inCommunity Inc – Privacy Policy

This document is the Privacy Policy of inCommunity Inc ABN 65 653 625 605 (referred to as “inCommunity”; “we”, “us” and “our”) and sets out how we collect, use, disclose and otherwise handle your personal information.

We are committed to protecting and maintaining your personal information in compliance with our obligations under the Australian Privacy Principles and the Privacy Act 1988 (Cth) (“Privacy Act”)

By submitting your personal information to us, using our website and app, or accessing our services, you agree to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy.

1. The kinds of personal information we collect and hold

We may collect information from you when you visit or use our website or app, use our services or submit your personal information to us.

Personal information we collect and hold may include, but is not limited to:

• your name and contact details, including your email address, postal address and phone number;
• other information reasonably relevant to the provision of our services, including your age, birthdate, profession, occupation and job title;
• any other personal information you provide to us in relation to your access to our website, app or our services.

When visiting or using our website, app or accessing our services, we may also collect and store information relating to such use and access including your IP address, your browser type, details of the pages or content you accessed on our website or app and time spent and information searched on our website or app.

2. How we collect your personal information

We collect personal information through lawful and fair means. We ordinarily only collect information directly from you, unless it is unreasonable or impracticable to do so.

We may collect personal information from you in the following ways:

• through your access and use of our website or app;
• when interacting or communicating with us, including in person, by telephone, letter, fax or email;
• when accessing or using our services, including completing of any enrolment or other application forms.

From time to time, we may obtain or collect personal information about you from third party sources, including:

• other organisations or persons where you have given your consent to the disclosure of your personal information;
• your representatives;
• our referral partners or organisation we work with to deliver our services.

3. Data security and how we hold and store personal information

We hold personal information in a number of ways, which may include:

• as part of records and other electronic documents on which personal information is contained;
• on our information technology systems and servers, including those operated by third parties who provide services to us in connection with our operations and services; and
• by securely storing hard copy documents, at our various premises and using third party document management and archiving services.

We will take reasonable steps to protect all personal information which we hold from misuse, interference, loss and from unauthorised access, modification or disclosure.

You should be aware that, when using our website or app, no data transmission over the internet can be guaranteed as completely secure. We do not warrant the security of any information you transmit to us over the internet and you do so at your own risk.

We will continue to store and hold your personal information indefinitely, until such time as we no longer need it for any purpose for which the information may be used or disclosed under this Privacy Policy or under applicable privacy or data protection laws or (if earlier, and subject to the next paragraph) a reasonable time after you ask us to delete it.

We are located in Australia and all personal information we hold and store will remain in Australia unless otherwise advised by us.

4. The purposes for which we collect, hold, use and disclose personal information

We will collect, hold, use and disclose your personal information for the purpose of interacting with you, performing our activities and functions and providing our services to you. This includes, without limitation:

• to provide you with use and access to our website, our app and our services;
• to communicate and interact with you in relation to our services, including to answer or attend to your enquiries and to provide you with information and advice about our services;
• internal management purposes, including to update our records and keep your contact details up to date;
• for business and service development and marketing purposes; or
• as otherwise permitted or required by law (such as to comply with obligations under the Privacy Act in relation to mandatory data breach notification)/

We may also disclose your personal information to:

• third parties that assist us in providing services to you;
• third parties who provide services that are requested for or by you;
• parties to whom you authorise us to disclose your personal information;
• government and regulatory authorities, as required or authorised by law;
• our professional advisors; or
• other third parties permitted by law.

5. Access to and correction of your personal information

We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date.

You may request access to or correction of any personal information we hold about you by using the contact details set out below. An access fee may be charged to cover our costs of providing the requested information to you. In certain circumstances, we may refuse to provide you with access or to correct your personal information including, but not limited to where:

• giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
• giving access would have an unreasonable impact on the privacy of other individuals;
• the request for access is frivolous or vexatious;
• giving access would be unlawful; or
• denying access is otherwise required or authorised by law.

Where we do not provide you with access to your personal information, we will provide you with the reason for denying access.

6. Opting out of promotional and marketing content

You may elect to opt-out of receiving direct marketing and promotional communications by contacting us using the contact details provided below, or by any other simple means to opt-out that we provide you. However, some of our services may include a direct marketing and promotional communications feature as part of the service which cannot be removed and, as such, you may not be able to access or use some of our website or services if you elect to opt-out of all direct promotional and marketing communications.

7. Third Party Sites

Our website may contain links and pointers to other websites maintained by third party providers. These links are provided for your convenience only. These third party websites are not under our control and we do not accept responsibility for such sites (including the suitability of those sites for your intended use). You are responsible for reading the privacy policies or terms and conditions of those third party websites.

8. Complaints and contact details

If you have any queries in relation to this Privacy Policy or have any questions, comments or complaints regarding our practices you may contact us by email at privacy@incommunity.com.au

We ask that any complaint should be made first in writing to us. We will then respond to your complaint in writing and in accordance with any timeframes required by law. We may request you to provide further information about your complaint to duly assess your complaint.

For information about privacy generally, or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.

9. Changes to this Privacy Policy

We reserve the right to change, modify or update this Privacy Policy at any time, without liability to you, by publication on our website or as otherwise notified to you. You will be bound by the changes immediately upon notification or publication, unless otherwise set out in this Privacy Policy or the notice.

This Privacy Policy was last updated on 17 January 2024.