1. Collection of personal information
Under the Privacy Act, “Personal information” includes information or an opinion about an identifiable individual. It includes their name, address, telephone number, email, gender, date of birth, finances, education information, video and photographs. “Sensitive information” is a subset of personal information which includes information about a person’s racial or ethnic origin, health information, political opinions, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices and criminal record.
We collect personal information from individuals in circumstances such as the following:
- when a person contacts us, online or offline, to enquire about our products and services;
- when a person registers an account with us, including an online account and online elearning platform account;
- when a person signs up for the Rekon Community and/or downloads the App;
- when a Website user posts or uploads Content that includes personal information, including but not limited to via the Rekon Community;
- when a Website or App user sends us an enquiry via a Contact Us form, registers interest in our training or consulting services, or makes a comment or other post through an email or via a social media platform;
- when a Website or App user signs up to receive our eNewletter, downloads an article, or otherwise agrees to receive marketing information from us;
- where you are required to pay to purchase products or services from us through the Website or the App; and
- when a person participates in a Rekon training course, consulting session, survey and/or any other event organised by us (“Participant”).
The type of personal information we collect may include:
- name, email address, contact address and telephone number;
- industry, organisation name, job title, work address and telephone number;
- payment details and other financial data, such as credit card information;
- work and education information, including comments about why you want to take our courses;
- any personal information, including sensitive information, that you choose to post or send to us via our Website or App.
All personal information that we and our related bodies corporate collect is reasonably necessary for the provisions of our products and services to you and for the purposes of our marketing communications.
2. Other types of information we collect
Website: We collect information on visitors and use of the Website, including information about your computer or device, your IP address, the date and time of your visit and how long you remained on our Website, the referral URL (the website from which the visitor has come), the pages visited on the Website, and other information about your operating system and browser.
App: We collect information from the App and your use of it, including information to assist us to identify the device the App is used on, such as your device IP address, operating system and your email address, location-based data, searches and other information you may input into or access from the App.
Cookies: We may utilise “cookies” which enable us to monitor traffic patterns and to serve you more efficiently if you revisit the Website. Cookies are small text files that are stored on your device’s browser director or program data subfolders. A cookie does not identify you personally, but it does identify your device. You can set your browser to notify you when you receive a cookie, and this will provide you with an opportunity to either accept or reject it in each instance. Rejecting cookies may have the effect of limiting your access to our online products and services. For more information about cookies, including information on how to manage and delete them, you can visit www.allaboutcookies.org.
3. Use and disclosure of personal information
We use the personal information collected from you for the purpose of providing you with our products and services and for other purposes that you would reasonably expect us to use that information, including in the following ways:
- For use for the purposes of collection described in section (1) above;
- To enable us to send information to and interact with Participants;
- To maintain a database of Participants who have completed a Rekon training course (“Participant Database”);
- To display it when you have posted or uploaded it to the Website or App;
- To receive and respond to any enquiries, feedback and complaints received from you;
- To process and perform authorised financial transactions with you;
- To create and manage any accounts you have with us, including to verify your identity and assist if you have forgotten any username or password;
- To communicate with you and provide you with marketing information about our products or services, engagements and offerings, where you have requested or consented to receiving this from us or where this is otherwise permitted under applicable laws;
- To improve our products and services;
- To allow you to participate in any interactive features of our Website and/or App when you choose to do so;
- To conduct market and usage research;
- To run competitions, prize draws and promotions;
- To protect our legal interests and fulfil our regulatory obligations (if and to the extent necessary); and
- In other circumstances, with your prior
We particularly note the following about how we use and disclose personal information:
Participant name and accreditation details are disclosed on our Website: When you participate in a Rekon training course you consent to us placing personal information about you on our Participant Database, and to us using this database to make your name and your Rekon accreditation(s) publicly available via a search page on our Website. If you do not wish to have this information made available on our Website, please contact us using the details set out at the end of this policy.
Direct marketing: We may use the personal information you have provided to us to send you information about our products and services by post, telephone or electronically. You the option to opt-out of receiving marketing communications from us. If you do not wish to continue to receive electronic marketing communications from Rekon, you can opt-out by clicking on the “unsubscribe” link in any communications that we might send you. Alternatively, you can contact us at the email at the end of this policy.
