Privacy Policy
Last updated: 10 March 2024
This document serves as the Privacy Policy for Star Swim Schools Clyde Pty Ltd (ABN: 22 307 299 662), herein referred to as Star Swim Schools Clyde or alternatively as we, us, or our.
Our paramount concern is safeguarding your privacy and personal data. We urge you to carefully review this Privacy Policy as it delineates:
Our methods of gathering and managing personal information.
Your entitlements concerning any personal information we possess about you. We reserve the right to revise this Privacy Policy periodically. The most recent iteration can be accessed on our official website (https://www.starswimschools.com.au/).
OVERVIEW
1.1 About Star Swim Schools Clyde
Star Swim Schools Clyde, herein referred to as Star Swim Schools Clyde or alternatively as "we," "us," or "our," is fervently dedicated to the instruction of children in the art of swimming. We firmly believe in the inherent potential of every child and our capacity to positively influence their growth and development both as swimmers and as individuals.
Operating swim schools (Centres) situated across various locations in Victoria, Australia, we offer a spectrum of programs and services, including but not limited to swimming lessons and other aquatic activities.
1.2 Purpose of Collecting and Handling Personal Information
Our collection, storage, utilization, and disclosure of personal information are exclusively conducted when reasonably necessary for the provision of our programs and services, the operation of our organization, and the execution of our other functions.
Activities necessitating the collection and handling of personal information typically include:
. Planning, administering, and delivering our programs and services.
. Identity verification as required by law or deemed reasonably necessary. . Tailoring programs and services to individual needs and preferences. . Recruitment functions, including consideration for roles within Star Swim Schools Clyde and subsequent position administration.
. Fulfilling duty of care obligations.
. Ensuring the health, safety, and security of staff and customers.
. Managing and securing physical premises, computer systems, websites, and apps. . Communication of services, programs, and activities, including newsletters and other forms of correspondence.
. Marketing and advertising endeavors.
. Community and stakeholder consultation for understanding and addressing community challenges.
. Organizational development and improvement initiatives.
. Compliance with legal and regulatory obligations.
. Investigation of allegations and handling of issues and complaints.
Personal information may also be collected and handled with:
. Consent from the individual.
. Situations where collection is reasonably expected and related to the original purpose. . Legal requirements or authorizations.
At the time of collection, reasonable steps are taken to inform individuals of the purpose, usage, and potential disclosure of their personal information.
1.3 Anonymity
While efforts are made to accommodate requests for anonymous or pseudonymous interactions, practical or legal constraints may necessitate the collection of personal information. Failure to provide requested information may impact the availability of services, programs, and products.
1.4 Information Inquiry
Individuals can request confirmation of personal information held by Star Swim Schools Clyde, including its nature, purposes of usage, and handling procedures. Requests for access or correction of personal information are also accommodated, subject to applicable privacy laws.
1.5 Photography and Videography
Permission may be sought to capture promotional photographs and videos at Star Swim Schools Clyde Centres for various purposes, including publicity and advertising. Guidelines are provided for personal camera/video usage, including consent requirements, prohibited areas, and usage restrictions. Compliance with staff directives and conditions is mandatory.
2.1 General Overview
The spectrum of personal information collected is contingent upon the nature of our engagement with you. In the routine conduct of our affairs, we commonly gather personal information pertaining to:
. Customers availing our services, participating in programs, or procuring goods. . Volunteers, employees, and other personnel associated with us.
. Partners and their respective personnel.
. Service providers and their staff.
Common Types of Information Collected
The typical categories of information we procure encompass:
. Name and contact particulars (e.g., address, email, and phone number).
. Date of birth and next of kin details, if pertinent to the service or activity. . Photographic, video, and image content.
. Payment particulars (e.g., credit card, bank, and direct debit information) for transactions conducted with us.
. Details essential for rendering the requested service, program, or product, inclusive of eligibility confirmation and special requirements.
. Records pertaining to services, programs, and goods dispensed (e.g., registration specifics, attendance records, purchase documentation).
. Membership or account specifics if created for our services, programs, or facilities. . Additional information volunteered by you (e.g., during telephonic or written correspondence, program or service applications, website or social media interactions, or survey responses).
. Emergency contact details if you're a parent or legal guardian of a minor utilizing our services.
. Information relevant to your role within Star Swim Schools Clyde if you're a volunteer, employee, or staff member (e.g., qualifications, tenure, resume, employment history, remuneration details, feedback, training logs, equipment usage).
. Details pertinent to your role within Partner organizations or service providers, as relevant to our collaborative endeavors.
. Identification verification upon request.
. Recorded telephone conversations for quality assurance and training objectives. . Details logged during visits to our premises or facilities, including contact information provided, date and time of visitation, and any captured images or voices via Closed-Circuit Television (CCTV) or similar surveillance systems, for safety, security, and regulatory compliance.
Additional Information
Certain services, programs, or initiatives may necessitate the collection of distinct data types. In such instances, reasonable efforts are made to inform individuals about the nature and handling of such information through written or verbal privacy collection statements.
