Privacy
Policy
1.
OUTLINE
1.1
This
Privacy
Policy,
which
is
subject
to
the
Privacy
Act
and
APPs,
regulates
how
we
collect,
use
and
disclose
personal
information.
1.2
Amendment.
We
may
change,
vary
or
modify
all
or
part
of
this
Privacy
Policy
at
any
time
in
our
sole
discretion.
It
is
your
responsibility
to
check
this
Privacy
Policy
periodically
for
changes.
If
we
adopt
a
new
Privacy
Policy:
1.2.1
we
will
post
the
new
Privacy
Policy
on
the
Platform;
and
1.2.2
it
will t
ill then
apply
through
your a
r acceptance
of
it
by
subsequent
or c
r continued
use
of
the
Platform
and/or
our
Services.
2.
PURPOSE
2.1
Primary
purpose.
We
collect
your
personal
information
to
lawfully
carry
out
our
functions
and
activities
and
provide
you
our
Services
(Primary
Purpose).
2.2
Related
purposes.
In
addition
to
the
Primary
Purpose,
we
may
use
the
personal
information
we
collect,
and
you
consent
to
us
using
your
personal
information
to:
2.2.1
provide
you
with
information
about
the
Services
you
requested
and
any
other
services
and
events
you
may
be
interested
in;
2.2.2
personalise
and
customise
your
experiences
with
us;
2.2.3
help
us
review,
manage
and
enhance
our
Services
and
develop
insights
used
in
reports
or
other
content
developed
by
us;
2.2.4
communicate
with
you,
including
by
email,
mobile
and
in–application
notifications;
2.2.5
conduct
surveys
or
promotions;
2.2.6
to
process
payments
and
administer
your
account,
including
to
send
you
account
related
reminders;
2.2.7
investigate
any
complaints
about
or
made
by
you,
or
if
we h
e have r
ve reason
to
suspect
you
have
breached
any
relevant
terms;
or
2.2.8
as
required
or
permitted
by
any
law.
3.
WHAT
WE
COLLECT
3.1
Personal
information
we
collect
about
you
may
include
identification
information
such
as
your
name,
business
name,
address,
username,
password,
email
address,
telephone
number,
mobile
phone
number,
location
and
usage
data
from
our
Services.
3.2
All
of
your
financial
and
payment
information
will b
ill be
managed
by
a
third–party
provider.
We
will
not
collect
any
of
your
financial
or
payment
information
apart
from
information
regarding
how
much
credit
is
available
in
your
account
available
for
you
to
access
our
Services.
3.3
We
will
only
collect,
hold,
use
or
disclose
your
sensitive
information
with
your
consent.
4.
HOW
WE
COLLECT
4.1
How
we
collect.
Your
personal
information
may
be
collected:
4.1.1
when
you
complete
an
application,
consent,
purchase,
account
sign–up or
up or
similar
form
via
our
Platform
or
otherwise;
4.1.2
when
you
contact
us
to
make
a
query
or
request;
2020
1
4.1.3
when
you
post
information
or
otherwise
interact
with
the
Platform;
4.1.4
when
you
participate
in
one
of
our
Services,
competitions
or
surveys;
4.1.5
from
those
who
request
our
Services
on
your
behalf;
4.1.6
from
publicly
available
sources
of
information;
4.1.7
from
government
regulators,
law
enforcement
agencies
and
other
government
entities;
4.1.8
from
business
contacts,
external
service
providers
and
suppliers;
or
4.1.9
by
other
means
reasonably
necessary.
4.2
Third
party
collection.
If
we
collect
any
personal
information
about
you
from
someone
other
than
you,
to
the
extent
not
already
set
out
in
this
Privacy
Policy,
we
will
inform
you
of
the
fact
that
we
will
collect,
or
have
collected,
such
information
and
the
circumstances
of
that
collection
before,
at
or
as
soon
as
reasonably
practicable
after
we
collect
such
personal
information.
4.3
Authority.
If
you
provide
us
with
the
personal
information
of
another
individual,
without
limiting
any
other p
r provision
of
this
Privacy
Policy,
you
acknowledge
and
agree
that
the
other
individual:
4.3.1
has
authorised
you
to
provide
their
personal
information
to
us;
and
4.3.2
consents
to
us
using
their
personal
information
in
order f
r for u
r us
to
provide
our
Services.
4.4
Unsolicited
information.
If
we
receive
unsolicited
personal
information
about
you
that
we
could
not
have
collected
in
accordance
with
this
Privacy
Policy
and
the
Privacy
Act,
we
will,
within
a
reasonable
period,
destroy
or
de–identify
such
information
received.
