Overview

Change Playbook Pty Ltd ACN 661 269 683 as the trustee for the Tyzack-Young Family Trust (“Change Playbook”, “we”, “us”, “our”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding Personal Data we collect from users of our website changeplaybook.com.au (“Website”) and all related products and services (together the “Services”).

The processing of Personal Data shall always be in line with the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (“Privacy Act”), the General Data Protection Regulation (“GDPR”), and in accordance with country-specific data protection regulations applicable to Change Playbook.

We have implemented a number of technical and organisational measures to ensure the most complete protection of Personal Data (as defined below) processed through the Service.

For the purpose of the GDPR in respect of the Personal Data of the Services, the Data Controller is Change Playbook.

Definitions

In this Privacy Policy, the following capitalised terms have the following meanings.

• Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
• “Personal Data” means any information that allows someone to identify you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
• “Sensitive Data” means Personal Information relating to a person’s physical or mental health, race or religion.

User Consent

Where we rely on your consent as the lawful basis to process your data we will always ask for you to positively affirm your acceptance. By clicking “I accept the Privacy Policy” or similar, or if we indicate that by clicking a button you are accepting this Privacy Policy you acknowledge and agree to be bound by this Privacy Policy.

We note that certain contact or other data forms where consent is required to be given by you include no pre-checked checkboxes so that you are able to freely and affirmatively opt-in. In cases where we do not consider it practical to include a checkbox, we will indicate that by clicking a certain button you have agreed to the terms of this Privacy Policy. We will also provide you with notice on the Website (or otherwise) specifically detailing what it is that you are consenting to in clear and plain language as well ensuring that each matter that requires consent is clearly distinguishable.

For all areas of the Website where consent is given it is just as easily able to be withdrawn.

If you believe that consent has not been given freely or in breach of the terms of this Privacy Policy please contact us.

Children

Our Services are not offered to persons under the age of 18 or who cannot form legally binding contracts under Applicable Law (except where parental/guardian consent is given). We do not knowingly collect Personal Data from such visitors. You must also be old enough to consent to the processing of your Personal Data in your country (in some countries we may allow your parent or guardian to consent on your behalf).

If you become aware that a child has provided us with information please contact us. Any information that is in breach of this provision will be deleted.

Types of Data We Collect

Information you provide to us

Content you provide us

We collect information that you provide to us while participating in the Services and otherwise using the Website. The information we collect includes customer level data (such as your billing address, shipping address and telephone number), order level data and any other additional information you provide to us directly or indirectly through your use of the Website. We use such information to assist in providing our Services to you.

This Personal Data is needed to enable us to provide our Services to you and to enable the Website to operate and otherwise to ensure your compliance with our terms.

The legal basis for this processing is based on:

• your consent through your voluntary submission of agreeing to these terms (where applicable);
• the Personal Data being necessary for the performance of a contract to which you are a party;
• for carrying out pre-contractual measures; and/or
• any other legitimate interests as detailed below.

Payment Data

If you make a payment for a Service, we (or our third party service provider) will collect all information necessary to complete the transaction, including your payment card information, bank account information and/or other billing information. We use this information to send to our third party payment gateways when you make payment for a Service.

The Personal Data we collect will be the data that you provide us when making payment.

The legal basis for this processing is based on:

• your consent through your voluntary submission of agreeing to these terms (where applicable);
• the Personal Data being necessary for the performance of a contract to which you are a party including the payment of goods or services; and/or
• any other legitimate interests as detailed below.

This Personal Data is needed to enable us to process your payment for the relevant purchase made by you. We retain information on your behalf, such as service invoices, transactional history, messages and any other information that facilitates payment for a Service.

Additional Data

If you provide us feedback or contact us via e-mail, or other means including by face-to-face meeting, by phone call, post, through social media or other communication or by contracting with us, we will collect your name and e-mail address, as well as any other content included in the e-mail or conversation, in order to send you a reply or otherwise process your request. We will store and process your communications and information as needed. When you participate in one of our surveys, we may collect additional profile information.

The legal basis for this processing is based on:

• either through your consent through your voluntary submission of agreeing to these terms or by your voluntary submission of data to us in other means;
• the Personal Data being necessary for the performance of a contract to which you are a party;
• for carrying out pre-contractual measures; and/or
• any other legitimate interests as detailed below.

By submitting the form or making contact with us such Personal Data is transmitted on a voluntary basis and you consent to its collection.

Marketing List Data

On the Website you may have the ability to subscribe to various newsletters and email marketing lists. We may collect the data when you input your details for subscription purposes which may include your name, email address and email marketing preferences.

The Personal Data is processed for the purpose of informing you regularly by means of a newsletter or other offer form. The Personal Data collected during the subscription will only be used for marketing materials or for reasons made known on the form.

The legal basis for this processing is based on:

• your consent through your voluntary submission of the form and agreeing to these terms; and/or
• any other legitimate interests as detailed below.