As customary within the not-for-profit sector, we maintain contact lists and databases for marketing and advertising endeavors. Refer to Section 7 of this policy for detailed insights.
Visitors to our website may have certain information collected regarding their visit and website usage. Please refer to Section 8 for comprehensive details on this matter.
2.2 Sensitive Information (Including Health Information)
Sensitive information encompasses specific categories of personal data, such as health information, racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of political, professional, or trade associations, as well as biometric and genetic information.
The collection of sensitive information about you is conducted solely with your explicit consent or in accordance with applicable privacy laws. Primarily, the sensitive information we may gather includes:
. Details of injuries (i.e., health information) sustained at our facilities or in connection with our services or programs, aimed at incident recording, injury management, and handling associated claim procedures (e.g., insurance claims).
. Information regarding disabilities or allergies (i.e., health information) disclosed to us to accommodate any special requirements during your engagement with our premises, services, or programs.
. Personal details shared by you (e.g., ethnicity, religious beliefs, or sexual orientation) to ensure culturally sensitive and appropriate delivery of our services and programs. . Membership affiliations with professional associations or relevant industry bodies pertinent to circumstances such as employment, consulting, or volunteering considerations. . Criminal record particulars as part of background assessments for roles within Star Swim Schools Clyde.
Should you provide sensitive information to us for any purpose, such action signifies your consent to its collection, usage, and disclosure for the intended purpose and as permitted by applicable laws, including privacy legislation.
2.3 Government Identifiers
In certain situations, the need may arise for your government identifiers, such as Tax File Numbers or Medicare numbers.
We typically request government identifiers when essential for identity verification, mandated by law, or deemed relevant and necessary for the specific service, program, or role you've sought.
2.4 Information Required or Authorized by Law
Collection, utilization, and disclosure of personal information may occur when mandated or permitted by law.
Certain services and programs we provide are subject to regulatory frameworks necessitating the collection, utilization, and disclosure of specific personal data. Failure to furnish requisite information may preclude access to such services and programs.
For instance, our swim programs for children and young people adhere to child safety legislation mandating the collection of specified information and reporting obligations to child safety authorities.
3.1 General Collection Methods
The primary method of acquiring personal information is through direct provision by individuals. We endeavor to obtain personal information directly from you whenever reasonable and feasible.
Common scenarios wherein we may gather personal information from you include:
. Participation in our programs, services, or purchasing transactions.
. Application for roles within our organization.
. Subscription to our mailing lists.
. Engagement with our marketing or advertising endeavors.
. Provision of feedback or participation in surveys, community engagement, or stakeholder consultation activities.
. Supply of goods or services to Star Swim Schools Clyde.
. Submission of inquiries, requests, applications, or complaints.
. Communication through our websites, telephone, email, social media platforms, or other channels.
. Visitation to our premises, facilities, or utilization of our computer networks.
For organizational efficiency, records of our correspondence and interactions with you may be maintained.
In certain instances, it may be necessary to procure personal information from publicly available sources or third parties, subject to legal permissions. Examples include:
. Acquisition of contact details from publicly available sources for community engagement endeavors.
. Collection of information from parents or legal guardians if you are a minor. . Receipt of information from agencies nominating or referring applicants for referral-only programs.
. Gathering of information from referees, government bodies, academic, and professional institutions during the recruitment process for validation of qualifications and background checks.
3.2 Technology Services Utilization
Similar to numerous organizations, we employ a range of technology services to facilitate program delivery, operational functions, and activities. These services are often provided and managed by third-party service providers.
In some instances, these technology services are utilized to gather information from or about you. Examples include:
. Utilization of social media platforms like Facebook and Twitter for community engagement purposes.
. Engagement of third-party services for conducting surveys.
. Requirement or optional utilization of third-party apps or websites for specific programs or services.
. Usage of cookies, web analytics, and similar technologies during website visits (refer to Section 8 for further details).
Information collected through these third-party technology services is utilized for the purposes outlined in this Privacy Policy. Each service may have its own privacy policy governing the handling and processing of collected personal information.
For communications via social media platforms, it's crucial to note that certain pages may be publicly accessible. We encourage the utilization of privacy settings available on each platform for discretion. Private communication with us can be initiated using the contact details provided in Section 11.
4.1 General Disclosure Principles
Depending on the nature and purpose of the collected information, there may arise instances where disclosure of your information to other individuals or entities becomes necessary.
In principle, we disclose information about you to others only:
. When aligned with the primary purpose for which the information was initially collected, or for a related purpose that you would reasonably anticipate.
. With your explicit consent.
. When legally mandated or authorized.
Whenever a third party, such as a contractor, is engaged to manage your personal information on our behalf, stringent measures are enforced to ensure the safeguarding and secure handling of your information.
We abstain from selling your information to other entities and undertake measures to ensure that our marketing and advertising endeavors adhere to relevant laws, including privacy, direct marketing, and anti-spam legislation.
4.2 Examples of Information Sharing
The entities and individuals with whom we commonly share information encompass:
. Our staff (including employees, contractors, and volunteers) requiring access to information pertinent to their roles.