4.5
Minors.
It
is
our
policy
to
not
collect
personal
information
from
persons
who
are
under
the
age
of
18
years
or
offer
to
send
any
promotional
material
to
such
persons.
If
you
are
under
the
age
of
18
you
will
need
the
consent
of
your
parent
/
guardian
in
order
to
provide
your
personal
information
to
us.
4.6
Anonymity.
If
you
would
like
to
access
any
of
our
Services
on
an
anonymous
basis
we
will
take
reasonable
steps
to
comply
with
your
request,
however:
4.6.1
you
may
be
precluded
from
taking
advantage
of
some
of
our
Services;
and
4.6.2
we
will
require
you
to
identify
yourself
if:
a)
we
are
required
by
law
to
deal
with
individuals
who
have
identified
themselves;
or
b)
it
is
impracticable
for
us
to
deal
with
you
if
you
do
not
identify
yourself
or
elect
to
use
a
pseudonym.
4.7
Destruction.
Subject
to
a
legal
requirement
to
the
contrary,
we
will
destroy
or
de–identify
your
personal
information
if:
4.7.1
the
purpose
for
which
we
collected
the
personal
information
from
you
no
longer
exists
or
applies,
which
includes
if
your
account
remains
inactive
for
a
sufficient
period
of
time
for
us
to
determine
it
is
no
longer in
r in
use;
4.7.2
you
delete
your
account;
or
4.7.3
you
request
us
to
destroy
your
personal
information.
5.
USE
5.1
Primary
use.
We
will
only
use
and
disclose
your
personal
information:
5.1.1
for
purposes
which
are
related
to
the
Primary
Purpose;
or
5.1.2
if
we
otherwise
get
your c
r consent
to
do
so,
in
accordance
with
this
Privacy
Policy
and
the
Privacy
Act.
5.2
We
will
not
use
your
personal
information
for
any
purpose
for
which
you
would
not
reasonably
expect
us
to
use
your
personal
information.
5.3
We
will
not
sell,
trade,
rent
or
licence
your
personal
information
to
third
parties.
5.4
Direct
marketing.
We
will
offer
you
a
choice
as
to
whether
you
want
to
receive
direct
marketing
communications
about
services.
If
you
choose
not
to
receive
these
communications,
we
will
not
use
your
personal
information
for
this
purpose.
5.5
We
will
otherwise
only
use
or
disclose
your
personal
information
for
the
purposes
of
direct
marketing
if:
5.5.1
we
collected
the
information
from
you;
5.5.2
it
is
reasonable
in
the
circumstances
to
expect
that
we
would
use
or
disclose
the
information
for
direct
marketing
purposes;
5.5.3
we
provide
you
with
a
simple
means
to
‘opt–out’
of
direct
marketing
communications
from
us;
and
5.5.4
you
have
not
elected
to
‘opt–out’
from
receiving
such
direct
marketing
communications
from
us.
5.6
You
may
opt
out
of
receiving
such
communications
by:
5.6.1
checking
the
relevant
box
on
the
form
used
to
collect
your
personal
information;
5.6.2
clicking
a
link
on
the
email
communication
sent
to
you;
or
5.6.3
contacting
us
using
our
contact
details
below.
5.7
We
may
offer
you
the
opportunity
to
receive
information
from
third
parties
regarding
goods
or
services
that
may
be
of
interest
to
you.
If
you
choose
to
receive
such
information,
we
may
forward
messages
from
such
third
parties
to
you.
If
we
do
so,
we
will
not
provide
such
third
parties
with
any
of
your
personal
information.
6.
DISCLOSURE
6.1
How
we
disclose.
We
may
disclose
personal
information
and
you
consent
to
us
disclosing
such
personal
information
to:
6.1.1
third
parties
engaged
by
us
to
perform
functions
or
provide
Services
on
our
behalf;
6.1.2
to
your
employer
or
sponsoring
organisation
(as
relevant);
6.1.3
our
professional
advisors,
including
our
accountants,
auditors
and
lawyers;
6.1.4
our
related
bodies
corporate;
6.1.5
persons
authorised
by
you
to
receive
information
held
by
us,
including
to
those
individuals
that
you
authorise
us
to
provide
information
to
via
the
Platform;
6.1.6
a
government
authority,
law
enforcement
agency,
pursuant
to
a
court
order
or
as
otherwise
required
by
law;
or
6.1.7
a
party
to
a
transaction
involving
the
sale
of
our
business
or
its
assets.
6.2
Our
third–party
payment
gateway
provider
may
disclose
your
personal
information
overseas.
