Effective Date: 19 August 2021
Halcyon Coaching is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au
When we talk about the “Site”, we mean our platforms, which include our websites and our mobile applications, our communications that we send and services that we provide, social networking sites, and any other websites we offer that link to or reference this Privacy Statement.

What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual.
Personal Information is obtained in many ways including through social media channels, correspondence, by phone, by email, via our website www.halcyonwomen.com, from your website, from media and publications, from other publicly available sources, from cookies and from third parties. We don’t guarantee nor take any liability for any website links or policy of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Personal Data We Collect

• We will collect the following personal data when you interact with the Site:
  Authentication and identification information (e.g. your name, email address, and password). This information is necessary to set up and log you into your account. If you don’t provide this, we may not be able to provide our full range of account services to you;
• Basic personal details (e.g. your name, date of birth, and nationality);
• Contact details (e.g. your postal address, telephone number, and email address). We may need some of this information to deliver products to you, such as your postal address to deliver physical products and your email address to send you vouchers, and won’t be able to carry out these Services if you don’t provide it;
• Payment details (e.g. your credit card details or payment tokens from third party payment providers like PayPal). We use these to process your order, and won’t be able to take payment from you or give refunds if you don’t provide it; and
• Information about your contacts with Halcyon Coaching (e.g. call recordings, instant messages on our site, and user generated content).

Some information we collect is necessary for us to provide our services or meet our legal obligations. We will make this clear when we collect that information from you.
We will also automatically collect personal data when you interact with the Site through your computer, mobile device, or other device.
We will collect the personal data described above at various stages in your relationship with us when you:

• Register, subscribe, authorise the transfer of, or create an account with us. If you choose not to create a password for your account, we create an account and link your purchase details to your email address, which you can set a password for during each purchase;
• Open or respond to emails or messages from us;
• Provide information to enrol or participate in programs provided on behalf of, or together with Sellers and Business Partners, with your consent or as necessary to provide Services you have requested;
• Visit any page online that displays our ads or content;
• Purchase products or Services on or through the Site;
• Connect, log-in, or link to the Site using social networking tools; and
• Post comments to the online relevant sections of the Site.

Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
     • For the primary purpose for which it was obtained
     • For a secondary purpose that is directly related to the primary purpose
     • With your consent; or where required or authorised by law.

Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
      • Third parties where you consent to the use or disclosure; and
      • Where required or authorised by law.

Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
You are responsible for your username and password to gain access to the Site. DO NOT pass this private password to any third party. We are not liable for your online account with Halcyon Coaching if it is used by a third party due to your negligence over security surrounding your password. We reserve our rights in the event of your password being used by a third party which causes any loss to Halcyon Coaching.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us at andrea@halcyoncoaching.com.au.
Halcyon Coaching will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Retention of Personal Data
We will retain your personal data for as long as your account is active or as needed to provide you services. If you close your account, we will retain your personal data for a period where it is necessary to continue operating our business effectively, to maintain a record of your transactions for financial reporting purposes or fraud prevention purposes until these purposes no longer exist, and to retain as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Policy Updates
We routinely update this Privacy Statement to clarify our practices and to reflect new or different privacy practices, such as when we add new services, functionality, or features to the Site. If we make any material changes we will notify you, either by email (sent to the email address specified in your account), by means of notice on the Site or by using other methods. You can determine when this version of the Privacy Statement was adopted by us by referring to the “Effective Date” above.
You understand that your continued use of the Site after we send a notice about our changes to the Privacy Statement means that the collection, control, processing, and use of your personal data is subject to the updated Privacy Statement. If you object to any changes, you may modify your account settings or close your account as described below.

Privacy Policy Complaints and Enquiries
We are committed to working with you to obtain a fair resolution of any request, complaint, or concern about our use of your personal data. If, however, you believe that we have not been able to assist you, you can submit a complaint to andrea@halcyoncoaching.com.au or contact the Office of the Australian Information Commissioner (OAIC) through their website, https://www.oaic.gov.au/.