By submitting the form and voluntarily providing us with your data, you are providing consent to the use of such data by us. For the purpose of revocation of consent there is a corresponding unsubscribe link found in each subscription email. Please note that some features of the Service may involve us providing, through the functionality within the Service, recommendations or suggestions for products, services or benefits that we offer.

Submission data

To make our Website more useful to you, we may collect Personal Data about your input on the Website.

This data may be processed for the purposes of monitoring your use of the Website and compliance with our terms. We may then use that data in aggregate (i.e. anonymised) in order to determine metrics associated with our Website, and otherwise to improve our Website. We can also use it to assess whether any warranty or other claims made by you are valid.

The legal basis for this processing is based on the legitimate interests of carrying out our business, providing personalised services to you and any other legitimate interests as detailed below.

We may also collect Personal Data at other points on the Service that state that Personal Data is being collected. In some circumstances, Personal Data is provided to us by third parties such as our related entities, service providers or other organisations conducting activities on your behalf. With your expressed consent, your Personal Data may be used and disclosed to us this way. The purposes as outlined above may include the processing of such Personal Data to the extent necessary for us to comply with a law, regulation or legal request or to protect the safety of any person or to prevent fraud.

INFORMATION WE COLLECT FROM OTHERS ABOUT YOU

Content other people post and share

We also collect information, communications and information other people provide when they use the Website. This includes any information about you that a third party provides to us.

The legal basis for this processing is based on:

• your consent through your voluntary submission of the form and agreeing to these terms;
• the Personal Data being necessary for the performance of a contract to which you are a party including the payment of goods or services; and/or
• any other legitimate interests as detailed below.

This Personal Data is needed to enable us to provide the Website to you in a functional manner.

INFORMATION WE COLLECT AS YOU USE OUR SERVICES

Log Data

To make our Website and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

This data may be processed for the purposes of operating our Website, providing our Services, improving our Services, ensuring the security of our Website and Services, maintaining back-ups of our databases and communicating with you.

The legal basis for this processing is based on:

• the Personal Data being necessary for the performance of a contract to which you are a party;
• for carrying out pre-contractual measures; and/or
• the legitimate interests of carrying out our business, providing personalised service to you and any other legitimate interests as detailed below.

Google Analytics

We currently use Google Analytics as well as Google Analytics for Display Advertising. Google Analytics collects information anonymously and reports website trends without identifying individual visitors. Google Analytics uses its own cookie to track visitor interactions. Site owners can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it. Please see the following links for more information about Google Analytics: http://www.google.com/analytics/,http://www.google.com/privacy.html and http://www.google.com/analytics/tos.html

Facebook pixels

We currently use Facebook pixels for conversion tracking and custom audiences, in accordance with Facebook’s terms which can be viewed here https://www.facebook.com/customaudiences/app/tos/?ref=u2u.

Use of Your Personal Data

In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in providing the Services in a personalised, safe and efficient manner. We collect, use, store and share your Personal Data in the following ways:

• to conduct our business;
• to facilitate the Services and to enable the benefits of the Service to be utilised and enjoyed, subject always to our Consultancy Agreement;
• to operate the Website and provide Services or information to you including to:
  • assist in streaming and personalising information for you;
  • enable us to process your personal data;
  • to manage our relationship with you, including information about similar products or terms and conditions or send you an email reminder that a task you have performed on our Website remains uncompleted such an incomplete form;
  • enable you to communicate with us regarding your use of the Website;
  • confirm your identity;
  • to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing the services to you;
  • communicate with you about any transaction;
  • to allow you to input data into the Website;
  • to allow your use to be restricted and limited as required;
• administer contracts including to negotiate, execute and or manage a contract with you;
• on an aggregated non-identifiable basis, to:
  • help Change Playbook understand its market position;
  • assist with marketing our Service to others, including in respect of any online advertising; and
  • deliver a statistical result to help with general Change Playbook announcements;
• for any marketing purposes;
• research, develop and improve our Services;
• customise content to match your preferences;
• provide you with access to protected areas of the site;
• send you administrative e-mail notifications, such as security or support and maintenance advisories;
• respond to your inquiries and requests;
• to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
• to send newsletters, surveys, offers, and other promotional materials related to our Service and for other marketing purposes of Change Playbook;
• detect, investigate and prevent potentially unlawful acts or omissions or acts or omissions with the potential to breach this Privacy Policy or any other policy;
• enforce this Privacy Policy or any other policy;
• verify information for accuracy or completeness (including by way of verification with third parties);
• comply with our legal obligations, a request by a governmental agency or regulatory authority or legally binding court order;
• combine or aggregate your Personal Data with information we collect from third parties and use it for the purposes set out this Privacy Policy;
• aggregate and/or make anonymous your Personal Data, so that it cannot be used, whether in combination with other information or otherwise, to identify you;
• resolve disputes and to identify, test and resolve problems;
• notify you about the Service and updates to the Services from time to time;
• supply you with generalised, targeted or personalised marketing, advertising and promotional notices, offers and communications, and measure and improve our marketing, advertising and promotions based on your ad customisation preferences; or
• protect a person’s rights, property or safety.

