1        PURPOSE OF OUR POLICY

1.1         Guroo Producer Pty Ltd ABN 74 613 775 616 (we, us or our) respects your right to privacy and has adopted this Privacy Policy to ensure that we have standards in place to protect the Personal Information that we collect about individuals that is necessary and incidental to:

(a)           Providing the system and services that weoffer (including PRODUCER and Academy learning portal); and

(b)           The normal day-to-day operations of our business.

1.2          This Privacy Policy follows the standards of the Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) (As Amended) (Privacy Act), and to the extent applicable, the EU General Data Protection Regulation (GDPR).

1.3          By publishing this Privacy Policy we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.

2        WHO AND WHAT THIS POLICY APPLIES TO

2.1          Our Privacy Policy deals with how we handle “personal information” as it is defined in the Privacy Act (Personal Information).

2.2          We handle Personal Information in our own right and also for and on behalf of our customers and users.

2.3          Our Privacy Policy does not apply to information we collect about businesses, companies or educational institutions, however it does apply to information about the people in those businesses, companies or educational institutions that we store.

2.4          The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.

2.5          If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person’s consent to provide such information for the purpose specified.

2.6          Users under the age of 18 years must not use our website and services without their parent or legal guardian’s consent.

3        THE INFORMATION WE COLLECT

3.1          In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, share Personal Information when asked of us, contact the individual in the ordinary course of business and transact with the individual.  Without limitation, the type of information we may collect is:

(a)           Personal Information.  Personal information is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonablyidentify an individual, either directly or indirectly.

(b)           Contact Information.  We may collect information such as an individual’s email address, telephone & fax number, third-party usernames, residential, business and postal address and other information that allows us to contact the individual;

(c)           Answers. We may collect an individual’s answers to questions within Guroo Producer.

(d)           Financial Information.  We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;

(e)           Statistical Information.  We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and

(f)            Information an individual sends us.  We may collect any personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities.

3.2          We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support which we will maintain in accordance with this Privacy Policy.

3.3          We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser.  This may include their IP address. Where non-Personal Information is collected the Australian Privacy Principles do not apply.

4        HOW INFORMATION IS COLLECTED

4.1          Most information will be collected in association with an individual’s use of PRODUCER or the Academy learning portal, an enquiry about Guroo Producer or generally dealing with us.  However, we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners.  In particular, information is likely to be collected as follows:

(a)           Registrations/Subscriptions.  When an individual registers or subscribes for a service, account, connection or other process whereby they enter Personal Information details in order to receive or access something, including a transaction;

(b)           Sharing with other Users.  When an individual provides Personal Information to other users of the website or service;

(c)           Supply.  When an individual supplies us with goods or services;

(d)           Contact.  When an individual contacts us in any way;

(e)           Access.  When an individual accesses us physically we may require them to provide us with details for us to permit them such access.  When an individual accesses us through the internet we may collect information using cookies (if relevant – an individual can adjust their browser’s setting to accept or reject cookies) or analytical services; and/or

(f)            Pixel Tags. Pixel tags enable us to send email messages in a format customers can read and they tell us whether mail has been opened.

4.2          As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected. By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.

4.3          Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Australian Privacy Principles.

5        WHEN PERSONAL INFORMATION IS USED & DISCLOSED

5.1          In general, the primary principle is that we will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission.  The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.

5.2          We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

5.3          If it is necessary for us to disclose an individual’s Personal Information to third parties in a manner compliant with the Australian Privacy Principles in the course of our business, we will inform you that we intend to do so, or have done so, as soon as practical.

5.4          We will not disclose or sell an individual’s Personal Information to unrelated third parties under any circumstances.

5.5          Information is used to enable us to operate our business, especially as it relates to an individual.  This may include:

(a)           The provision of goods and services between an individual and us;

(b)           Verifying an individual’s identity;

(c)           Communicating with an individual about:

i               Their relationship with us;

ii              Our goods and services;

iii            Our own marketing and promotions to customers and prospects;

iv            Offers from our partners to our customers;

v              Competitions, surveys and questionnaires;

(d)           Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or

(e)           As required or permitted by any law (including the Privacy Act).

5.6          There are some circumstances in which we must disclose an individual’s information:

(a)           Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;

(b)           As required by any law (including the Privacy Act); and/or

(c)         If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.

5.7          We will not disclose an individual’s Personal Information to any entity outside of Australia that is in a jurisdiction that does not have a similar regime to the Australian Privacy Principles or an implemented and enforceable privacy policy similar to this Privacy Policy. We will take reasonable steps to ensure that any disclosure to an entity outside of Australia will not be made until that entity has agreed in writing with us to safeguard Personal Information as we do.