. Service providers, including:
. IT service providers offering web hosting, cloud services, IT support, and cybersecurity services.
. Entities assisting us in marketing and advertising activities (e.g., call centers, mailing houses, online targeted advertising networks, social media platforms, and data analytics providers).
. Accountants, insurers, lawyers, auditors, and other professional advisors. . Payment processors and other entities aiding in transaction processing. . Our Partners, who may:
. Offer funding for our programs and services.
. Provide equipment and facilities.
. Assist in program and service delivery (e.g., health service providers, other charities, and community service organizations).
. Government agencies, regulatory bodies, and law enforcement agencies, when mandated by law or deemed reasonably necessary in the circumstances.
. Authorized persons responsible for you (e.g., your parent or legal guardian if you are a minor).
. Universities and research organizations.
Certain programs and services may be executed by Star Swim Schools Clyde on behalf of our Partners, including federal, state/territorial, and local governments. In such scenarios, we may be obligated to:
. Report to the funding organization regarding the utilization of provided funds. . Transfer program or service records (including attendance or participation records) to the funding organization upon program or service completion or at their request.
. Safeguard personal information against misuse, interference, loss, unauthorized access, modification, or disclosure.
. Ensure the accuracy, completeness, and currency of information pertaining to you.
We deploy an array of security protocols to protect the personal information within our purview, including the implementation of IT security tools to fortify our electronic databases.
Our electronic records housing personal data are securely stored within Australian-based data centers, maintaining compliance with stringent security standards.
Access to personal information is restricted solely to authorized staff, volunteers, and subcontractors for approved purposes.
Upon cessation of necessity, we diligently undertake reasonable steps to either destroy or de-identify records containing your personal information. The retention period for such records is contingent upon the nature of the information and the purpose of its collection.
International Disclosures
Certain third parties to whom we may disclose personal information could be situated outside Australia. The specific countries wherein such third-party recipients are based may vary depending on circumstances.
In the ordinary course of business, personal information may be disclosed to overseas recipients in countries such as the United States, the United Kingdom, and the European Union. Typically, these overseas recipients comprise IT service providers catering to Star Swim Schools Clyde. It's important to note that the engagement of overseas service providers for storing personal information does not necessarily equate to disclosure of personal information to said providers.
Whenever the transfer of personal information outside Australia is necessitated, we adhere to the requirements outlined in applicable privacy and data protection laws. Disclosure to overseas recipients may occur without your explicit consent if permitted by applicable Australian privacy laws, with strict adherence to pertinent legal requirements.
Should you opt to engage with us via social media platforms such as Facebook or Twitter, it's pertinent to acknowledge that these platforms may utilize facilities located outside Australia for the collection and storage of your information.
7.1 Overview
Marketing and advertising endeavors play a pivotal role in the ongoing advancement and expansion of Star Swim Schools Clyde and its programs.
Periodically, we may reach out to you to furnish copies of our marketing and advertising materials through various channels including phone, post, email, SMS, internet advertising, or other means.
You may find yourself added to our mailing list and/or marketing databases under the following circumstances:
. If you expressly convey your desire to be added.
. If such addition aligns with legal permissions to dispatch marketing materials and advertising.
7.2 Email Analytics
Similar to numerous organizations, we utilize email analytics to assess and quantify the efficacy of our email newsletters, marketing emails, and other email campaigns.
Various technologies, including tracking pixels, facilitate the acquisition of information such as email opens, clicked links, email client usage, device types, and geolocation data. These insights are instrumental in analyzing and enhancing the performance of our email campaigns.
7.3 Internet Advertising
To optimize the targeting of our advertisements to individuals with heightened interest, we may leverage online targeted advertising services. These services aid in showcasing our ads on websites, apps, and social media platforms frequented by our target audience.
Examples of such services encompass:
. Retargeting: To display our ads on other sites to individuals who have previously visited our website.
. Behavioral Advertising: To tailor ads based on user behavior across various online platforms.
. Audience-based Advertising: To target individuals on other sites who are members of our databases or share similarities with our customer base.
While some services utilize non-identifiable statistical data acquired through cookies and tracking technologies, others may necessitate limited disclosure of personal information to effectively target and disseminate ads.
Any utilization of advertising services involving the use or disclosure of personal information strictly adheres to applicable privacy laws.
For detailed information about the tracking technologies employed on our websites, refer to section 8.2 below.
7.4 Opt-out Requests
Should you prefer to cease receiving direct marketing communications or opt out of targeted advertising initiatives utilizing your personal information, you may submit your request to our Marketing Manager via email at: clyde@StarSwimSchools.com.au. Alternatively, you can reach out to us using the contact details provided in section 11 of this Privacy Policy.
Certain categories of communications, mandated or permitted by law, may not be subject to opt-out requests.
Additionally, you have the option to opt out of specific online targeted advertising networks by visiting the Digital Advertising Alliance's opt-out portal at: http://optout.aboutads.info/.
