Privacy Policy

GEI EDUCATION PTY LTD ACN 632 917 492

trading as GROEI and Growth Education Institute (‘GROEI’)

Protecting personal information and privacy has always been important to us at GROEI. Amendments to Australia’s Privacy Act 1988 (Cth) (“Privacy Act”) introduced Australian Privacy Principles (APP) to replace the National Privacy Principles in March 2014. These Privacy Principles are to ensure that your personal information is handled in an open and transparent way.

This is a summary of GROEI’s policy on the management, integrity, security, collection, disclosure of and access to the personal information of clients. We recommend that you take the time to read this policy and retain a copy for future reference. This Privacy Policy is in addition to our general terms of use governing our website and services.

Please note that if you become a member of our GEI Education private Groei.Us Community Group, your activity and personal information shared via the Groei.Us Community platform will also be governed by Groei.Us Community’s Data Policy available www.groei.com.au/datapolicy.

Personal information collected and disclosed by GROEI

Information	Purpose of collection and disclosure of personal information and how we protect that personal information
·          Contact details including name, address, occupation, email, phone number and professional contact·          Copies of identification documents·          Date of birth·          Financial information·          Court proceeding information·          Publicly available information·          Information provided by on or behalf of prospective employees	Personal information is collected for:·          identification;·          to provide the services that you request;·          to do all things necessary to administer those services;·          to develop, manage and improve those services;·          investigate, prevent and deal with breaches of our agreement with you;·          conduct client surveys and inform you of any improvements that we have made to our services;·          deal with credit reporting bodies (CRBs) as to your information. This information is collected either directly from you, as authorised by you, as is required for our reasonable business purposes, or in accordance with the law. Where it is unreasonable or impractical to collect the information directly from you we may collect that information from other persons that we deal with. When your personal information is provided to us by other people including family, colleagues, clients or agents, and where it is reasonable to assume you would not already know or expect us to have the information, we will take reasonable steps to inform you that we have received your personal information. We may disclose your personal information to Third Party Sites including:·          Employees of GROEI;·          organisations and contractors that may be used to provide you with requested services;·          your company or organisation if you use our services under a corporate account;·          banks;·          credit reporting and fraud checking agencies;·          debt collection agencies, if you default in payment of monies owed to us;·          government, regulatory and law enforcement agencies where the disclosure is required or authorised by law. You may choose not to provide some of your personal details however this may limit us providing our services to you.
Unsolicited or sensitive information	We may sometimes collect sensitive information. Sensitive information is only collected if the information is reasonably necessary for the purpose of performing our functions and activities. When we collect sensitive information we will collect it directly from you or with your consent unless we are otherwise entitled to do so. We will destroy unsolicited information, whether sensitive or otherwise, unless it is necessary for the reasonable purposes of our business.
Anonymity or pseudonymity	We will preserve your anonymity or pseudonymity where practical and in accordance with the law.
Overseas Disclosure of information	Personal information collected by us may be stored, disclosed and processed both in Australia and/or overseas in the United States. Some of our third party contractors and service providers may perform some of their services overseas. If GROEI needs to disclose your personal information overseas, we will comply with the requirements of the Privacy Act that relates to trans-border data flow. To provide you with the best service possible, we may use ‘cloud’ based technology services to hold your data, including your personal information. As a consequence, your data, including your personal information may be held in the data centres used by a provider of such ‘cloud’ based technology services. It is important to note that, by becoming a GEI Education member or by using the website, you consent to your data, including your personal information being transferred to data centres located outside of Australia.
Government related identifiers	Unless you otherwise authorise us, we will not collect and/or disclose government related identifiers with the exception of your driver’s licence information which is collected in order to accurately identify you.

We may store personal information itself or such information may be stored by third party sites to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the personal information collected from loss, misuse, unauthorised use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or email transmission is ever fully secure or error free. You should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any personal information.

Marketing

Where you have consented, or where GROEI has a business relationship with you, we may send you updates about GROEI itself, information about events, or other communications. You may opt out of these communications at any time by contacting the email below. 

We do this to in order to inform you about services or events we believe might be of interest to you, develop promotional or marketing materials and display GROEI or event-related content.

To unsubscribe from our email database, please do so via any link or function contained in an email, via the website or send an e-mail to [email protected] with “UNSUBSCRIBE” typed into the subject line of the email. Note that, while you maintain a groei.Us membership, you are unable to unsubscribe from certain types of e-mails, such as important updates (including information about your account, security concerns and technical issues). You can change how often you receive updates from the Community in your membership settings https://faq.mightynetworks.com/hc/en-us/articles/204986339.

Payment default

If you default in the payment of any fees or charges to GROEI, we may give information about you to:

• a CRB to list your default in the CRB’s records. That information may then be shared by the CRB with other credit providers for credit assessment and other purposes;
• a debt collection agency to assist us to collect the payment owed to GROEI by you.

Website access and use

Where you have used GROEI website for account access, to read content, obtain contact details or to provide a testimonial, cookies may be used by GROEI to collect information including IP addresses about people from GROEI website. There are many aspects of GROEI website which can be viewed without providing personal information. Cookies allow GROEI to determine who has seen particular pages on its website and how frequently. This can help GROEI to identify your preferences and allow GROEI to recommend content it believes you would be most interested in.

