Last Updated 1 December 2023
As the owner of the Transition to Freedom website (www.transitiontofreedom.com.au and its subdomains) (“Website”), Boyer Business Advisory Pty Ltd (“BBA”) aims to make the following Privacy Policy comprehensive, accessible, and succinct for the reader. While we encourage you to read the document in its entirety, here is a summary for your convenience:
• The BBA privacy procedures are in line with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth) (Privacy Act).
• We collect and store a range of personal data, both directly (for example, when providing it to us via our website) and indirectly (that is, records on how you interacted with our website, for example, when you clicked a button).
• We do not use data for any purpose other than to provide you with BBA services or provide you with pertinent updates.
• We take all reasonable steps to ensure the security and integrity of your personal information.
• We do not access personal information we store on your behalf without your consent.
• In the unlikely event of a data breach that could result in harm, we will immediately notify you and the Australian Information Commissioner.
BBA may review and update this Privacy Policy including taking into account new laws, regulations, and technology. All personal information held by us will be governed by our most recent Privacy Policy, posted on our website: www.boyerbusiness.com.au/. Our most recent Privacy Policy will apply to our collection, use, and disclosure of personal information.
What information we collect:
BBA collects several types of personal information about people who interact with us, both offline and online. Under the Privacy Act, personal information is information or an opinion about an identified individual, or a reasonably identifiable individual, whether the information is true or not, and whether recorded in a material form or not (personal information).
Contacting us:
If you write to us via email or one of our contact forms, for example when asking for assistance or making a sales enquiry, we’ll keep a record of that correspondence for future reference. The same applies to surveys, website forms, or competition entry forms.
Interacting with BBA:
This Privacy Policy together with the BBA usage terms and conditions govern how we use, collect or disclose personal information provided on the Website. By using the Website you agree to the terms and conditions contained in this Privacy Policy and the BBA usage terms and conditions.
Prior to account activation, we request that you provide your email address, full name, and password. We ask for this information so that we can personalize your account, provide better assistance for your usage of the Website, and communicate important updates.
Anonymous accounts:
BBA does not require users’ real names to operate, though we believe it provides a better user experience for our community! You have the option of entering a pseudonym or aliased numeric as your name for use with our online service. Please note that we highly recommend you provide us with an active email address, as this is the only way you can gain initial access to all resources provided to you.
Please remember that if you provide personal information about other individuals to us, you must ensure that you have informed those individuals that you are providing their personal information to BBA, and that you have obtained their consent and advised them of our Privacy Policy.
Indirect collection of information:
Aside from the information you directly provide, we may also collect personal information about how our community (both email subscribers, and BBA users) interact with us, which we refer to as ‘metadata’. For example, we collect and store information about when you click certain buttons or how far you scroll on a page – something that is increasingly common with modern websites.
The collection of metadata is undertaken for two reasons:
1. To learn more about how our users interact with BBA, as part of our continued efforts to improve user experience.
2. To calculate interesting information about learners, such as the time taken to complete a particular question within an activity.
Links to external websites:
If you follow any links to third-party external websites from the Website, the Privacy Policy and the BBA usage terms and conditions will not apply to those websites which may have their own policies relating to privacy and data collection and website usage. If you choose to access any linked website or to provide any personal information on such websites, you should review their policies and terms of use to learn more about how they may use your personal information. We are not responsible for and will not be liable for the operations or policies of any third-party external website.
Unsolicited information:
In some circumstances, we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.
Use and disclosure of your personal information:
Your privacy is of utmost importance to us and we are extensive in our procedures to ensure that your data is kept safe and secure.
The personal information you provide us is yours. We don’t claim any ownership of it whatsoever. We do not use this personal information for any purpose other than to provide you with the BBA service, which may include the following:
1. to provide you with information, products or services you have requested;
2. to provide you with an account, including evaluating and processing your application for an account, assessing or approving an application for credit, or assessing your creditworthiness;
3. to manage your account or credit account (if applicable), including orders and payments, collecting overdue amounts, and managing fraud and risks;
4. to promote and market our products and services to you, including communicating with you via SMS or email newsletters;
5. to personalize and customize your experiences on the Website;
6. to help us research the needs of our customers;
7. to conduct research for the purposes of improving existing products or services or creating new products or services;
8. to provide you with ongoing information about us and our activities;
9. to allow us to provide third party information and offers in which we believe you may be interested;
10. to use aggregated or de-identified information for the purposes of data analysis, research and reporting;
11. to comply with regulatory or other legal requirements;
12. for purposes related to the recruitment and employment of our personnel and providing internal services to our staff; and
13. for any other use required or permitted by law or any other purpose communicated to you at the time that the personal information was collected or for which you provided your consent.