8.1 Overview
Star Swim Schools Clyde meticulously collects diverse information, including personal information, via our websites and e-commerce systems. We uphold the security of our
websites through the implementation of industry-standard SSL encryption, ensuring the confidentiality of your data.
Upon visiting our website, we collect:
. Information voluntarily provided by you through website interactions. . Other information automatically collected through cookies, web analytics, and analogous technologies.
8.2 Usage of Cookies, Web Analytics, and Similar Technologies
Our websites leverage cookies and tracking technologies to gather non-identifiable information, facilitating website management and enhancing user experience. Unless you voluntarily furnish details by completing a web form or logging in, your anonymity remains intact.
Information collected includes:
. Visitation timestamp.
. Viewed pages.
. Device specifications.
. Geo-location and IP address.
. Referring website address.
Cookies serve to deliver secure, personalized services and are instrumental in enhancing website functionality. By accessing the website, you consent to Star Swim Schools Clyde's utilization of such technology. While most internet browsers default to accepting cookies, you retain the option to configure preferences to reject cookies. However, rejecting cookies may curtail website functionality and personalized experience.
Our websites deploy session cookies for analytical purposes, generating visitor behavior insights to enhance website performance. This data is reported in aggregate form for analytical purposes. Google Analytics, for instance, facilitates this function and offers an opt-out browser add-on.
Furthermore, our websites utilize tags like the Facebook advertising pixel to measure traffic and visitor behavior. These tags, devoid of personally identifiable information, aid in remarketing and audience targeting efforts.
8.3 Links
Our websites feature links to external websites and third-party providers. We disclaim any responsibility for the privacy practices of these third-party websites and their associated content. It is incumbent upon third-party websites to elucidate their privacy policies and procedures to users.
We encourage users to peruse the pertinent privacy policies or terms and conditions governing linked third-party sites to ensure alignment with their privacy preferences.
. Access to personal information held by us.
. Correction of errors in personal information held by us.
Additional access and correction rights may be conferred under state or territorial privacy and freedom of information laws.
Requests for access or correction are handled in compliance with applicable laws. In instances where refusal is mandated or permitted by law, a written explanation is furnished.
9.2 How to Submit an Access or Correction Request
To make an access or correction request, kindly utilize the contact details provided in section 11 of this Privacy Policy below.
Verification of your identity may be necessary before processing your request. If you're requesting access or correction on behalf of another individual (e.g., your child or someone under your care), we may require confirmation of your authorization.
No charges apply for requesting access to or correction of your information. However, if costs are incurred (e.g., retrieval and copying), we may request a reasonable fee to cover those expenses.
We retain the discretion to decline correction of your personal information if we disagree with its necessity. In such cases, we will furnish a written notice detailing the reasons for refusal. No charges are applicable for actions taken in response to a correction request.
All requests for access to or correction of personal information will be addressed within a reasonable timeframe.
9.3 Parents and Legal Guardians
If you are a parent or legal guardian of a child (under 18) who has utilized our programs or services, you may request access to their information. However, there are circumstances where we may refuse to provide the requested information, such as when it:
. Violates the law.
. Poses a serious threat to the life, health, or safety of the child or another individual. . Unreasonably affects another person's privacy.
If we determine that your child is capable of making their privacy decisions, obtaining their approval may be required by privacy laws before granting you access.
10.1 How to Submit a Complaint
Should you wish to lodge a complaint regarding our handling of your personal information, kindly submit your complaint in writing using the contact details provided in section 11 of this Privacy Policy below.
10.2 How We Handle Complaints
We take all privacy complaints seriously. Upon receipt of your complaint, we will respond within a reasonable period, adhering to any legal timeframes. Cooperation from your end by providing relevant information aids in our investigation.
Our typical procedure involves appointing a designated officer to review the complaint, engage with relevant parties, and determine appropriate steps for Star Swim Schools Clyde in response. Following assessment, we will contact you (usually by phone) to convey our decision. If unsatisfied, further discussion or referral to our privacy regulator is available.
10.3 What if I am Unsatisfied with Star Swim Schools Clyde's Response? Our primary privacy regulator is the Office of the Australian Information Commissioner (OAIC). If discontent with our response, you may escalate your complaint to the OAIC.
Complaints under the Privacy Act 1988 (Cth) must be submitted to the OAIC in writing via email or the OAIC's online form. Alternatively, you may contact the OAIC by phone, although written confirmation may be required.
In some instances, additional rights to complain may exist under State and Territory privacy laws. The OAIC may redirect complaints to the appropriate regulator, or you may directly submit your complaint to the regulator of choice.
CONTACTING US
For privacy queries, complaints, or requests for access or correction of personal information, you can reach us through the following channels:
Email: clyde@StarSwimSchools.com.au
Phone: Star Swim Schools Clyde Customer Contact Centre: 0493433076 Postal Address:
Star Swim Schools Clyde Customer Contact and Support Team
2/38 Palladium Circuit, Clyde North, VIC 3978
This document serves as the Privacy Policy for Star Swim Schools Clyde Pty Ltd (ABN: 22 307 299 662), herein referred to as Star Swim Schools Clyde or alternatively as we, us, or our.
