Privacy Policy
WorkPlan Pty Ltd ACN 070 917 289 (WorkPlan, We, Our, Us and other similar terms) takes all reasonable steps to implement processes and procedures for the responsible management of Personal Information and Data.
We have implemented this Privacy Policy in accordance with the Australian Privacy Principles (APP) and other data protection rules in order to be open and transparent about how We collect, hold, and use Your Personal Information, and under what circumstances We may disclose or transfer it.
This Privacy Policy applies to all Personal Information collected by Us in the course of operating Our Business and in providing access to the Workplan Learning Platform to End Users authorised by Our Subscribers (You, Your and other similar terms) and forms part of our Terms of Service with Subscribers.
1. Definitions used in this Privacy Policy
In this Privacy Policy, unless the context or subject matter otherwise require:
Data means any information which is reduced to electronic form and stored in any of our computer systems.
Data Breach means any unauthorised access to, unauthorised disclosure of, or loss of, Personal Information held by Us where the access, disclosure or loss is likely to result in serious harm to any of the individuals to whom the information relates.
End User means a person authorised by the Subscriber to access and use the Workplan Learning Platform.
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- (a) whether the information or opinion is true or not; and
- (b) whether the information or opinion is recorded in a material form or not.
Subscriber means that entity that enters into contract for the provision of the Workplan Learning Platform pursuant to an agreement labelled Terms of Service.
Terms of Service means the terms and conditions on which Subscribers and their End Users obtain access to the Workplan Learning Platform.
Workplan Learning Platform means the software which We make available to Subscribers to access and use which is available from https://workplan.com.au/workplan-learning/ pursuant to the terms and conditions of our Terms of Service.
2. Collection
2.1 Collection of Personal Information
(a) We collect Personal Information:
- (i) when Subscribers and potential Subscribers interact with us online, over the phone, by email, in person or through other means of communication; and
- (ii) in order to assist Subscribers and their employees to obtain the full benefit of Workplan.
(b) The type of Personal Information We collect for the purpose of our business includes Personal Information about a Subscriber’s employees including name, address, mobile and office phone numbers, email, position or job title, profile image, address, city and any additional information You provide to Us from time to time.
- (i) Where You contact Us on behalf of the Subscriber, the information You provide often contains information about Your employment, position and employers contact details. In those circumstances certain employment information is collected.
- (ii)Information will only be collected directly from You unless You authorise another person to provide the information.
(c) The type of Personal Information that End Users authorised by Subscribers upload to Workplan includes name, address, mobile and office phone numbers, email, position or job title, profile image, address, city and any additional information You provide to Us.
2.2 Device information and cookies
(a) When You visit our website at www.workplan.com.au and www.workplanlearning.com.au, We may collect certain information about Your device, including details about Your Web browser, IP address, time zone, and some of the cookies that are installed on Your device. Additionally, as You browse these websites, We collect information about the individual Web pages, You view, what websites or search terms referred You, and information about how You interact with Us online.
(b) We collect device information using the following technologies:
- (i) “Cookies” which are data files placed on Your device or computer which may include an anonymous unique identifier;
- (ii) “Log files” which track actions occurring on the website, and collect data including Your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps; and
- (iii) “Web beacons”, “tags”, and “pixels” which are electronic files used to record information about how You browse Websites.
(c) Please note that We do not alter our Websites’ data collection and use practices when We see a Do Not Track signal from Your browser.
(b) Through Our use of Google Analytics, the information generated by the cookie about Your use of the website (including Your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating Your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
(e) Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
(f) You may refuse the use of cookies by selecting the appropriate settings on Your browser, however if You do, You may not be able to use the full functionality of Our website.
(g) We do not collect Personal Information or associate the information collected via cookies, web beacons, tags, log files or pixels with other Data We hold.
3. Consent
By agreeing to this Privacy Policy, You give us Your consent to use Your Personal Information as set out herein. You have a right to withdraw Your consent at any time and may do so by contacting Us via the details provided below.
By using our website, You consent to the processing of data about You by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if You disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.
4. Use
4.1 General use
(a) We use Personal Information collected as part of Our business operations which are primarily associated with the provision of the Workplan Platform to Subscribers. Examples of when Your information may be accessed and used include:
- (i) informing You about WorkPlan Learning Platform software updates, features and functionality;
- (ii) Notify You of scheduled downtime or unexpected downtime of Workplan Learning Platform;
- (iii) providing You with online or onsite training information;
- (iv) informing you of upcoming news and events;
- (v) processing and scheduling attendances to events;
- (vi) receiving from You, feedback and ratings for WorkPlan Learning or otherwise in relation to the services that we provide;
- (vii) notifying You of changes to Our Privacy Policy or Terms of Service or any other legal or regulatory information We believe is important;
- (viii) administration requirements in relation to providing Subscribers with access to the Workplan Learning Platform including managing the Subscriber’s account;
- (ix) dealing with requests for support, enquiries or complaints and other customer care related activities;
- (x) carrying out any activity in connection with a legal, governmental or regulatory requirement imposed on Us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.