Please
refer
to
the
privacy
policies
of
the
third–party
payment
gateway
provider
for
information
regarding
how
they
will u
ill use,
disclose
and
manage
your
personal
information.
6.3
If
we
send
your
personal
information
to
overseas
recipients,
we
will
take
reasonable
measures
to
protect
your
personal
information
such
as
ensuring
all
information
is
de–identified
where
appropriate
before
being
transmitted.
However,
you
acknowledge
and
agree
that
if
we
disclose
your
personal
information
to
overseas
recipients,
we
are
not
obliged
to
take
reasonable
steps
to
ensure
overseas
recipients
of
your
personal
information
comply
with
the
Privacy
Act
and
the
APPs.
7.3
If
you
make
a
request
for
access
to
personal
information, w
, we
will:
7.3.1
respond
to
your
request
within
24
hours
or
otherwise
within
a
reasonable
period;
and
7.3.2
if
reasonable
and
practicable,
give
access
to
the
personal
information
as
requested.
7.4
If
we
refuse
to
give
access
to
the
personal
information, w
, we
will
give
you
a
written
notice
that
sets
out
at
a
minimum:
7.4.1
our
reasons
for
the
refusal
(to
the
extent
it
is
reasonable
to
do
so);
and
7.4.2
the
mechanisms
available
to
complain
about
the
refusal.
7.5
Correction.
We
request
that
you
keep
your
personal
information
as
current
as
possible.
If
you
feel
that
information
about
you
is
not
accurate
or
your
details
have
or
are
about
to
change,
you
can:
7.5.1
contact
us
using
our
contact
details
below
and
we
will
correct
or
update
your
personal
information;
or
7.5.2
change
your
details
via
the
Platform.
7.6
If
you
otherwise
make
a
request
for
us
to
correct
your
personal
information, w
, we
will:
7.6.1
respond
to
your
request
within
14
days
or
otherwise
within
a
reasonable
period;
and
7.6.2
if
reasonable
and
practicable,
correct
the
information
as
requested.
7.7
If
we
refuse
a
request
to
correct
personal
information, w
, we
will:
7.7.1
give
you
a
written
notice
setting
out
the
reasons
for
the
refusal
and
how
you
may
make
a
complaint;
and
9.2.1
Request
for
further
information: W
: We
may
request
further
information
from
you.
Please
provide
us
with
as
much
information
as
possible,
including
details
of
any
relevant
dates
and
documentation.
This
will
enable
us
to
investigate
the
complaint
and
determine
an
appropriate
solution.
9.2.2
Discuss
options: W
: We
will
discuss
options
for
resolution
with
you
and
if
you
have
suggestions
about
how
the
matter
might
be
resolved
you
should
raise
these
with
our
Privacy
Officer.
9.2.3
Investigation: W
: Where
necessary, t
, the
complaint
will
be
investigated.
We
will
try
to
do
so
within
a
reasonable
time
frame.
It
may
be
necessary
to
contact
others
in
order
to
proceed
with
the
investigation.
This
may
be
necessary
in
order
to
progress
your
complaint.
9.2.4
Conduct
of
our
employees: If
: If
your
complaint
involves
the
conduct
of
our
employees,
we
will
raise
the
matter
with
the
employees
concerned
and
seek
their
comment
and
input
in
the
resolution
of
the
complaint.
9.3
After
investigating
the
complaint,
we
will
give
you
a
written
notice
about
our
decision.
9.4
You
are
free
to
lodge
a
complaint
directly
with
the
Office
of
the
Australian
Information
Commissioner
(OAIC)
online,
by
mail,
fax
or
email.
For
more
information
please
visit
the
OAIC
website
at
oaic.gov.au.
10.
CONTACT
10.1
Please
forward
all
correspondence
in
7.7.2
take
reasonable
steps
to
include
a
note
with
respect
of
this
Privacy
Policy
to:
7.
ACCESS
+
CORRECTION
7.1
Access.
If
you
require
access
to
your
personal
information, p
, please
contact
us
using
our
contact
details
below
or
through
our
Platform.
You
are
required
to
put
your
request
in
writing
and
provide
proof
of
identity.