5.8          We may utilise third-pay service providers (such as Gmail from Google, Inc., and MailChimp from The Rocket Science Group LLC) to communicate with an individual and to store contact details about an individual. These service providers are located in the United States of America.

6        GENERAL DATA PROTECTION REGULATION (GDPR) FOR THE EUROPEAN UNION (EU)

6.1         Guroo Producer Pty Ltd will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.:

6.2          We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.

6.3         We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.

6.4          We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.

6.5         We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legalobligation.

6.6          We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.

6.7         We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.

6.8          You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

7        YOUR RIGHTS UNDER GDPR

7.1          If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. Guroo Producer Pty Ltd complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.

7.2          Except as otherwise provided in the GDPR, you have the following rights:

(a)           to be informed how your personal information is being used;

(b)           access your personal information (we will provide you with a free copy of it);

(c)           to correct your personal information if it is inaccurate or incomplete;

(d)           to delete your personal information (also known as "the right to be forgotten");

(e)           to restrict processing of your personal information;

(f)           to retain and reuse your personal information for your own purposes;

(g)           to object to your personal information being used; and

(h)           to object against automated decision making and profiling

7.3          Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy. 

7.4          We may ask you to verify your identify before acting on any of your requests.

8        HOSTING AND INTERNATIONAL DATA TRANSFERS

8.1          Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia. These may include, but are not limited to countries in Asia, the United States of America, EU countries and/or the United Kingdom.

8.2          Transfers to each of these countries will be protected by appropriate safeguards, including the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website, and our Security Architecture and Design in place with our hosting partner.

8.3          The hosting facilities for our servers is situated in Australia. Transfers to Australia will be protected by appropriate safeguards, including the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website, and our Security Architecture and Design in place with our hosting partner.

8.4          Our Suppliers and Contractors are situated in Australia. Transfers to each of these Countries will be protected by appropriate safeguards, including the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website, and our Security Architecture and Design in place with our hosting partner.

8.5         You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
 

9        OPTING “IN” OR “OUT”

9.1          An individual may opt to not have us collect their Personal Information.  This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us.  They will be aware of this when:

(a)           Opt In.  Where relevant, the individual will have the right to choose to have information collected and/or receive information from us; or

(b)           Opt Out.  Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.

9.2          If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below.

10        THE SAFETY & SECURITY OF PERSONAL INFORMATION

10.1          We may appoint a Privacy Officer to oversee the management of this Privacy Policy and compliance with the Australian Privacy Principles and the Privacy Act.  This officer may have other duties within our business and also be assisted by internal and external professionals and advisors.

10.2          Guroo Producer Pty Ltd is committed to ensuring that the information you provide to us is secure.  In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

10.3          Guroo Producer uses SSL encryption to store and transfer Personal Information.  Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft. Despite this, the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed.  Each individual that provides information to us via the internet, over the phone or by post does so at their own risk.  We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.

10.4          The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

10.5          We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws).  The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.

10.6          If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.

10.7          We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.

11        HOW TO ACCESS AND/OR UPDATE INFORMATION

11.1          Users of PRODUCER can update their Personal Information from within their PRODUCER account or profile.

11.2          You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable the EU GDPR.  If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at loiswake@gurooproducer.com.

11.3          If an individual cannot update its own information, we will correct any errors in the Personal Information we hold about an individual within 7 days of receiving written notice from them about those errors.

11.4          It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.

11.5          We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the Personal Information we hold about them.

12        COMPLAINTS AND DISPUTES

12.1          If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing the address below.  We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

12.2          If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.

12.3          If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.

13      CONTACTING INDIVIDUALS

13.1        From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.

14      CONTACTING US

14.1        All correspondence with regards to privacy should be addressed to:

The Privacy Officer
Guroo Producer Pty Ltd
G04/38-52 Waterloo Street,
Surry Hills 2010,
NSW, Australia

privacy@gurooproducer.com

You may contact the Privacy Officer by email in the first instance.

15      ADDITIONS AND/OR AMENDMENTS TO THIS POLICY

15.1        Please be aware that we may change this Privacy Policy in the future.  We may modify this Policy at any time, in our sole discretion, and all modifications will be effective immediately upon our posting of the modifications on our website at http://www.gurooproducer.com. Please refer back to this Privacy Policy from time to time to review any amendments.

15.2        We may do things in addition to what is stated in this Privacy Policy to comply with the Australian Privacy Principles, and nothing in this Privacy Policy shall deem us to have not complied with the Australian Privacy Principles.

16      WEBSITE

16.1        When you visit our website (www.gurooproducer.com), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

16.2        We may from time to time cookies on our website. Cookies are very small   files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. 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.

16.3        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 Guroo Producer Pty Ltd 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.