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1. Scope

The Human Consultancy (“the Company”) is an Australian registered business.  The Company takes its obligations under the Privacy Act seriously and will take all reasonable steps to comply with the Act and to protect the privacy of the personal information that we hold.

The Company operates in many countries around the globe and strives to fulfil our obligations in respect of the management of your information in each of those countries.  

The Policy applies to the provision of personal information which allows us to identify you.  This policy does not affect our obligation of confidentiality.  The obligation to respect your privacy is in addition to obligations of confidentiality.

 

2.Personal Information 

The Company provides training programs to people and businesses which are delivered in person and online.  The Company collects information in a number of ways through researching publicly available information and where you may have volunteered it yourself by contacting us through our website, a third party website, social and professional media or by another means.

The Company may collect and hold the following personal information:

• Your name

• Location Address and contact details (electronic and physical).

• Email.

• Occupation

• Your IP address.

• Billing and Account Information.

 

3.Use and disclosure

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Personal information is also collected for the purpose of:

• To provide and maintain our Service

• To notify you about changes to our Service

• To allow you to participate in interactive features of our Service when you choose to do so

• To provide customer support

• To gather analysis or valuable information so that we can improve our Service

• To monitor the usage of our Service

• To monitor fraud and abuse

• To monitor and track our own advertising

• To detect, prevent and address technical issues

• Processing payment, financial statements and administering the internal accounting systems.

• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

 

4.How we collect personal information

The Company collects information in a number of ways including where you may have volunteered it yourself by contacting us through our website, in person by email or telephone, a third party website, social and professional media or by another means.

When you visit our website or download information from it, our Internet Service Provider (ISP) makes a record of your visit and records the following information:

• your Internet address;

• your domain name, if applicable; and

• the date and time of your visit to the website.

Our ISP also collects information such as the pages our users access, the documents they download, links from other sites they follow to reach our site, and the type of browser they use. However, this information is anonymous and is only used for statistical and website development purposes.

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5.Use of Cookies

Our website uses cookies.  A cookie is a small message given to your web browser by our web server. The browser stores the message in a text file, and the message is then sent back to the server each time the browser requests a page from the server.

We use cookies to measure how you use the site and how much traffic is attributed to each section of the site.  We may also use cookies to improve the functionality of our website and to direct users to the most relevant parts of the site.

When cookies are used by this site, they are used to store information relating to your visit such as a unique identifier, or a value to indicate whether you have seen a web page.

Most Internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer, giving you the choice whether to accept it or not.

We use the following type of cookies.

• Session Cookies. We use Session Cookies to operate our Service.

• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

• Security Cookies. We use Security Cookies for security purposes.

In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.

 

Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that The Human Consultancy Group is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

 

6.What happens if you choose not to provide the information 

You are not obliged to give us your personal information.  However, if you choose not to provide the Company with some or all of the personal information requested we may:

1. not be able to provide you with any services that the Company offers;

2. be more restricted in providing you the full range of services; and

3. decline to allow you to register on the website or use our services.

 

7.Use and Disclosure

We will use personal information for the purposes for which it was collected.

Having read and understood our terms of use, including this policy, you will have provided your authority and consent for us to collect, use and disclose your personal information. 

 

8.Storage and Security

We will take all reasonable steps to protect the security of the personal information we hold. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy.

Your information is not held on the web server but in secure data storage facilities provided by third party hosts.  The Company has Data Storage facilities in different geographic locations internationally complying with local laws wherever practicable.

It is possible that your personal information could be unlawfully and/or maliciously observed by a third party while in transit over the Internet, our secure storage servers or secure third party servers. The Human Consultancy Group disclaims all liability to you possible pursuant to the law should this occur.

 

9.Sending Information Overseas

The Company conducts itself on a global basis.  Accordingly, information may be sent to employers overseas.  You have complete knowledge of the jurisdiction where your information has been sent.

When we do send information overseas, and the laws of the receiving countries do not have comparable privacy protection laws, we will take all reasonable steps to make contractual arrangements that provide for privacy protection of the personal information that we send overseas.

 

10.Access and Complaints

1. Overriding principles

At all times, the conduct under this Policy will be governed by the following principles:

• all requests for access or any complaints will be treated seriously;

• all requests or complaints will be dealt with promptly;

• all requests or complaints will be dealt with in a confidential manner; and

• your request to access your personal information, or any complaints that you make, will not affect your existing obligations or affect the commercial arrangements between you and the Company.

  1. Form of Access

The Company will provide access by allowing you to inspect, take notes of or receive copies or print outs of the personal information that the Company holds about you.

You can make your request in writing to the Privacy Manager at support@thehumanconsultancy.com

In making your request, you will have to provide proof of your identity (for example, driver’s license or other appropriate identification). This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

 

1. When will Access be denied?

Access will be denied if:

• the request does not relate to the personal information of the person making the request;

• providing access would pose a serious and imminent threat to life or health of a person;

• providing access would create an unreasonable impact on the privacy of others;

• the request is frivolous and vexatious;

• the request relates to existing or anticipated legal proceeding;

• providing access would prejudice negotiations with the individual making the request;

• access would be unlawful;

• denial of access is authorised or required by law;

• access would prejudice law enforcement activities;

• access discloses a ‘commercially sensitive’ decision making process or information; or

• any other reason that is provided for in the National Privacy Principles.

Where possible, the Company will favour providing access. It may do so by providing access to the appropriate parts of the record or by using an appropriate ‘intermediary’.

1. Time

We will take all reasonable steps to provide access within 30 days of your request. In cases where the request is not complicated or does not require access to a large volume of information, we will take all reasonable steps to provide that information within 14 days.

1. Costs and charges

The Company has a right to charge you a reasonable fee for providing access.  For example:

• photocopying charges;

• delivery cost of information stored off-site; and

• access to electronic databases.

The charge may include the cost of our professional time.

1. Complaints

If you have provided us with personal information, you have a right to make a complaint, have it investigated and dealt with.  The Company tries to resolve complaints at the local level if possible. 

If you wish to make a complaint, please contact us  support@thehumanconsultancy.com

The Company will keep a record of your complaint and the outcome.

The Company is unable to deal with anonymous complaints.  This is because it is unable to investigate and follow up such complaints.  However, in the event that an anonymous complaint is received, we will note the issues raised and try to resolve them appropriately.

 

11.Right to Review

The Company reserves the right to review, and if necessary, revise or amend the terms of this policy.

 

1. Service Providers

 

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

• Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/intl/en/policies/privacy/

 

Remarketing

THE HUMAN CONSULTANCY uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

 

• Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/intl/en/policies/privacy/

 

• Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA https://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe https://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

By using the affiliate links, you are helping support the Service, and we genuinely appreciate your support.

 

1. GDPR - Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

 

If you are from the European Economic Area (EEA), the legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

THE HUMAN CONSULTANCY may process your Personal Data because:

• We need to perform a contract with you

• You have given us permission to do so

• The processing is in our legitimate interests and it's not overridden by your rights

• For payment processing purposes

• To comply with the law

Retention of Data

THE HUMAN CONSULTANCY will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

THE HUMAN CONSULTANCY will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

THE HUMAN CONSULTANCY will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. THE HUMAN CONSULTANCY  aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

 

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Data.

• The right of restriction. You have the right to request that we restrict the processing of your personal information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where THE HUMAN CONSULTANCY relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

1 January 2019