(b) We may also use Personal Information for purposes, as would be reasonably expected by You, in connection with those activities described above. However, We will not use Your Personal Information for purposes, other than as described in this Privacy Policy or other agreement We have with You, unless You consent to that use or there are specific law enforcement, public health or safety reasons.
4.2 Direct marketing
Where You have elected to be included on our mailing list or to receive other electronic communications, We may use Your contact details to send You those communications. To opt-out of receiving marketing material, You may contact Us via the details below or select the “unsubscribe” link provided in that communication.
5. Accessing Your information
On Your request and after satisfying ourselves of Your identity, We will provide access to Your Personal Information We hold about You except in certain prescribed circumstances. These include, where:
(a) We believe giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
(b) giving You access would be unlawful;
(c) granting access would have an unreasonable impact on the privacy of other individuals;
(d) the request for access is frivolous or vexatious; or
(e) there are anticipated legal proceedings.
6. Data integrity
We take reasonable steps to ensure the Personal Information We collect, use and disclose is accurate, complete and up-to-date. You have a right to access and correct incorrect Personal Information at any time and may do so by contacting Us using the details provided below.
If You become aware Your information is no longer accurate, complete or up-to-date please contact Us.
7. Sharing information
(a) We may disclose Personal Information to:
-
- (i) Our employees, a related entity and Our professional advisors, such as Our lawyers and accountants;
- (ii) law enforcement agencies to assist in the investigation and prevention of criminal activities; and
- (iii) Our third-party contractors or service providers with whom We have a business association, including:
- marketing service providers;
- accounting service providers; and
- information technology service providers including cloud application providers.
(b) We may also share Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information We receive, or to otherwise protect Our rights.
(c) We will not disclose Personal Information other than in accordance with this Privacy Policy without Your consent.
8. Offshore transfers
The Personal Information We collect may be transferred out of Australia to the United States where it may be processed by third party providers, of cloud-based services, who assist Us to manage promotional material, email, office administration and accounting services. We rely solely on reputable service providers such as Nimble customer relationship manager and Eventbrite event management system.
While We do not otherwise actively disclose Your Personal Information to other overseas entities, the service providers We engage may use international data centres and disaster recovery sites. Consequently, these providers may have access to Your information.
Regardless of where You reside Your right to Privacy is protected in Australia pursuant to the Privacy Act 1988 (Cth) which is administered by the Office of the Australian Information Commissioner (OAIC). The OAIC is contactable via their Website at https://www.oaic.gov.au/.
9. Anonymity and use of pseudonyms
We may interact with You anonymously or through the use of pseudonyms if You have questions general in nature. However, You are required to provide true and accurate details when requesting that We provide You with access to the Workplan Platform.
10. Security
We take commercially reasonable steps to protect the Personal Information We hold from misuse, loss and unauthorised access, modification or disclosure. We do this by:
(a) maintaining and keeping our systems up to date;
(b) using secure servers protected from unauthorised access, modification or disclosure;
(c) where possible using two factor authentication where it is available;
(d) using secure sockets layer (SSL) encryption to transfer data across public networks, such as the internet;
(e) relying on reputable service providers; and
(f) limiting the collection of Your Personal Information to that which We reasonably require.
11. Data retention
We envisage Your Personal Information will be deleted or de-identified within ten (10) years, if it is not reasonably required for any period exceeding this.
12. Complaints procedure
We are a customer service-oriented business. Therefore, if You have a complaint about Our collection or use of Personal Information pertaining to You, then We would ask You to contact Us. Our Privacy Officer can be contacted via the information provided below.
If after investigating Your complaint and reporting to You our findings, You are still not satisfied then We ask You to consult:
The Office of the Australian Information Commissioner
GPO Box 5218
Sydney, NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
14. Contacting Us
We are obligated to regularly review and update this Privacy Policy. As such We may update it from time to time in order to reflect changes to our practices or for other operational, legal or regulatory reasons.
15. Amendments
For more information about our privacy practices, if You have questions, or if You would like to make a complaint, please contact Us using the details below:
Privacy Officer
WorkPlan Pty Ltd ACN 070 917 289
Level 4, 303 Adelaide Street Brisbane, QLD, 4000
Telephone: 07 3220 2229
Email address: contact@workplan.com.au
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Head Office
1300 726 708
+61 7 3220 2229
Melbourne Office
+61 3 9752 5651
In the spirit of reconciliation WorkPlan acknowledges the Traditional Custodians of country throughout Australia and their connections to land, sea and community. We pay our respect to their Elders past and present and extend that respect to all Aboriginal and Torres Strait Islander peoples.