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PRIVACY POLICY.

Confit Pathways Limited values and respects the privacy of the people we deal with. Confit Pathways Limited is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and other applicable privacy laws and regulations.

 

This Privacy Policy (Policy) describes how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of your personal information. It also sets out how you can make enquiries as to the information we hold on you and how to register complaints regarding the handling of your personal information.

What is personal information?

“Personal information” is a term defined in the Privacy Act, it means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.

 

In this Policy, we also refer to "sensitive information", another kind of information defined in the Privacy Act and which generally attracts additional privacy protections given its sensitive nature. This might include any information or opinion about your racial or ethnic origin, political opinions, political association, religious or philosophical beliefs, membership of a trade union or other professional body, sexual preferences, criminal record, or health information. In this Policy, references to personal information refer to both personal and sensitive information, unless context dictates otherwise.

What personal information do we collect?

The personal information we collect about you depends on the nature of your dealings with us or what you choose to share with us. 

The personal information we collect about you may include:

  • name;

  • mailing or street address;

  • date of birth;

  • gender;

  • email address; 

  • phone number; and

  • the name of your emergency contact and their details.

 

Under certain circumstances, Confit Pathways Limited may also need to collect sensitive information about you.  The sensitive information we collect about you may include:

  • Information about your interactions with the justice system; and

  • any known medical conditions.
     

If we collect your sensitive information, we will do so only with your consent, or otherwise if it is necessary to prevent a serious and imminent threat to life or health, or as otherwise required or authorised by law, and we take appropriate measures to protect the security of this information including by limiting employee access to such information as far as possible.      

You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our services or otherwise interact with you.

How do we collect your personal information?

We collect your personal information directly from you when you: 

  • interact with us over the phone;

  • interact with us in person;

  • interact with us online;

  • participate in surveys or questionnaires;

  • participate in one of our programs;

  • attend a Confit Pathways Limited event;

  • subscribe to our mailing list; and/ or

  • apply for a position with us as an employee, contractor or volunteer.

Collecting personal information from third parties

We may also collect your personal information from third parties or through publicly available sources, for example from a parent, school representative or corrections officer when they are completing our referral form.  We collect your personal information from these third parties so that you may be referred for enrolment in one of our programs. When we collect your personal information from a third party, we will seek confirmation that they have obtained your consent to provide it to us. We will also provide a privacy collection notice in relation to any personal information we have collected through a third party, for example via a referral form.     

How do we use your personal information?

We use personal information for many purposes in connection with our functions and activities, including the following purposes:

  • provide you with information or services that you request from us;

  • deliver to you a more personalised experience and service offering, for example amending training schedules for program participants in light of relevant medical information;

  • improve the quality of the services we offer;

  • internal administrative purposes;

  • marketing and research purposes.

Disclosure of personal information to third parties

We may disclose your personal information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:

  • our third party service providers (for example, our IT providers);

  • our marketing providers; or

  • our professional services advisors;

Transfer of personal information overseas

Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia, including in the United States or Europe. 

Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if: 

  • you have given us your consent to disclose personal information to that third party; or 

  • we reasonably believe that:

    • the overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the APPs; and

    • the law or binding scheme can be enforced; or

  • the disclosure is required or authorised by an Australian law or court / tribunal order.

 

Confit Pathways Limited uses various Google services, including Google Docs, Google Drive, and other Google Workspace tools, to store and process personal information. Google’s infrastructure is globally distributed, and personal data may be transferred to other jurisdictions and stored on servers located in Australia as well as in other regions, including but not limited to the United States, Europe, and Asia. Google has data centres in multiple locations worldwide, including Sydney, Australia, where personal information may be processed. The specific location of the servers used to store personal information will depend on the specific service and configuration settings chosen by Confit Pathways Limited.   

   

Google complies with applicable data protection laws and offers a range of privacy and security features designed to protect the personal data stored and processed on its platforms, including encryption and data access controls. For more information on how Google handles personal data, please refer to Google's Privacy Policy and Data Processing Agreement. 

