1. Introduction

    1. Social Skills Training Pty Ltd ACN 600 644 326 and its related entities (SST, we, us or our) are committed to upholding and protecting personal information of all trainers, providers, participants in its training courses, clients and customers.
    2. SST is required to comply with the Privacy Act 1988 (Cth) including the Australian Privacy Principles (APPs).
    3. This Privacy Policy outlines the processes and procedures relating to how SST handles your personal information.
    4. This Privacy Policy is intended to provide a general overview of our policies for the approach to handling of your personal information. Other policies may apply instead of or in addition to this Privacy Policy in certain circumstances, such as a Privacy Collection Statement that you are provided with by SST in connection with your dealings with us.
    5. "Personal information" is information or an opinion about you as an identified (or reasonably identifiable) individual and includes "sensitive information" which is personal information relating to an individual's racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, health information and biometric information.
    6. By using our website (sst-institute.net), using our products or services, and/or providing your personal information to us you consent to us handling your personal information in accordance with this Privacy Policy.
  2. Collection of Personal Information

    1. The nature of personal information collected by SST depends on our dealings with you. Generally this personal information comprises of name, address, age, professional qualifications, name of employer, address of employer, position in the employer’s organisation, contact details (phone numbers, fax numbers, email address), credit card or payment details and details about the products or services you have enquired about.
    2. We may also collect additional personal information from you, for example:
      1. where you participate in one of our games we may collect additional personal information from you including your progress in the game and health information about the individual participants such as their learning capacities and medical history;
      2. where you access one of our training courses or games for use by your own students or clients, we may also collect additional details about you and your students, such as your professional qualifications, name of employer, address of employer, position in the employer’s organisation and details of your students;
      3. if you use any of our online platforms, then we may collect information about how you use those platforms (including your location, pages visited, MAC addresses, IP addresses, operating system and browser being used);
      4. if you are applying for a position with SST, then we may collect personal information about you related to our recruitment processes (for example your qualifications, skills, work history, residency status and health information as applicable);
      5. if you or an entity you are associated with are providing services to SST, we may collect a range of personal information for the purpose of assessing the potential engagement, carrying out induction and work, health and safety processes; and
      6. information to comply with our obligations permitted or as otherwise required by law.
  3. How we collect personal information

    1. We generally collect your personal information directly from you unless it is impracticable or unreasonable to do so. For example, this may include in forms that you provide to us, your use of our online platforms including information and analysis relating to your use of our games, and other forms of communication between SST and you such as email, over the phone and in person.
    2. We may, in some circumstances, collect personal information about you from third parties or other sources (for example, from public records, law enforcement agencies, government agencies, our contractors or advisers, your agents or if you are a prospective employee your referees).
    3. Generally, if we are unable to collect the personal information we require then we may not be able to provide you with the products and services you seek. If the information provided is incorrect or incomplete, this may also prevent, limit or otherwise affect our ability to provide products or services to you.
  4. Provision of personal information about third parties and children

    1. If you provide us with personal information about a third party, you represent and we collect the personal information on the basis that you have that person's consent for us to collect and handle their personal information in accordance with this Privacy Policy.
    2. If the third party is under the age of 18 years of age then you also represent and we collect the personal information on the basis that you have the consent of their parent or legal guardian to provide us with that personal information and for us to use that personal information in accordance with this Privacy Policy.
    3. This means that if you are a teacher or clinician providing the SAS (or related product) to a child you warrant you have the consent of that child's parent or legal guardian to provide us with the relevant personal information. If you are the parent or legal guardian of a child, you warrant that you consent to the collection of the relevant personal information.
  5. Purposes for which personal information is collected, held used and disclosed

    1. The personal information we collect is used for the purposes for which we collected it, and for other related purposes that you would reasonably expect. Generally, these include to enable us to inform you, as one of our customers, of new developments in the Secret Society Program (SAS), the availability of new training and resources (such as books, DVDs and any other SAS related products) and provide you with other marketing and promotional material, to facilitate the shipment of resources, and, in the case of participants in our SAS Training Courses to track progress through the courses and for market research, product development and other research purposes. We may also use and disclose your personal information with your consent and as otherwise required or permitted by law.
    2. At any time you are able to request that we discontinue sending you marketing and promotional information by contacting the Privacy Officer via the details below.
    3. Generally, we also collect and use your personal information to respond to your enquiries, obtain your feedback on your customer experience and for our general business operations. Our general business operations include a range of activities, such as maintenance of our business records, compliance with our legal and insurance obligations, statistical analysis and planning purposes, managing and defending claims involving SST and undertaking targeted online advertising.
    4. Additionally, if you were to participate in sessions conducted by our clinicians you may also disclose sensitive information to us. Should you do so, this will be used to help other clinicians' better serve your individual needs.
    5. By providing us with your personal information, you consent to us using your personal information for these purposes.
    6. We may exchange your personal information within the SST corporate group. We may disclose your personal information to our agents, contractors, service providers and research partners for the purposes set out above, and for the purposes of those parties providing services to us or performing business services or functions on our behalf (for example, our technology service providers, marketing service providers, mail distributors, conference and event organisers).
    7. We may also, in the event of a sale, transfer or assignment of the whole or part of SST's business and/or assets and facilities to a third party, disclose your personal information to that third party for their use in operating the business or assets to be transferred.
  6. Sensitive information