Related bodies corporate: We may disclose personal information, and you consent to us doing so, to our related bodies corporate.
Third party service providers: We may disclose or make available personal information, and you consent to us doing so, to third parties who are engaged by us to perform functions or provide products and/or services on our behalf, including:
- third party hosting service providers, analytics platform providers and other software products and services providers including Google and Apple (i.e. for the purpose of facilitating the operation of features of the Website and/or App and to collect and track certain data and information regarding the activities and characteristics of our users);
- financial services providers processing credit cards and other payment data; and
- advertising service providers (i.e. for the purpose of targeted advertising via Google Ads and Nuture Stream services).
We will take reasonable steps to ensure that these third parties adhere to relevant privacy obligations in relation to protection of your personal information, including to only use your personal information in accordance with applicable laws.
Legal requirements: We may need to disclose personal information if required to conduct an investigation into you or your activities, e.g. there is reason to believe that you have committed a breach of our Website or App Terms & Conditions. We may also disclose such information as required or permitted by any law.
4. Overseas disclosure
We may make some personal information available to businesses located outside Australia to fulfil our business purposes, for example for the purposes of those businesses providing hosting services and/or providing goods or services that enable the App and Website to function and for us to provide various features and track certain data and information. By providing your personal information you consent to this transfer. These service providers are typically located in [insert country details]. They agree with us that they will not to use or disclose personal information for unrelated or extraneous purposes.
5. Security and storage of personal information
Security: We will use reasonable endeavours to keep your personal information secure, including implementing technical and organisational security measures to protect it against any unauthorised or unlawful use and against accidental loss, destruction, or damage. You will appreciate, however, that we cannot guarantee the security of your personal information, as there are always risks associated with transmitting information across the Internet.
Storage: If we no longer need your personal information, unless we are required by law or a court order to retain it, we will take reasonable steps to destroy or de-identify your personal information.
6. Your rights in relation to your personal information
We take reasonable steps to ensure that your personal information held by us is accurate, up-to-date, complete, relevant and not misleading. You are entitled to have access to any personal information relating to you which we hold, to correct it and to raise concerns or complaints about the same.
Access: You can send us a request for access to your personal information using the contact details set out at the end of this policy. After receiving your request, and sufficient information to verify your identity, we will provide you with access to any personal information we have about you which you are entitled to access under applicable laws.
Correction: You may write to us at any time requesting amendments to any personal information that you consider to be incorrect or irrelevant, or to request that we block, erase or otherwise remove your personal information. We will correct your personal information upon request if required under applicable laws.
Complaints: If you have any complaints about our use of your personal information, please contact us using the details set out at the end of this policy. Rekon will inquire into any complaint and respond to you in writing within 30 days. If you are not satisfied with our response, you can contact us to discuss your concerns or lodge a complaint with the Australian Information Commissioner (www.oaic.gov.au).
7. Consent, Changes and Third Party Links
Your warranty in relation to any third party personal information you provide: If at any time you provide or disclose personal information about someone other than yourself, you must ensure and you warrant that you have that person’s consent to provide such information for the purpose specified and that the information provided is accurate.
Children: The Website and App are not intended to target minors. If you inform us or we become aware that we have inadvertently collected personal information about a child under the age of eighteen (18), we will take steps to delete the information as soon as possible, except where we are required by applicable law to keep it.
Information Transfer: In the event that our business (or part of it) is ever sold, acquired, merged, liquidated, reorganised or otherwise transferred, we reserve the right to transfer to the extent permissible at law all information we hold about you as a result of your use of our Website, the App and our other products and services (including all personal information and other data we collect) to a third party acquiring the assets.
If you wish to make any kind of enquiry in relation to your personal information or privacy, including obtaining a copy of the personal information we hold about you or making a complaint, please contact us at:
Rekon Group Pty Ltd
Level 28, AMP Building
275 St Georges Terrace
PERTH WA 6000
Last Updated: November 2019