Our paramount concern is safeguarding your privacy and personal data. We urge you to carefully review this Privacy Policy as it delineates:
Our methods of gathering and managing personal information.
Your entitlements concerning any personal information we possess about you. We reserve the right to revise this Privacy Policy periodically. The most recent iteration can be accessed on our official website (https://www.starswimschools.com.au/).
OVERVIEW
1.1 About Star Swim Schools Clyde
Star Swim Schools Clyde, herein referred to as Star Swim Schools Clyde or alternatively as "we," "us," or "our," is fervently dedicated to the instruction of children in the art of swimming. We firmly believe in the inherent potential of every child and our capacity to positively influence their growth and development both as swimmers and as individuals.
Operating swim schools (Centres) situated across various locations in Victoria, Australia, we offer a spectrum of programs and services, including but not limited to swimming lessons and other aquatic activities.
1.2 Purpose of Collecting and Handling Personal Information
Our collection, storage, utilization, and disclosure of personal information are exclusively conducted when reasonably necessary for the provision of our programs and services, the operation of our organization, and the execution of our other functions.
Activities necessitating the collection and handling of personal information typically include:
. Planning, administering, and delivering our programs and services.
. Identity verification as required by law or deemed reasonably necessary. . Tailoring programs and services to individual needs and preferences. . Recruitment functions, including consideration for roles within Star Swim Schools Clyde and subsequent position administration.
. Fulfilling duty of care obligations.
. Ensuring the health, safety, and security of staff and customers.
. Managing and securing physical premises, computer systems, websites, and apps. . Communication of services, programs, and activities, including newsletters and other forms of correspondence.
. Marketing and advertising endeavors.
. Community and stakeholder consultation for understanding and addressing community challenges.
. Organizational development and improvement initiatives.
. Compliance with legal and regulatory obligations.
. Investigation of allegations and handling of issues and complaints.
Personal information may also be collected and handled with:
. Consent from the individual.
. Situations where collection is reasonably expected and related to the original purpose. . Legal requirements or authorizations.
At the time of collection, reasonable steps are taken to inform individuals of the purpose, usage, and potential disclosure of their personal information.
1.3 Anonymity
While efforts are made to accommodate requests for anonymous or pseudonymous interactions, practical or legal constraints may necessitate the collection of personal information. Failure to provide requested information may impact the availability of services, programs, and products.
1.4 Information Inquiry
Individuals can request confirmation of personal information held by Star Swim Schools Clyde, including its nature, purposes of usage, and handling procedures. Requests for access or correction of personal information are also accommodated, subject to applicable privacy laws.
1.5 Photography and Videography
Permission may be sought to capture promotional photographs and videos at Star Swim Schools Clyde Centres for various purposes, including publicity and advertising. Guidelines are provided for personal camera/video usage, including consent requirements, prohibited areas, and usage restrictions. Compliance with staff directives and conditions is mandatory.
Types of Personal Information We Collect
2.1 General Overview
The spectrum of personal information collected is contingent upon the nature of our engagement with you. In the routine conduct of our affairs, we commonly gather personal information pertaining to:
. Customers availing our services, participating in programs, or procuring goods. . Volunteers, employees, and other personnel associated with us.
. Partners and their respective personnel.
. Service providers and their staff.
Common Types of Information Collected
The typical categories of information we procure encompass:
. Name and contact particulars (e.g., address, email, and phone number).
. Date of birth and next of kin details, if pertinent to the service or activity. . Photographic, video, and image content.
. Payment particulars (e.g., credit card, bank, and direct debit information) for transactions conducted with us.
. Details essential for rendering the requested service, program, or product, inclusive of eligibility confirmation and special requirements.
. Records pertaining to services, programs, and goods dispensed (e.g., registration specifics, attendance records, purchase documentation).
. Membership or account specifics if created for our services, programs, or facilities. . Additional information volunteered by you (e.g., during telephonic or written correspondence, program or service applications, website or social media interactions, or survey responses).
. Emergency contact details if you're a parent or legal guardian of a minor utilizing our services.
. Information relevant to your role within Star Swim Schools Clyde if you're a volunteer, employee, or staff member (e.g., qualifications, tenure, resume, employment history, remuneration details, feedback, training logs, equipment usage).
. Details pertinent to your role within Partner organizations or service providers, as relevant to our collaborative endeavors.
. Identification verification upon request.
. Recorded telephone conversations for quality assurance and training objectives. . Details logged during visits to our premises or facilities, including contact information provided, date and time of visitation, and any captured images or voices via Closed-Circuit Television (CCTV) or similar surveillance systems, for safety, security, and regulatory compliance.
Additional Information
Certain services, programs, or initiatives may necessitate the collection of distinct data types. In such instances, reasonable efforts are made to inform individuals about the nature and handling of such information through written or verbal privacy collection statements.
As customary within the not-for-profit sector, we maintain contact lists and databases for marketing and advertising endeavors. Refer to Section 7 of this policy for detailed insights.