    1. We will only collect ‘sensitive information’ with your consent or where otherwise permitted or required by law. For example, we may collect sensitive information (such as medical diagnosis) about individuals who use our online platforms where that information is provided to us as part of the registration process and as provided to us or derived by us through use of our games.
    2. We will assume that you have consented to us collecting all information which is provided to us by you for use in accordance with this policy, including any ‘sensitive information’, unless we are told otherwise at the time it is provided to us.
    3. We will only use and/or disclose 'sensitive information' for the purpose for which we collected it, for any directly related purpose that you would reasonably expect, for other purposes with your consent or as otherwise permitted or required by law.
  7. Security of your Personal Information

    1. SST is committed to providing secure storage of your personal information. Generally, we will take reasonable steps to protect your information from unauthorised access, modification and disclosure, and from misuse, interference and other types of loss. We generally take reasonable steps to destroy or permanently de-identify your personal information when we no longer require it for any purpose for which it can be used or disclosed.
    2. We may retain your personal information for as long as necessary to comply with any applicable law, for insurance and corporate governance purposes, for the prevention of fraud and to resolve disputes. Your personal information may also be retained in our IT system back-up records.
    3. The transfer of data over the internet is inherently insecure. We cannot guarantee the security, during transmission, of any personal information provided to us via our website. Please bear this in mind when transmitting important information by this means to us.
  8. Website and cookies

    1. Our website uses cookies. We do not use the information stored in those cookies to collect information about you or your computer. For statistical purposes, we may collect and analyse traffic on our website. This is done solely by tracking web site activity from our web server and in no way can customers be identified. We may also collect click-stream data when you use the website, such as the date and time of your visit, the pages you accessed, your IP address, the type of browser and operating system you are using and the websites you come from and move to. This information is collected for statistical purposes to assist us to find out how our website is used and navigated and to improve our website.  We also carry out planning and marketing activities using the personal information you provide which may include targeted online advertising, data and audience matching, analytics, research.
    2. Our website may contain links to third party websites or advertisements. We are not responsible for how your personal information is collected and used or handled once you leave our website. This Privacy Policy does not apply to any third party websites. You should review the privacy policy and terms of use for those websites each time you visit them.
  9. Overseas disclosure of your personal information

    1. Where you access and use the SAS Program or any other of our products and services from a location outside of Australia, and your registration or use involves others (such as your teacher, practitioner or student) then we may disclose your personal information to you and those persons overseas in connection with your use of the SAS Program. Otherwise generally, we do not disclose your personal information to overseas recipients except as permitted or otherwise required by law.
  10. The Quality of Personal Information

    1. We aim to ensure that your personal information is accurate, compete and up to date.
    2. If you believe that we don’t have accurate, complete or up to date information about you, please contact us via the details below and we will use reasonable steps to correct the information except where we refuse such a request as permitted by law.
  11. Access to Personal Information

    1. You can request access to your personal information. A written request is needed for us to process your application and must be directed to our Privacy Officer via the details below. We will endeavour to respond to your request within a reasonable time which will generally be within 30 days.
    2. In some circumstances, we may be unable to provide you access such as where the information would cause an unreasonable impact on another's privacy or as otherwise permitted by law.
    3. Please note no fee will be incurred for requesting access and if your request for access is accepted, we will inform you of the fee (if any) that will be payable for providing access if you proceed with your request.
  12.  Complaints

    1. You may lodge a complaint with us in relation to our handling of your personal information. To do so, please contact our Privacy Officer via the contact details below. We will confirm receipt of your complaint and set out the time frame we require to investigate your complaint and provide you with a response. We will endeavour to respond as quickly as possible, which generally will be within 14 days of receiving your complaint.
  13. Changes to this Statement

    1. SST may from time to time, make changes to this Privacy Policy. We will publish those changes on our website sst-institute.net. You should review our Privacy Policy each time you visit our website, use our services or provide us with personal information.
    2. Further information regarding the Privacy Act 1988 (Cth) or your privacy rights can be obtained from the Office of the Australian Information Commissioner’s website at http://www.oaic.gov.au/
  14. Our Contact Details

    Attention: The Privacy Officer

    The Social Skills Training Institute

    Level 3 Foxtail Building, Long Pocket Campus
    The University of Queensland
    80 Meiers Road, Indooroopilly
    Brisbane, QLD 4072
    Australia

    Or

    PO Box 6068
    St Lucia, Brisbane
    Queensland 4067
    Australia

    Phone: +61 (0) 7 3720 8740

    Email: privacy@sst-institute.net