7.2
We
are
not
obliged
to
allow
access
to
your
personal
information
if:
7.2.1
it
would
pose
a
serious
threat
to
the
life,
health
or
safety
of
any
individual
or
to
the
public;
7.2.2
it
would
have
an
unreasonable
impact
on
the
privacy
of
other
individuals;
7.2.3
the
request
for
access
is
frivolous
or
vexatious;
7.2.4
it
relates
to
existing
or a
r anticipated
legal
proceedings
between
you
and
us
and
would
not
ordinarily
be
accessible
by
the
discovery
process
in
such
proceedings;
7.2.5
it
would
reveal o
l our in
r intentions
in
relation
to
negotiations
with
you
in
a
way
that
would
prejudice
those
negotiations;
7.2.6
it
would
be
unlawful;
7.2.7
denying
access
is
required
or
authorised
by
or
under
an
Australian
law
or
a
court/tribunal
order;
7.2.8
we
have
reason
to
suspect
that
unlawful
activity,
or
misconduct
of
a
serious
nature
relating
to
our
functions
or
activities
has
been,
is
being
or
may
be
engaged
in
and
giving
access
would
be
likely
to
prejudice
the
taking
of
appropriate
action
in
relation
to
the
matter;
7.2.9
it
would
likely
prejudice
one
or m
r more
enforcement
related
activities
conducted
by,
or
on
behalf
of,
an
enforcement
body;
or
7.2.10
it
would
reveal c
l commercially
sensitive
information.
your
personal
information
of
the
fact
that
we
refused
to
correct
it.
8.
SECURITY
+
PROTECTION
8.1
In
relation
to
all
personal
information, w
, we
will
take
all
reasonable
steps
to:
8.1.1
ensure
that
the
personal
information
we
collect
is
accurate,
up
to
date
and
complete;
8.1.2
ensure
that
the
personal
information
we
hold,
use
or
disclose
is,
with
regard
to
the
relevant
purpose,
accurate,
up
to
date,
complete
and
relevant;
and
8.1.3
protect
personal
information
from
misuse,
loss
or
unauthorised
access
and
disclosure.
8.2
We
require
staff
and
service
providers
to
respect
the
confidentiality
of
personal
information.
We
store
your
personal
information
on
a
secure
server
behind
a
firewall
and
use
procedures
including
IP
Blocking,
whitelisting,
and
other s
r security
software
and
encrypted
databases
accessible
only
by
authorised
personnel
to
protect
your
personal
information
from
unauthorized
access,
destruction,
use,
modification
or
disclosure.
We
will
require
any
the
third–party
payment
gateway
provider
to
process
any
payment
transactions
through
a
PCI
compliant
payment
gateway.
8.3
Please
contact
us
immediately
if
you
become
aware
of
or
suspect
any
misuse
or
loss
of
your
personal
information.
9.
COMPLAINTS
9.1
If
you
have
a
complaint
about
how
we
collect,
use,
disclose,
manage
or
protect
your
personal
information, o
, or
consider
that
we
have
breached
the
Privacy
Act
or
APPs,
please
contact
us
using
our
contact
details
below.
We
will
respond
to
your
complaint
within
24
hours
of
receiving
the
complaint.
9.2
Once
the
complaint
has
been
received,
we
may
resolve
the
matter
in
a
number
of
ways:
Privacy
Officer
21
Churchill
Grove
Hawthorn
3122.
info@aspiresme.com
[0417
212
240]
11.
INTERPRETATION +
DEFINITIONS
11.1
Personal
pronouns: E
: Except
where
the
context
otherwise
provides
or
requires:
11.1.1
the
terms
we,
us
or
our
refers
to
Advisory
System
for
Process
Innovation
and
Resource
Exchange
Pty
Ltd
(ASPIRE)
(ABN
47
632
061b
164);
11.1.2
the
terms
you
or
your
refers
to
a
user
of
the
Platform
and/or
a
customer
to
whom
we
provide
the
Services.
11.2
Terms
italicised
and
defined
in
the
Privacy
Act
have
the
meaning
given
to
them
in
the
Privacy
Act.
11.3
Defined
terms: In
: In
this
Privacy
Policy
unless
otherwise
provided,
the
following
terms
shall
have
their
meaning
as
specified:
APPs
means
any
of
the
Australian
Privacy
Principles
set
out
in
Schedule
3
of
the
Privacy
Act.
Platforms
means
all
or
any
of
the
relevant
platforms,
electronic
interfaces
and
websites
that
are
owned,
provided
and/or
operated
from
time
to
time
by
us,
regardless
of
how
those
websites
are
accessed
by
users
(including
via
the
internet,
mobile
phone,
mobile
applications
or
any
other
device
or
other
means).
Privacy
Act
means
the
Privacy
Act
1988
(Cth)
as
amended
from
time
to
time.
Privacy
Policy
means
this
privacy
policy
as
amended
from
time
to
time.
Services
means
the
supply
or
sale
of
our
goods
and
services.
2
2020