APP 1.4, which sets out the topics an APP privacy policy must cover.
APP 1.5, which requires an APP entity to take reasonable steps to make the privacy policy available free of charge and in an appropriate format.
APP 1.6, which requires an APP entity to take reasonable steps to give its privacy policy to an individual in the form the individual asks for.
Privacy Policy
INTRODUCTION AND GENERAL TERMS
This Privacy Policy covers the processing of personal data by CASUAL CONNECT PTY LTD, trading as CC Coach ("CC Coach""," " We", "us", or "our" in this policy), when providing its services to clients. If you have any questions or comments about this Privacy Policy, please contact us at:
Address:
Casual Connect Pty Ltd Collective Financial Partners
3 Woodford Place, Thornton. New South Wales Email:
CC Coach is committed to protecting and respecting your privacy.
The personal information that CC Coach collect and hold.
This Privacy Policy explains the following:
What personal data we may collect about you.
Why our processing is lawful.
Who we may share your information with.
How we will use that information.
Who we may disclose that information to; and
Your rights regarding the information.
WHAT INFORMATION WILL CC COACH COLLECT ABOUT ME?
We collect and process the following data, which may include your personal data.
CC Coach's Website: If you contact us about our services or request a demo on our website, the forms you complete or the emails you send may include information about you, such as your full name, email address, the organisation on behalf of whom you are contacting us, and your inquiry.
CC Coach's Online Client Platform: To provide an CC Coach Client with access to our platform and enable them to access our services, we collect the full name, email address, and password of each individual authorized by such client to access the platform.
Analytics on the Website and the Platform: Our website and online client platform use cookies and other mechanisms to collect and log analytical information, help analyse usage, compile statistical reports on the use of our website, and improve both our website and marketing efforts.
The following data may be collected:
number of visitors to our website.
pages visited and time spent per page.
page interaction information, such as scrolling, clicks and browsing methods.
Websites tracking the origins of visitors and their subsequent destinations.
page response times and any download errors; and
other technical information relating to end user device, such as IP address or browser plug- in.
CC Coach Database: CC Coach gathers current and historic business contact data. The data collected about individuals on the CC Coach Database comprises:
Name
Company Details
Location
Telephone Number
Email Address
Page response times and any download errors; and
To facilitate specific aspects of its services, CC Coach requires an email address to be recorded for profiles in our database.
Information is also acquired through correspondence with you (via email or phone), from our clients, our affiliate's services, recruiters, and other premium data providers.
When our clients utilize our service to send marketing emails, they may include cookies (or similar technologies) in the emails. This enables them to determine whether an email bounced back and was not delivered, whether an email was opened and whether links in the email were followed.
GROUNDS OF PROCESSING
Consent: On some occasions, CC Coach processes your data with your consent, which may be obtained by third parties on CC Coach's behalf. You have the right to withdraw such consent at any time, and we will cease processing the data after consent is withdrawn.
Legitimate interest: CC Coach process your personal data when it is in our or our clients' legitimate interest to do so, and when these interests are not overridden by your rights. Our and our clients'
legitimate interests include: organising information about potential business customers in a searchable database, accessing up-to-date and complete information, identifying individuals in specific roles within B2B leads, identifying individuals with a certain estimated net worth, enabling clients to reach out only to relevant contacts, generate and contact potential B2B leads for B2B marketing, and having access to aggregated statistical insights for understanding patterns and trends.
Legal obligation: CC Coach may process your data to comply with our legal and regulatory obligations, such as preventing, investigating, and detecting crime, fraud, or anti-social behaviour, and prosecuting offenders, including working with law enforcement agencies.
Contractual obligation: CC Coach may process your data when there is a contractual relationship with the individual, and it is necessary to process their personal data to comply with our obligations under the contract.
DATA SHARING
We will share your information with the following:
Our companies: Access to personal data within the CC Coach and our group of companies is restricted to individuals who have a legitimate need to access the information for our business purposes.
Please note that in providing data to its clients, CC Coach is processing such data as a processor on behalf of the client, who is acting as the controller. Clients are likely to have their own privacy policies and opt-out options, and we recommend that you review them. Where CC Coach has made personal data available to its clients, the client's privacy policy should include CC Coach as a data source.
Suppliers, subcontractors, and service providers: We maintain your information confidentially but may disclose it to suppliers or subcontractors as far as reasonably necessary for the purposes outlined in this privacy policy. However, such disclosure is contingent on their agreement to safeguard this information.
This includes external third-party service providers, such as accountants, auditors, experts, lawyers, and other professional advisors external to our organization. It also includes IT systems, support, and hosting service providers, technical engineers, data storage and cloud providers, and similar third-party vendors and outsourced service providers that assist us in conducting our business activities.
Data management platform: A Data Management Platform (DMP) is a technology platform utilized for collecting and managing data, primarily for digital marketing purposes. CC Coach provides DMPs with data, enabling the DMP to create audience segments, which are used by advertisers to target specific types of users in online advertising campaigns.
Government authorities: Additionally, we may disclose your information to the extent required by law, including to government bodies and law enforcement agencies. This disclosure may also occur in connection with any legal proceedings or prospective legal proceedings, as well as to establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention.
Potential acquirers or investors: If we are engaged in a merger, acquisition, or sale of all or part of our assets, you will be informed via email, account message, and/or a prominent notice on our website of any change in ownership or the uses of this information. Additionally, you will be provided with any choices you may have regarding this information.