Visitors to our website may have certain information collected regarding their visit and website usage. Please refer to Section 8 for comprehensive details on this matter.
2.2 Sensitive Information (Including Health Information)
Sensitive information encompasses specific categories of personal data, such as health information, racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of political, professional, or trade associations, as well as biometric and genetic information.
The collection of sensitive information about you is conducted solely with your explicit consent or in accordance with applicable privacy laws. Primarily, the sensitive information we may gather includes:
. Details of injuries (i.e., health information) sustained at our facilities or in connection with our services or programs, aimed at incident recording, injury management, and handling associated claim procedures (e.g., insurance claims).
. Information regarding disabilities or allergies (i.e., health information) disclosed to us to accommodate any special requirements during your engagement with our premises, services, or programs.
. Personal details shared by you (e.g., ethnicity, religious beliefs, or sexual orientation) to ensure culturally sensitive and appropriate delivery of our services and programs. . Membership affiliations with professional associations or relevant industry bodies pertinent to circumstances such as employment, consulting, or volunteering considerations. . Criminal record particulars as part of background assessments for roles within Star Swim Schools Clyde.
Should you provide sensitive information to us for any purpose, such action signifies your consent to its collection, usage, and disclosure for the intended purpose and as permitted by applicable laws, including privacy legislation.
2.3 Government Identifiers
In certain situations, the need may arise for your government identifiers, such as Tax File Numbers or Medicare numbers.
We typically request government identifiers when essential for identity verification, mandated by law, or deemed relevant and necessary for the specific service, program, or role you've sought.
2.4 Information Required or Authorized by Law
Collection, utilization, and disclosure of personal information may occur when mandated or permitted by law.
Certain services and programs we provide are subject to regulatory frameworks necessitating the collection, utilization, and disclosure of specific personal data. Failure to furnish requisite information may preclude access to such services and programs.
For instance, our swim programs for children and young people adhere to child safety legislation mandating the collection of specified information and reporting obligations to child safety authorities.
How We Collect Personal Information
3.1 General Collection Methods
The primary method of acquiring personal information is through direct provision by individuals. We endeavor to obtain personal information directly from you whenever reasonable and feasible.
Common scenarios wherein we may gather personal information from you include:
. Participation in our programs, services, or purchasing transactions.
. Application for roles within our organization.
. Subscription to our mailing lists.
. Engagement with our marketing or advertising endeavors.
. Provision of feedback or participation in surveys, community engagement, or stakeholder consultation activities.
. Supply of goods or services to Star Swim Schools Clyde.
. Submission of inquiries, requests, applications, or complaints.
. Communication through our websites, telephone, email, social media platforms, or other channels.
. Visitation to our premises, facilities, or utilization of our computer networks.
For organizational efficiency, records of our correspondence and interactions with you may be maintained.
In certain instances, it may be necessary to procure personal information from publicly available sources or third parties, subject to legal permissions. Examples include:
. Acquisition of contact details from publicly available sources for community engagement endeavors.
. Collection of information from parents or legal guardians if you are a minor. . Receipt of information from agencies nominating or referring applicants for referral-only programs.
. Gathering of information from referees, government bodies, academic, and professional institutions during the recruitment process for validation of qualifications and background checks.
3.2 Technology Services Utilization
Similar to numerous organizations, we employ a range of technology services to facilitate program delivery, operational functions, and activities. These services are often provided and managed by third-party service providers.
In some instances, these technology services are utilized to gather information from or about you. Examples include:
. Utilization of social media platforms like Facebook and Twitter for community engagement purposes.
. Engagement of third-party services for conducting surveys.
. Requirement or optional utilization of third-party apps or websites for specific programs or services.
. Usage of cookies, web analytics, and similar technologies during website visits (refer to Section 8 for further details).
Information collected through these third-party technology services is utilized for the purposes outlined in this Privacy Policy. Each service may have its own privacy policy governing the handling and processing of collected personal information.
For communications via social media platforms, it's crucial to note that certain pages may be publicly accessible. We encourage the utilization of privacy settings available on each platform for discretion. Private communication with us can be initiated using the contact details provided in Section 11.
Disclosures of Your Personal Information
4.1 General Disclosure Principles
Depending on the nature and purpose of the collected information, there may arise instances where disclosure of your information to other individuals or entities becomes necessary.
In principle, we disclose information about you to others only:
. When aligned with the primary purpose for which the information was initially collected, or for a related purpose that you would reasonably anticipate.
. With your explicit consent.
. When legally mandated or authorized.
Whenever a third party, such as a contractor, is engaged to manage your personal information on our behalf, stringent measures are enforced to ensure the safeguarding and secure handling of your information.
We abstain from selling your information to other entities and undertake measures to ensure that our marketing and advertising endeavors adhere to relevant laws, including privacy, direct marketing, and anti-spam legislation.
4.2 Examples of Information Sharing
The entities and individuals with whom we commonly share information encompass:
. Our staff (including employees, contractors, and volunteers) requiring access to information pertinent to their roles.
. Service providers, including:
. IT service providers offering web hosting, cloud services, IT support, and cybersecurity services.