Disclosure of personal information to third parties

We may disclose your personal information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:

  • our third party service providers (for example, our IT providers);

  • our marketing providers; or

  • our professional services advisors;

How do we protect your personal information?

Confit Pathways Limited will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:

  • having a robust physical security of our databases / records;

  • taking measures to restrict access to only personnel who need that personal information to effectively provide services to you; and 

  • having technological measures in place (for example, anti-virus software, fire walls).

Online activity

Cookies

 

The Confit Pathways Limited website uses cookies. A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our website(s) before, so we can distinguish you from other users of the website. This improves your experience and the Confit Pathways Limited website(s).

We do not use cookies to identify you, just to improve your experience on our website(s). If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected.

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Direct marketing

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We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. 

You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe'' set out in the relevant communication or by contacting us using the details set out in the “How to contact us” section below.

In addition, where you opt in to receive marketing materials, we may also use your personal information or disclose your personal information to third parties for the purposes of advertising, including targeted advertising based on your online behaviour, website personalisation, and to provide targeted or retargeted advertising content to you (including through third party websites). We will not use or disclose sensitive information for this purpose.  

Retention of personal information

We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information at most for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations. We will endeavour to only keep your personal information for as long as necessary for the purpose for which it was originally collected.

How to access and correct your personal information

We are committed to ensuring that your personal information is accurate, complete, and up to date. Under the Privacy Act, you have the right to request access to the personal information we hold about you and to request corrections if the information is inaccurate, incomplete, or outdated.

 

How to Make a Request
To request access to or correction of your personal information, please submit a request in writing to info@confitpathways.org. You will need to provide sufficient details for us to identify you and the information you are requesting.

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Response Time
We will respond to your request within 30 days of receiving it. If we need more time to process your request due to its complexity, we will notify you within the initial 30-day period and explain the reason for the delay, including the extended timeframe for our response.

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Accessing Your Information
Once your request has been processed, we will provide you with a copy of the personal information we hold about you, unless there is a valid reason under the Privacy Act for us to refuse access (such as when the request is frivolous or vexatious, or when it would impact other individuals' privacy or legal rights).

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Correcting Your Information
If you believe that the personal information we hold about you is incorrect, incomplete, or outdated, please inform us by submitting a request for correction. We will take reasonable steps to update or correct your information and will inform you once the correction has been made. If we refuse to correct the information, we will provide you with the reasons for our refusal and advise you of how you can complain.

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No Fee for Access or Correction
We do not charge a fee for you to access or request the correction of your personal information. However, we may charge a reasonable fee for any costs incurred in processing your request (e.g., for photocopying or postage), and we will inform you of any charges before processing your request.

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Privacy Complaints
If you are not satisfied with our response to your access or correction request, or if you believe that we have mishandled your personal information, you can lodge a complaint with us using the contact details provided below. We will investigate your complaint and respond to you within a reasonable period. If you are still dissatisfied, you can escalate your complaint to the Office of the Australian Information Commissioner (OAIC).

Links to third party sites

Confit Pathways Limited website(s) may contain links to websites operated by third parties. If you access a third-party website through our website(s), personal information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third-party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.

How to contact us

If you have a question or concern in relation to our handling of your personal information or this Policy, you can contact us for assistance as follows: 

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Email 

info@confitpathways.org

 

Post

Attention: Confit Pathways Limited Privacy Officer

Address: 940 Glenhuntly Road, Caufield South VIC 3162

Based in Sydney, Australia. 

We respectfully acknowledge the Traditional Owners of the land on which we work and live. We pay our respects to Elders past, present, and emerging, and extend that respect to all Aboriginal and Torres Strait Islander peoples.

We recognize their ongoing connection to land, waters, and culture, and are committed to working together towards reconciliation and understanding.

Privacy Policy

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