have a right to access and seek correction of your personal information that is collected and held by us. This is subject to some exceptions specified in the Privacy Act 1988 (Cth) (Australia). If at any time you would like to access or amend the personal information we hold about you, or you would like more information on our approach to privacy, please contact our Privacy Officer in accordance with the contact details set out below.
We will grant access to personal information to the extent required by applicable Privacy Law and will take reasonable steps to amend personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- we request that you be reasonably specific about the information you require; and
- we may charge you a reasonable administration fee which reflects the cost to us for providing access in accordance with your request. We will not charge you for making the request.
If we refuse your request to access or correct your personal information, we will provide you with written reasons for the refusal and details of the ways in which you can make a complaint. We will also take steps reasonable in the circumstances to provide you with access to your personal information in a manner that meets your and our needs.
If you are dissatisfied with a refusal of a request to access or correct your credit information, you may make a complaint to the Australian Information Commissioner.
In the event that we correct your personal information previously disclosed to another entity and you request that other entity to be notified of the correction, we will take reasonable steps in the circumstances to do so unless impracticable or unlawful.
Complaints and disputes
If you wish to complain about the way in which we collect or handle your personal information, including your credit-related personal information, or if you believe we have breached any Privacy Law, you can contact our Privacy Officer using the details below.
Following a complaint, our Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or impact on the commercial arrangements between you and us.
In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Australian Information Commissioner.
How to contact us
Please direct all privacy queries and complaints to our Privacy Officer via email at firstname.lastname@example.org