. Entities assisting us in marketing and advertising activities (e.g., call centers, mailing houses, online targeted advertising networks, social media platforms, and data analytics providers).
. Accountants, insurers, lawyers, auditors, and other professional advisors. . Payment processors and other entities aiding in transaction processing. . Our Partners, who may:
. Offer funding for our programs and services.
. Provide equipment and facilities.
. Assist in program and service delivery (e.g., health service providers, other charities, and community service organizations).
. Government agencies, regulatory bodies, and law enforcement agencies, when mandated by law or deemed reasonably necessary in the circumstances.
. Authorized persons responsible for you (e.g., your parent or legal guardian if you are a minor).
. Universities and research organizations.
Certain programs and services may be executed by Star Swim Schools Clyde on behalf of our Partners, including federal, state/territorial, and local governments. In such scenarios, we may be obligated to:
. Report to the funding organization regarding the utilization of provided funds. . Transfer program or service records (including attendance or participation records) to the funding organization upon program or service completion or at their request.
Storage, Management, and Security of Personal Information
. Safeguard personal information against misuse, interference, loss, unauthorized access, modification, or disclosure.
. Ensure the accuracy, completeness, and currency of information pertaining to you.
We deploy an array of security protocols to protect the personal information within our purview, including the implementation of IT security tools to fortify our electronic databases.
Our electronic records housing personal data are securely stored within Australian-based data centers, maintaining compliance with stringent security standards.
Access to personal information is restricted solely to authorized staff, volunteers, and subcontractors for approved purposes.
Upon cessation of necessity, we diligently undertake reasonable steps to either destroy or de-identify records containing your personal information. The retention period for such records is contingent upon the nature of the information and the purpose of its collection.
Location of Personal Information
International Disclosures
Certain third parties to whom we may disclose personal information could be situated outside Australia. The specific countries wherein such third-party recipients are based may vary depending on circumstances.
In the ordinary course of business, personal information may be disclosed to overseas recipients in countries such as the United States, the United Kingdom, and the European Union. Typically, these overseas recipients comprise IT service providers catering to Star Swim Schools Clyde. It's important to note that the engagement of overseas service providers for storing personal information does not necessarily equate to disclosure of personal information to said providers.
Whenever the transfer of personal information outside Australia is necessitated, we adhere to the requirements outlined in applicable privacy and data protection laws. Disclosure to overseas recipients may occur without your explicit consent if permitted by applicable Australian privacy laws, with strict adherence to pertinent legal requirements.
Should you opt to engage with us via social media platforms such as Facebook or Twitter, it's pertinent to acknowledge that these platforms may utilize facilities located outside Australia for the collection and storage of your information.
Marketing and Advertising Activities
7.1 Overview
Marketing and advertising endeavors play a pivotal role in the ongoing advancement and expansion of Star Swim Schools Clyde and its programs.
Periodically, we may reach out to you to furnish copies of our marketing and advertising materials through various channels including phone, post, email, SMS, internet advertising, or other means.
You may find yourself added to our mailing list and/or marketing databases under the following circumstances:
. If you expressly convey your desire to be added.
. If such addition aligns with legal permissions to dispatch marketing materials and advertising.
7.2 Email Analytics
Similar to numerous organizations, we utilize email analytics to assess and quantify the efficacy of our email newsletters, marketing emails, and other email campaigns.
Various technologies, including tracking pixels, facilitate the acquisition of information such as email opens, clicked links, email client usage, device types, and geolocation data. These insights are instrumental in analyzing and enhancing the performance of our email campaigns.
7.3 Internet Advertising
To optimize the targeting of our advertisements to individuals with heightened interest, we may leverage online targeted advertising services. These services aid in showcasing our ads on websites, apps, and social media platforms frequented by our target audience.
Examples of such services encompass:
. Retargeting: To display our ads on other sites to individuals who have previously visited our website.
. Behavioral Advertising: To tailor ads based on user behavior across various online platforms.
. Audience-based Advertising: To target individuals on other sites who are members of our databases or share similarities with our customer base.
While some services utilize non-identifiable statistical data acquired through cookies and tracking technologies, others may necessitate limited disclosure of personal information to effectively target and disseminate ads.
Any utilization of advertising services involving the use or disclosure of personal information strictly adheres to applicable privacy laws.
For detailed information about the tracking technologies employed on our websites, refer to section 8.2 below.
7.4 Opt-out Requests
Should you prefer to cease receiving direct marketing communications or opt out of targeted advertising initiatives utilizing your personal information, you may submit your request to our Marketing Manager via email at: clyde@StarSwimSchools.com.au. Alternatively, you can reach out to us using the contact details provided in section 11 of this Privacy Policy.
Certain categories of communications, mandated or permitted by law, may not be subject to opt-out requests.
Additionally, you have the option to opt out of specific online targeted advertising networks by visiting the Digital Advertising Alliance's opt-out portal at: http://optout.aboutads.info/.