We may use your personal information for a secondary purpose if that secondary purpose is related to the purposes listed above, if we have your consent or if otherwise provided for under the Privacy Act. Generally, we will only collect and use your personal information in accordance with this Privacy Policy. In the event that we collect or use personal information in ways other than as stated in this Privacy Policy, we will ensure that we do so following the Privacy Act.
We do not use your personal information to build a profile on you to sell to others, or to target advertising to you now or in the future. If you choose to close your account with BBA we will no longer use your personal information. Except as otherwise may be required in this Privacy Policy, we will not access the personal information you have provided us unless you ask us to (usually in connection with a support enquiry) or if we have a reason to believe we need to do so to investigate or prevent a violation of our BBA usage terms and conditions.
Direct marketing:
BBA may use your personal information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your personal information from a third party. Direct marketing material may include promotional material about us or important updates about our services. We try and keep these to a minimum, while still providing you with the information you need or would probably want to know. We always give you the ability to unsubscribe from product update emails.
Service providers:
We may also disclose your personal information to a BBA host or service providers in certain limited circumstances, for example when BBA experiences a technical problem or to ensure that it operates effectively and securely. To the extent that we do share your personal information with a service provider, we would only do so if that party has agreed to comply with our privacy standards as described in this Privacy Policy.
We may also share non-personal, de-identified, and aggregated information for research or promotional purposes in connection with providing requested information or services to you, or to improve our services. We will not sell your personal information to third parties for marketing purposes.
Legal disclosure of your data:
We will not provide law enforcement authorities with access to your personal information unless required by law, is otherwise permitted by the Privacy Act, or is with your consent. We will always let you know if an authority does make such a request unless we’re legally prevented from doing so.
Security:
BBA employs industry best practices to secure your data and prevent access by unauthorised parties. For example:
• All network communication between BBA and your web browser is encrypted.
• Passwords are only stored in an encrypted form.
NDB scheme:
Part IIIC of the Privacy Act established the Notifiable Data Breaches Scheme (NDB scheme) in Australia. The NDB scheme sets out obligations for notifying affected individuals and the Commissioner about a data breach that is likely to result in serious harm.
Where serious harm to affected individuals is possible, we will notify those individuals and the Commissioner following our legal obligations. You may contact our Privacy Officer (details set out below) should you require additional information.
Deleting Personal Information from BBA:
We will keep your personal information only for as long as required for our business purposes and otherwise as required by Australian law. Where we no longer need to keep your personal information, we will take reasonable steps to destroy or de-identify your personal information.
You may request the deletion of your personal information from BBA upon account closure. Personal information will be destroyed or de-identified from our live systems as soon as practical though may persist for a reasonable time period in backups. Note that this personal information removal includes all personal information you have uploaded or provided to BBA that we’ve managed on your behalf, but not our account-keeping records on you, which we’ll keep for future reference.
Updating and correcting your personal information:
We will take reasonable steps to ensure that the personal information that we hold is accurate, up-to-date, and complete. You can update your personal information at any time by contacting us. We welcome any changes to your personal information to keep our records up to date.
Requesting your personal information:
You are entitled to access the personal information that we hold about you. If you request access to your personal information, we will grant your request unless providing you with access would unreasonably impact the privacy of others or is not otherwise permitted under the APPs or at law. If we refuse your request to access your personal information, we will provide you with written reasons for the refusal.
A request for access can be made to [email protected].
How you can contact us, find out more information or make a complaint:
If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this Privacy Policy, the APPs, a registered APP Code, and/or the Privacy Act in respect of your personal information, or for any other queries, problems, complaints or communication concerning this Privacy Policy, please address them to the Privacy Officer at g’[email protected].
We will be in contact with you as soon as practical to address your concerns.
You can find out more information about the Privacy Act and the APPs from the Office of the Australian Information Commissioner. The Information Commissioner may be contacted at www.oaic.gov.au or by email at [email protected]
Boyer Business Advisory Pty Ltd
ABN: 70 161 840 062