Privacy Policy
About this privacy policy
This Privacy Policy (Policy) is the statement of Easton Coaching Pty Ltd (Easton Coaching or we, our or us).
This Policy outlines how we manage your personal information.
Easton Coaching is committed to protecting your privacy through compliance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), to the extent applicable to us.
This Policy uses the definition of personal information provided for in the Privacy Act.
Please read this Policy carefully and contact us if you have questions.
What personal information do we collect?
Personal information. The type of personal information we collect will depend on the circumstances of its collection and the nature of your dealings with us. This information may include your name, contact details, date of birth, age, marital status, job title, information about your employment, bank account details, and other information relevant to providing you with coaching services and your preferences and opinions about our services. This is not an exhaustive list.
Sensitive information. Sensitive information includes information about an individual’s mental health, disability, racial or ethnic origin, criminal record, and religious and political affiliations. We will only collect, use or disclose your sensitive information if it is reasonably necessary to carry out our functions or activities and we have your consent.
How do we collect your personal information?
We generally collect your personal information directly from you. For example, when you inquire about or engage us to provide you with coaching services, complete our coaching intake and feedback forms, visit our website, or use or access our online materials. This collection may take place over the phone, by electronic communication, in person or via our website.
We may also collect your personal information from third parties. For example, from organisations for whom you work or have worked (where, as part of the coaching services, you request us to speak with sponsors, managers or other stakeholders that you work with); from referrals who may have introduced you to Easton Coaching; or from our service providers or credit reporting bodies.
How do we hold and protect your personal information?
We hold your personal information in both hard copy and encrypted electronic forms, in secure databases that we own and operate or that are owned and operated by our service providers.
We take reasonable steps to keep secure and protect any personal information which we hold about you, including by:
securing our physical premises and digital storage media;
placing password protection and access control over our information technology systems and databases to limit access and protect electronic information from unauthorised interference, access, modification and disclosure; and
taking regular back-ups of our electronic systems.
While we take reasonable steps to protect the security of your personal information, data protection and security measures can never be guaranteed. We therefore cannot guarantee the security of your personal information.
We destroy personal information when we no longer need it, unless we are otherwise required or authorised by law to retain it.
Why do we collect your personal information?
We collect your personal information primarily to interact with you and provide you with our services. We only collect personal information if it is reasonably necessary for us to carry out our functions and activities.
The ways in which we use your personal information include:
to provide you with coaching services;
to provide you with information about our coaching services and respond to your queries;
to invite you to workshops and events;
to meet professional certification requirements in the field of coaching and for our continued accreditation with International Coaching Federation (ICF);
to fulfill our legal and ethical obligations under the ICF Code of Ethics;
to perform accounting, billing and other administrative and operational functions, including to create backups of business records;
to improve and/or develop our business;
to secure and protect our website or our legal rights; and
for any other purpose for which you give your consent.
We do not sell or trade your personal information to third parties.
To whom we disclose your personal information?
Subject to our professional and ethical obligations, we may disclose your personal information to:
our employees, officers and agents;
coaching certification and accreditation organisations;
our professional advisers such as legal advisers and auditors;
our business partners;
governmental or regulatory authorities, and enforcement agencies;
third parties and contractors who provide services to us, including support services, debt-recovery functions, information technology service providers, marketing services;
protect the interests or welfare of our clients or third parties; and
enforce this Policy or any of our terms and conditions with you.
We may also disclose your personal information if we are required, authorised or permitted by law to do so.
Do we disclose your personal information overseas?
We use third party computer servers including our email and website hosts, which may be located overseas and your personal information may be stored and transmitted overseas as part of the normal operation of our business.
By providing us with your personal information, you consent to us disclosing your personal information to third parties located overseas and acknowledge APP 8.1 does not apply to any such disclosure.
You acknowledge that:
we are not responsible for the privacy practices of third parties located overseas; and
we do not have to ensure third parties located overseas handle your personal information in compliance with the Privacy Act and the APPs.
What about direct marketing?
You acknowledge that by providing us with your personal information, we may communicate with you by email, SMS or push notification, to promote our services or to inform you about matters that may be of interest to you including workshops, informational content or features on our website.
You can opt-out from being contacted by us for direct marketing by emailing “unsubscribe” to support@eastoncoaching.com.au
What happens if you don’t provide us with your personal information?
You can choose not to provide us with your personal information. If you choose not to provide us with certain types of personal information, we may not be able to provide our services to you or otherwise interact with you.
How do you access and correct your personal information or make a complaint?
Contacting us
If you have any queries about this Policy, wish to access or correct the personal information we hold about you, or make a complaint, please contact us in writing at:
Contact Name: The Privacy Officer
Email: bob@eastoncoaching.com.au
In certain circumstances, we may be unable to give you access to your personal information. If this is the case, we will write to you to explain why we cannot comply with your request, unless it is unreasonable to do so.
While we will try to give you access to your personal information free of charge, we may (depending on the request) charge you a fee. We will inform you of any fees payable in respect of accessing your personal information prior to actioning your request.
All requests for personal information will be handled in a reasonable period of time (no more than 30 calendar days after the request is received).
Correcting your personal information
We try to ensure any personal information we hold about you is accurate, up-to-date, complete and relevant.
If you believe the personal information we hold about you is inaccurate, out-of-date, incomplete or not relevant, please contact us using the details provided above.
Making a complaint
If you believe your privacy has been breached or you have a complaint about our data privacy practices, please contact us using the details provided above.
We take privacy complaints seriously. If you make a complaint, we will try to resolve your complaint within 10 calendar days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint.
We will investigate your complaint and, where necessary, consult with third parties. We will decide about how to address your complaint and write to you to explain our decision.
You can also complain directly to the Office of the Australian Privacy Commissioner. Details about how to make a complaint can be found at www.oaic.gov.au or by calling 1300 363 992.
Cookies
When you visit our website, we may use cookies and other tracking technology (Cookies) to recognise you and customise your online experience. Cookies are small files that store information on your computer, mobile phone or other device. They enable us to recognise you across different websites, services, devices and/or browsing sessions. Cookies also assist us to customise online content, save your preferences for future visits to the website, prevent potential fraud and analyse your and other users’ interactions with the website.
If you do not wish to grant us the right to use cookies to gather information about you while you are using our website, then you may set your browser settings to delete, disable or block certain Cookies.
You may be requested to consent to use of Cookies when you access certain parts of our website, for example, when you are asked if you want the website to “remember” certain things about you.
Third party links
Our website may contain links to websites operated by third parties. Those links are provided for your convenience only and may not remain current or be maintained. We are not responsible for the privacy practices of, or content on, those linked websites. You should read the privacy statements of the operators of those third party websites before using their websites.
Changes to this policy
We may amend this Policy from time to time, including to take into account and cater for business developments or legal or regulatory developments.
If we make changes, we will notify you by revising the date at the top of the Policy and publishing the updated version on www.eastoncoaching.com.au/privacy
We recommend that you regularly review the Policy to see if there have been any recent changes and to stay informed about our data privacy practices.