OUR WEBSITES
8.1 Overview
Star Swim Schools Clyde meticulously collects diverse information, including personal information, via our websites and e-commerce systems. We uphold the security of our
websites through the implementation of industry-standard SSL encryption, ensuring the confidentiality of your data.
Upon visiting our website, we collect:
. Information voluntarily provided by you through website interactions. . Other information automatically collected through cookies, web analytics, and analogous technologies.
8.2 Usage of Cookies, Web Analytics, and Similar Technologies
Our websites leverage cookies and tracking technologies to gather non-identifiable information, facilitating website management and enhancing user experience. Unless you voluntarily furnish details by completing a web form or logging in, your anonymity remains intact.
Information collected includes:
. Visitation timestamp.
. Viewed pages.
. Device specifications.
. Geo-location and IP address.
. Referring website address.
Cookies serve to deliver secure, personalized services and are instrumental in enhancing website functionality. By accessing the website, you consent to Star Swim Schools Clyde's utilization of such technology. While most internet browsers default to accepting cookies, you retain the option to configure preferences to reject cookies. However, rejecting cookies may curtail website functionality and personalized experience.
Our websites deploy session cookies for analytical purposes, generating visitor behavior insights to enhance website performance. This data is reported in aggregate form for analytical purposes. Google Analytics, for instance, facilitates this function and offers an opt-out browser add-on.
Furthermore, our websites utilize tags like the Facebook advertising pixel to measure traffic and visitor behavior. These tags, devoid of personally identifiable information, aid in remarketing and audience targeting efforts.
8.3 Links
Our websites feature links to external websites and third-party providers. We disclaim any responsibility for the privacy practices of these third-party websites and their associated content. It is incumbent upon third-party websites to elucidate their privacy policies and procedures to users.
We encourage users to peruse the pertinent privacy policies or terms and conditions governing linked third-party sites to ensure alignment with their privacy preferences.
ACCESSING, CORRECTING, AND TRANSFERRING YOUR INFORMATION 9.1 Your Rights to Access and Correct Your Information
. Access to personal information held by us.
. Correction of errors in personal information held by us.
Additional access and correction rights may be conferred under state or territorial privacy and freedom of information laws.
Requests for access or correction are handled in compliance with applicable laws. In instances where refusal is mandated or permitted by law, a written explanation is furnished.
9.2 How to Submit an Access or Correction Request
To make an access or correction request, kindly utilize the contact details provided in section 11 of this Privacy Policy below.
Verification of your identity may be necessary before processing your request. If you're requesting access or correction on behalf of another individual (e.g., your child or someone under your care), we may require confirmation of your authorization.
No charges apply for requesting access to or correction of your information. However, if costs are incurred (e.g., retrieval and copying), we may request a reasonable fee to cover those expenses.
We retain the discretion to decline correction of your personal information if we disagree with its necessity. In such cases, we will furnish a written notice detailing the reasons for refusal. No charges are applicable for actions taken in response to a correction request.
All requests for access to or correction of personal information will be addressed within a reasonable timeframe.
9.3 Parents and Legal Guardians
If you are a parent or legal guardian of a child (under 18) who has utilized our programs or services, you may request access to their information. However, there are circumstances where we may refuse to provide the requested information, such as when it:
. Violates the law.
. Poses a serious threat to the life, health, or safety of the child or another individual. . Unreasonably affects another person's privacy.
If we determine that your child is capable of making their privacy decisions, obtaining their approval may be required by privacy laws before granting you access.
MAKING A COMPLAINT
10.1 How to Submit a Complaint
Should you wish to lodge a complaint regarding our handling of your personal information, kindly submit your complaint in writing using the contact details provided in section 11 of this Privacy Policy below.
10.2 How We Handle Complaints
We take all privacy complaints seriously. Upon receipt of your complaint, we will respond within a reasonable period, adhering to any legal timeframes. Cooperation from your end by providing relevant information aids in our investigation.
Our typical procedure involves appointing a designated officer to review the complaint, engage with relevant parties, and determine appropriate steps for Star Swim Schools Clyde in response. Following assessment, we will contact you (usually by phone) to convey our decision. If unsatisfied, further discussion or referral to our privacy regulator is available.
10.3 What if I am Unsatisfied with Star Swim Schools Clyde's Response? Our primary privacy regulator is the Office of the Australian Information Commissioner (OAIC). If discontent with our response, you may escalate your complaint to the OAIC.
Complaints under the Privacy Act 1988 (Cth) must be submitted to the OAIC in writing via email or the OAIC's online form. Alternatively, you may contact the OAIC by phone, although written confirmation may be required.
In some instances, additional rights to complain may exist under State and Territory privacy laws. The OAIC may redirect complaints to the appropriate regulator, or you may directly submit your complaint to the regulator of choice.
CONTACTING US
For privacy queries, complaints, or requests for access or correction of personal information, you can reach us through the following channels:
Email: clyde@StarSwimSchools.com.au
Phone: Star Swim Schools Clyde Customer Contact Centre: 0493433076 Postal Address:
Star Swim Schools Clyde Customer Contact and Support Team
2/38 Palladium Circuit, Clyde North, VIC 3978