Social Traders Ltd (ABN 42 132 665 804) (Social Traders), referred to as ‘we’ ‘us’ and ‘our’, is committed to protecting the privacy of the personal information that we collect from you, hold and use. ‘Personal information’ is simply information that identifies you. We are bound by the Australian Privacy Principles, found in the Privacy Act 1988.

This policy applies to personal information that you provide to us directly, through our programs or events, through online channels and personal information that we receive from third parties. This policy does not apply to employee records. This policy does not apply to most of the information that we collect about corporate entities, as generally that information is not ‘personal information’.

Collecting your personal information

a) Personal information we collect

The type of personal information Social Traders collects and holds includes but is not limited to:

• contact details, including your name, address, phone, email, social media profile details;
• date of birth;
• credit card details;
• bank account details;
• Australian Business Number (ABN);
• dietary requirements;
• information contained on business cards;
• photographs, film, audio or other recordings.

b) Information collected from our websites

Social Traders collects and stores the following information about visitors to its website:

• Server IP address
• Domain name
• Date and time of visit
• Web pages accessed and documents downloaded
• Previous site visited
• Type of browser used
• Screen monitor resolution

This information is collected in an aggregated form and cannot directly identify individual visitors. We only use the information to measure the number of visitors to the different parts of the site and to help us make the site more useful to you. If we do not collect this information, we may be unable to tailor our website content to your preferences. You are able to browse our site without entering any personal information so you can remain completely anonymous during your visit.

c) How we collect personal information

We collect personal information about program applicants, program participants, mentors, job applicants, email subscribers, consultants, students, donors, individuals who attend events or functions, and individuals who make enquiries or otherwise come into contact with us.

We collect personal information through the following avenues:

• our websites;
• in person or phone enquiries and contact;
• written enquiries and correspondence;
• applications to participate in our programs;
• job applications;
• mentor intake procedures;
• student intake procedures;
• at networking events and at Social Traders events;
• from third parties, such as recruitment agents.

What will Social Traders Ltd use your personal information for?

Social Traders will only use or disclose personal information for the primary purpose for which it was collected, or a directly-related secondary purpose. In other words, we will only use your personal information in a way in which you would be likely to expect us to use it. Some of the main purposes for which we use personal information are:

a) Direct marketing

Social Traders may use your personal information for direct marketing, such as sending you our newsletter(s) or other relevant social enterprise development information. We may also invite you to Social Traders events and functions. Our direct marketing will always contain an ‘unsubscribe’ mechanism, and we will no longer use your personal information for direct marketing if you ‘unsubscribe’. If we receive your personal information from a third party, we will only use it for direct marketing purposes if you have consented, and have not unsubscribed.

b) Photographs and media

We sometimes use photographs taken at our events, which may include photographs of attendees, in our promotional and marketing materials. Otherwise, we will only use photographs, film, audio or other recordings of you if you have provided your consent, and in accordance with other Social Traders documents, in particular our ‘Content Release Form’.

c) Program applications and participation in Social Traders programs

Social Traders will collect personal information from applicants for its programs in order to assess and, if successful, do all things required to facilitate the successful applicant’s engagement in that particular program.

Social Traders may also use the personal information of program applicants and participants in our promotional and marketing materials, in accordance with the agreements in place for those programs.

d) Payments, donations and invoicing

We use your personal information to process payments and donations that you want to make to Social Traders, or to prepare invoices if applicable.

e) Contacting you

Where we need to contact you, for example, to answer an enquiry you have raised, we will use your personal information to respond by mail, fax, email, phone or in person.

f) Job applications and engaging third parties

Social Traders collects personal information from job applicants, or indirectly through recruitment agencies, in order to assess, and if successful, employ or otherwise engage the applicant. We also collect personal information from consultants, mentors and students to enable us to engage them in various capacities, such as speaking engagements, mentoring programs, and running events.

Sharing your personal information

Social Traders may, in accordance with the above specific purposes only, disclose your personal information to:

• Our employees;
• Our consultants, auditors, professional advisers, agents or subcontractors, mentors or students; and
• Anyone you authorise us to disclose it to.

It is not likely that we will share your personal information with overseas recipients, and we will not do so without obtaining your consent.

• Social Traders may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Social Traders or third parties.
• If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

We may make a business decision to store our data with a trusted service provider who is in the business of providing data storage and processing services. Information that we collect may from time to time be stored, processed in or transferred between these service providers located in countries outside of Australia, including but not limited to the United States of America.

Other than the above, we will not disclose your personal information without your consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.

Cookies

Our website uses cookies in order to provide a better user experience. Cookies are a small text file our website stores on your computer, and are used to determine whether your computer uses Javascript (a software language used in websites), and a session cookie, to determine whether you are a registered, logged-in user.

Off-site links

Our website contains links to other websites. Social Traders is not responsible for the privacy policies, practices or content of any site that may be linked to or from our website. We recommend that you review the privacy policies of each site you visit.

Storing your personal information

Social Traders stores your personal information on our electronic databases. We implement a variety of security measures to maintain the safety of your personal information.

On our website, we offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorised with special access rights to such systems, and with a requirement to keep the information confidential.

Your personal information that is no longer required by us or by law will be destroyed or de-identified.

Right to request access and correction

You have the right to request access to the personal information we hold, and seek to have it corrected and updated. Such requests can be made by contacting Social Traders directly on the contact details below. No fee will be charged for complying with these requests, but we may charge you for any reasonable photocopying fees incurred. If you want us to delete your personal information, please contact us and we will take all reasonable steps to delete it, unless we are prevented from doing so by law.

Right to deal with us anonymously or via pseudonym

You may interact with us anonymously or via pseudonym, however, if you do so, or you choose not to provide us with personal information that we reasonably require, we may not be able to:

• adequately deal with your enquiry or fulfil your request; or
• process your application to participate in a Social Traders program, or your job application.

How to complain

If you believe Social Traders has breached the Australian Privacy Principles or a binding registered Australian Privacy Principles code, you may complain by using the following procedure:

1. Contact Social Traders on the below contact details and provide us with the details of your complaint;
2. We will:
   • record your complaint in writing and ask for further information if required;
   • We will assess your complaint and contact you within 28 days of the date of the complaint to discuss options to resolve it;
   • Work with you to implement any agreed action to resolve the complaint;
   • Contact you to follow up about resolution of the complaint;

• If the above process does not deal satisfactorily with your concerns, you can refer your complaint to the Office of the Australian Information Commissioner via:

Email: enquiries@oaic.gov.au

Tel: 1300 363 992

Fax: (02) 9284 9666

Changes to Privacy Policy

Please be aware that Social Traders may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website. Please check back from time to time to review our Privacy Policy.

Our contact details

Privacy Officer

Social Traders Ltd (ABN 42 132 665 804)

Address: Level 27,150 Lonsdale Street, Melbourne VIC 3000

Postal address: PO Box 18147, Collins Street East VIC 8003

Tel: (03) 8319 8444

Email: info@socialtraders.com.au

Dated: 23 March 2018, version 2.0