For each visitor to reach the site, GROEI expressly collects the following non-personally identifiable information, including but not limited to: browser type; operating system; pages viewed while browsing the website; page access times; and referring website address. This collected information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at the website.

From time to time, GROEI may use client information from new, unanticipated uses not previously disclosed in this privacy notice. If GROEI’s information practices change at some time in the future, GROEI will use data collected from the time of the policy change for these new purposes only.

We may share your personal information with our contractors and service providers who process personal information on behalf of Growi to perform certain business-related functions. When we engage another company to perform such functions, we may provide them with information, including personal information, in connection with their performance of such functions.

Any personal information you choose to make publicly available on our website, for example, by posting comments on any of our pages, will be available to others. If you remove information that you have made public on our website, other users may have already saved or downloaded that information, and copies may remain viewable in cached and archived pages of our website.

Security and Access of your Private Information

GROEI endeavours to make sure the information we collect is accurate, complete and up to date. We shall take reasonable steps to protect personal information from misuse and loss and from unauthorised access, modification or disclosure.

Third Party Connections

We are not in the business of selling your personal information. We consider this information to be a vital part of our relationship with you. We will not sell your personal information to Third Party Sites, including third party advertisers. There are certain circumstances in which we may disclose, transfer or share your personal information with certain Third Party Sites without further notice to you.

Our website may contain links to other websites not operated or controlled by us (the “Third Party Sites”). You may provide your personal information to the Third Party Sites while in use of their websites. We are not responsible for the actions of the Third Party Sites, or their affiliates, with respect to your personal information. It is important that you review the applicable privacy policies of the Third Party Sites before providing personal information or other information in connection with that event or related webpage.

We may disclose your Personal information if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of Third Party Sites, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.

Cookies and tracking technologies

Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. We use the following types of cookies and other similar tracking technologies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that allow you to sign in and use our services and remember you when you log into secure areas of our website.
• Analytics cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our websites. Some of the tools we use only provide us with information about trends and aggregate user behaviour. Other tools we use enable us to see how each visitor engaged with our website. For example, we will be able to see what you clicked on and how you navigated through our websites. We use this information to better understand how our visitors use our websites, so that we may make the necessary improvements to enhance our visitors’ experience in the future. We do not attempt to identify you with this information.
• Functionality cookies: These are used to recognise you when you return to our services and to allow us to personalise our content for you, for example, by remembering your preferences.
• Advertising cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the content and advertising displayed on it more relevant to your interests. We also use this information to determine the effectiveness of advertising campaigns. We may also share this information with third parties for this purpose.
• Social media cookies: We use these cookies when you connect and share our content and information using a social media sharing button or “like” button on our website to keep track of the way end-customers engage with and share our content. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

You have the ability to accept or decline cookies. If you choose to decline cookies, you may not be able to sign in or use other interactive features of our websites and services, and some advertising preferences may not be able to be respected. If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted.

Destruction of Information

GROEI will destroy personal information upon your request (by telephone and/or by e-mail) or when the personal information is no longer required. The exception to this is if the personal information is required in order to fulfil the purpose of this organisation or is required to be maintained and/or stored in accordance with the law.

Your access

You may request access to your personal information we hold about you at any time.

External access to information

Any authorised representative including your spouse, accountant, financial planner and solicitors must have been authorised to receive your personal information, security checked and verified and it be recorded on our database except if it’s required in accordance with the law such as a Federal Act.

The following measures are in place in order to deal with any enquiries that would result in the divulgence of personal information:

Telephone Enquiry	Administration staff will advise the third party of privacy requirements, and seek authorisation in writing from you to divulge personal information before providing said information.
Written Enquiry	Response is provided to the address on the written enquiry but only if it is the same address as in GROEI records.
Authorised Representatives	Any authorised representative including accountants, solicitors and spouses must have been authorised by you, security checked and verified and it be recorded on GROEI database except if it’s required in accordance with the law such as a Federal Act.
Website Enquiries	User identification and password requirements for clients that are set and maintained by GROEI.

Contact for Further Information or Complaints

If you have any questions about how we handle your personal information or if you believe that we have handled your personal information inappropriately, you can contact GROEI via e-mail at [email protected]. GROEI will respond to any complaint within 14 days of receipt and will take all reasonable steps to make a decision as to the complaint within 30 days of the receipt of the complaint.

If you are not satisfied with the way in which we handle your enquiry, you can call the Office of the Australian Information Commissioner on 1300 363 992 or make a complaint to the Information Commissioner on the OAIC website at http://www.oaic.gov.au/.

Consent

You hereby agree and consent to the contents of the collection, use and disclosure of your personal information. In the event that you do not wish to agree or consent to any of the above use, collection and disclosure of your personal information by GROEI, GROEI warrants that any request by you to withdraw your consent or agreement shall be deemed as confirmation by you to cease any and/or all collection use and disclosure of your personal information. Request, in writing, can be made by you to GROEI.

This Privacy Policy applies only to GROEI and the use of GROEI’s website. The policies and procedures we described here do not apply to the Third Party Sites. The links from our website do not imply that we endorse or that we have reviewed the policies of the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Changes to this Policy

This is our current privacy policy outlining our personal information management practices. It replaces any previously published privacy policy. From time to time we may need to vary this policy. If we do so, an updated version will be posted on our website and shall apply to all the information held by us at the time.