HOW WE WILL USE INFORMATION WE COLLECT ABOUT YOU
CC Coach Website and CC Coach Client Platform:
We may process your personal data for the following purposes for CC Coach's own:
to administer platform logins (where applicable) and deliver our services to our clients or their customers under the agreed terms of service.
to process your enquiries to reply and provide support, including providing you and/or your organisation with information about the services CC Coach offers.
to keep you updated via our mailing list with information on news, offers, and updates about CC Coach (see below for how to unsubscribe);
to compile reports on how visitors use the CC Coach website and improve the website.
to conduct remarketing for CC Coach, which allows us to show CC Coach ads to people who've previously visited our website.
to conduct advertising on social networks for CC Coach, meaning that if you link to one of our social media platforms you may be subject to targeted marketing displaying CC Coach ads via that site.
If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies.
CC Coach Database:
We may use your personal data on the CC Coach Database for the following purposes:
to build our sales intelligence database to empower our clients or their customers to generate and manage sales leads for businesses and high net worth individuals.
to enable our clients or their customers to deliver relevant display ads on social networks (such as Facebook, LinkedIn, and Instagram) and other services.
to empower our clients or their customers to enrich their existing customer relationship management records and receive timely updates of changes.
to undertake research and compile statistical aggregated reports based on data held in CC Coach's sales intelligence database.
to supply data management platforms.
to run our own marketing campaigns and promote our services.
Additionally, we process personal data to comply with necessary legal and regulatory obligations. These obligations include preventing, investigating, and detecting crime, fraud, or anti-social behaviour, as well as prosecuting offenders, which may include working with law enforcement agencies.
All content, if you send us objectionable content or behave disruptively on our website, we may process personal data included in your messages to respond to and stop such behaviour. In cases where we reasonably believe you are or may be in breach of the law (e.g., if the content you send amounts to harassment or is defamatory), we may use your personal data to inform relevant third parties, such as your email/internet provider or law enforcement agencies, about the content.
MARKETING OPT-OUT OPTIONS
If you do not wish for your personal data to be used in the CC Coach Database for the specified purposes, please fill in your details here or contact us using the provided contact details.
If you receive a marketing email from us and wish to be removed from our mailing list, please inform us by clicking the "unsubscribe" link located at the bottom of any marketing email you receive from us.
CC COACH Additional Limits on the Use of Your Google User Data:
Notwithstanding any other provisions in this Privacy Policy, if you grant the App access to the following types of your Google data, the App's use of that data will be subject to the following additional restrictions:
App's use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy, including the Limited Use requirements, which is available at the following link:https://developers.google.com/terms/api-services- user-data-policy additional_requirements_for_specific_api_scopes. It's important to note that these are policies are governed by Google, and CC Coach does not have any control or interference in this regard. We recommend you visit Google´s policies directly for further details on their procedures and future updates.
The CC COACH will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing it is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
The CC COACH will not use this Gmail data for serving advertisements.
The CC COACH will not permit humans to read this data unless we have your affirmative agreement for specific messages. Reading is only done when necessary for security purposes, such as investigating abuse, complying with applicable law, or for the App's internal operations. Even in these cases, access is granted only when the data has been aggregated and anonymized.
YOUR RIGHTS WITH PERSONAL DATA THAT WE PROCESS RELATING TO YOU
You have the following rights regarding the way we process personal data about you. We aim to comply without undue delay and within one month at the latest.
To make a request, please contact us using the following contact details privacy@cccoach.au, attention to the Data Protection Officer.
You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts as required by law to supply, correct, or delete personal data held about you on our files (and with any third parties to whom it has been disclosed).
you consented to CC Coach processing the personal data and have withdrawn that consent.
CC Coach no longer needs to process that personal data for the reason it was collected.
CC Coach is processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of CC Coach, you don't agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
the personal data was unlawfully processed; or
you need the personal data to be deleted in order to comply with a legal obligation.
Obtain a machine-readable copy of your personal data, which you can use with another service provider.
If we are processing data to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
If you request, CC Coach will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
If you are unhappy with the way CC Coach is processing your personal data, please let us know.
If you do not agree with the way we have processed your data or responded to your concerns, or if you do not think we are handling your personal data adequately, you have the right to lodge a complaint with the Office of the Australian Information Commissioner. Further information, including contact details, is available at https://www.oaic.gov.au/
DATA RETENTION
We will hold your personal data for as long as is necessary for the relevant purpose.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
CHILDREN
We do not knowingly solicit data from or market to children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@cccoach.au We will delete such information from our files within a reasonable time.
SECURITY
CC Coach is committed to ensuring the safety and security of your personal data, guarding against unauthorized access, alterations, disclosure, or destruction of the information we hold. We will take all reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal data.
Our security measures include:
hashing and encryption of our services and data.
regular review of information collection practices.
encryption of our services and data.
restricted access of data to employees, contractors, and agents; and
internal policies outlining our data security.
It's important to note that, despite our efforts to provide reasonable security for the information we process and maintain, no security system can entirely eliminate the possibility of potential security breaches.
CHANGES
We will notify you of any changes to this Privacy Policy by email and/or notice on the website, as appropriate.
INTERNATIONAL DATA TRANSFERS
Your personal data, which you provide to us, is primarily stored and maintained within the Asia Pacific Region.
You have the right to:
request access to your personal information and request that CC Coach disclose what personal information we collect, uses, discloses, and sells;
request deletion of your personal information collected or maintained by us;