SuperFriend – Industry Funds’ Mental Health Initiative (ACN 123 196 663) (SuperFriend, us, we, our) maintain a policy of confidence concerning your (you, your) personal information (Privacy Policy).

This Privacy Policy details how we deal with your personal information and has been developed in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).

By providing your personal information to us directly or indirectly you accept the terms of this Privacy Policy.

What kinds of information do we collect?

The type of information that we collect from you will depend on how you engage with us.

We will collect the following: name, job title, organisation name, contact information (including email address and telephone number), gender, age, state, industry, partner fund name, IP address, preferences and interests, other information relevant to products and surveys and any other personal information that you submit to us, via our websites, including superfriend.com.au (Site), mysuperfriend.com.au (Learning Management System) and via other mediums such as through web forms, online surveys, or via our partner organisations and collaborators.

How do we collect your personal information?

We collect your personal information directly from you or through your employer. The main ways we collect personal information about you are when:

  • you request to receive the goods and services offered and provided by us, including online or facilitated learning and webinars (training);
  • you register to be on our mailing list, including through signing up to our regular newsletter;
  • you register to become a user on our Site;
  • you register to complete training through our Learning Management System, either directly or through your employer;
  • you provide feedback relating to our training through interviews, or completing evaluation questions through data collection vehicles such as our Learning Management System or third-party survey providers such as SurveyMonkey;
  • you complete an online form on our Site, including registering for webinars and downloading resources;
  • you engage with us on our social media channels, including Facebook, Twitter and LinkedIn.

We will only collect your personal information from third parties (for example, your employer or our partner organisations) if you give the third party your consent to provide the information to us or it would be reasonably expected.

We will only collect sensitive information with your consent.

If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.

If you are under 18 years of age

If you are under 18 years of age you must ask your parent or legal guardian to approve your provision of personal information before you submit your personal details to us.

Use of personal information

This Privacy Policy deals with personal information of registered users, clients, service providers and other third parties.

We will only use your personal information for the purposes for which it was given to us, or for purposes which are directly related to the provision of our services.

Your personal information may be used by us in a number of ways, including to:

  • help you to access and use the services that we offer and provide;
  • improve the services this Site offers you;
  • support internal record keeping;
  • improve SuperFriend’s products and services;
  • periodically send communications about upcoming events and activities and/or other information which SuperFriend considers that you may find useful and interesting;
  • conduct research or evaluate our training and other services (information will be de-identified for those purposes);
  • provide feedback to our partner organisations on the effectiveness of our programs; and
  • develop and conduct our programs.

Disclosure of personal information

In certain circumstances, it may be necessary for us to disclose your personal information to third parties in order to assist us in providing our services, or where disclosure is required by us to meet our legal and regulatory obligations. Third parties may include:

  • digital marketing and other service providers, including third party web development providers;
  • technology support service providers where applicable to the service provided to you;
  • data storage providers;
  • our customer relationship management system that securely stores personal information to manage newsletter subscriptions;
  • SuperFriend’s partner organisations and collaborators as listed on our Site, employer organisations who participate in our programs;
  • facilitators who deliver our training;
  • government and law enforcement agencies and regulators; and
  • entities established to help to identify illegal activities and prevent fraud where authorised by law.

If you are participating in our training, we may also disclose deidentified and aggregate level results generated from data collection conducted in connection with the training.

We may also disclose your personal information to anyone authorised by you, or to whom you have provided your consent (either expressly or impliedly) or where another permitted general situation applies (as defined in Section 16A of the Privacy Act).

We will not disclose information that personally identifies you to any third party other than as set out in this Privacy Policy.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve the SuperFriend website in order to tailor it to user’s needs. We only use this information for statistical analysis purposes, after which the data is removed from the system. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Site.

Linked sites

Although the Site may link directly to websites operated by third parties (Linked Sites), you acknowledge that Linked Sites are not operated by SuperFriend. We encourage you to always read the applicable privacy statement of any Linked Site on entering the Linked Site. We are not responsible for the content or practices of the Linked Sites nor their privacy policies regarding the collection, storage, use and dissemination of your personal information.

Storage and security

The security of your personal information is paramount to us and we use all reasonable endeavours to keep your information in a secure environment and to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. If you reasonably believe that there has been unauthorised use or disclosure of your personal information, please contact us using the details below.

We keep records of the personal information we gather from you. Where this information is used for evaluation purposes, it is deidentified.

The encrypted data from our Site is stored by our IT service provider at their secure data centres in Melbourne and Sydney. The Virtual Private Server and Online Backup are all stored at our IT service provider’s data centre in Melbourne.

Encrypted data from our Learning Management System is stored in a secure data centre in Sydney.

You warrant that you will not act in a manner that results in us collecting, using or storing information that is in breach of our obligations at law.

If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy, securely delete, or de-identify your personal information as appropriate.

Accuracy of your information

We take reasonable steps to ensure that the personal information held by us is accurate, complete and up to date. If you believe that any of your personal information is inaccurate, please contact us using the below details and we will take reasonable steps to correct it.

Variation and consent to variation

We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy.

Disclosure to overseas recipients

The providers of our customer relationship management and third-party online survey sites such as SurveyMonkey are located overseas and host encrypted data on servers in the United States. Personal information (for example, the name and predominately office contact details of the personnel at our partner organisations) may be disclosed to these service providers for the purposes of providing a platform service to us. The providers are required to use any data provided to them for the sole purposes of providing the services to us.

Any overseas disclosure does not affect our commitment to protecting your personal information and our providers have a number of measures in place to secure the data provided to it. You consent to such overseas disclosure and acknowledge that entities outside of Australia may not be subject to substantially similar laws to those contained in the Privacy Act and you may not have the same rights to those afforded to you under the Australian laws.

Access to your information and making a complaint

You may request access to the personal information we hold about you. If you do so we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions provided under the Privacy Act. You may request this information by writing to our Privacy Officer.

Where it is practical to do so, when contacting us, you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.

If you wish to make a complaint about a breach of the Privacy Act by us, you may do so by providing your complaint in writing to the contact details listed below. You may also make a complaint verbally. We will seek to respond to any complaint within a reasonable period of time. We may seek further information from you in order to provide a comprehensive and complete response.

You may also make a complaint to the Office of the Australian Information Commissioner (OAIC). You may contact the Australian Information Commissioner via telephone on 1300 363 992, by submitting a complaint or inquiry online at oaic.gov.au or by writing to the OAIC at GPO Box 5218 Sydney NSW 2001.

Contact us

If you have any questions, or if you wish to contact us for any of the reasons described above, including to correct or access the information we hold about you, make a complaint, or view a copy of our Data Governance Framework, please contact our Privacy Officer at:

Level 2

157 Spring Street

Melbourne VIC

3000

Phone: 03 9615 8600 or Email

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