If you access the Website from a shared device or a device of a third party (such as in an internet café), your Personal Data may also be available to other persons who access that device.

CREATION OF ANONYMOUS DATA

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyse request and usage patterns so that we may enhance the content of the Services and improve Website navigation. Change Playbook reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

Disclosure of Your Personal Data

We may disclose your Personal Data to third parties for the purposes contained in this Privacy Policy, including without limitation to:

Service Providers

We may share your Personal Data with service providers and licensors of software services utilised by us in the provision of the Service to:

• develop and improve our Service;
• provide you with the Service;
• to conduct quality assurance testing;
• to provide technical support;
• and/or to provide other services to Change Playbook.

The service providers (and if necessary data processors) include:

• information technology service providers such as web host providers and analytical providers;
• mailing houses;
• organisations who carry out credit, fraud and other security checks;
• payment processors;
• hosting services;
• content delivery services;
• IT support providers;
• marketing businesses engaged by us to disseminate materials to which recipients have consented; and
• specialist consultants.

We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services and associated purposes. We deal with third parties that are required to meet the privacy standards required by law in handling your Personal Data, and use your Personal Data only for the purposes that we give it to them.

Affiliates and Acquisitions

We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honour this Privacy Policy. In the event we are involved in a merger, acquisition or sale of assets we may disclose Personal Data collected by us to such entities that we propose to merge with or be acquired by, and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Social media and marketing businesses

We may share some or all of your Personal Data with social media companies such as Facebook in order to provide targeted marketing to you and others. You consent to such disclosure.

Third parties with your consent

We may disclose your Personal Data to third parties to whom you expressly ask to us to send the Personal Data to or to third parties you consent to us sending your Personal Data to.

We may also, with your consent or at your direction, disclose your Personal Data to your authorised representatives.

Other disclosures

Regardless of any choices you make regarding your Personal Data (as described below),Change Playbook may disclose Personal Data if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws, regulations, enforceable governmental requests or to respond to subpoenas or warrants served on Change Playbook; (c) to protect or defend the rights or property of Change Playbook or users of the Service; (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy; (e) to protect the safety of any person or to protect the safety or integrity of our platform including for security reasons; and (f) detect, prevent or otherwise address fraud, security or technical issues.

We may share your Personal Data with such third parties subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your Personal Data only on our behalf and pursuant to our instructions.

We will take reasonable steps to ensure that anyone to whom we disclose your Personal Data respects the confidentiality of the information and abides by the APPs the GDPR or equivalent privacy laws.

We will not share, sell, rent or disclose your Personal Data in ways different from what is disclosed in this Privacy Policy.

If we can’t collect your data

If you do not provide us with the Personal Data described above, some or all of the following may happen:

• we may not be able to provide the Services to you, either to the same standard or at all;
• we may not be able to run the competitions and promotions in a way that benefits you;
• we may not be able to provide you with information about products and services that you may want; or
• we may be unable to tailor the content of the Service to your preferences and your experience of the Service may not be as enjoyable or useful.

Cookies Policy

Please see our Cookies Policy published here [link].

Third Party Sites

When you click on a link to any other website or location, you will leave the Service and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content and we are not responsible for the privacy practices of those third parties. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites. The privacy policies and other terms that apply to those outside websites or their content may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those outside websites.

Managing Your Personal Data

Subject to the Privacy Act and the GDPR you may request to access the Personal Data we hold about you by contacting us. All requests for access will be processed within a reasonable time.

• Accessing or Rectifying your Personal Data

  If required by law and if reasonably practicable, we may provide you with tools to access, correct, delete, or modify the Personal Data you provided to us. You can download and access certain information you provide to us by emailing us. You may submit a request to us to correct, delete or modify your Personal Data and download the data for you.

  Sometimes, we may not be able to provide you with access to all of your Personal Data and, where this is the case, we will tell you why. We reserve the right to charge a reasonable fee for searching for, and providing access to, your information on a per-request basis. We may also need to verify your identity when you request your Personal Data.

• Deletion

  We keep data for as long as it is needed for our operations.

  If you wish to have us delete your data please contact us.

• Object, Restrict, or Withdraw Consent

  You may manually submit a request to us if you object to any Personal Data being stored, or if you wish to restrict or withdraw any consent given for the collection of your Personal Data.

  You may withdraw your consent to the processing of all your Personal Data at any time. If you wish to exercise this right you may do so by contacting us.

  You may withdraw your consent or manage your opt-ins by clicking the unsubscribe link at the bottom of any marketing materials we send you.

• Portability

  We may provide you with the means to download the information you have shared through our services. If you require such information, please email us.

  We may retain your information for fraud prevention or similar purposes. In certain instances we may not be required or able to provide you with access to your Personal Data. If this occurs we will give you reasons for our decision not to provide you with such access to your Personal Data in accordance with the Privacy Act and the GDPR.

  There is no application fee for making a request to access your Personal Data. However, we may charge an administrative fee for the provision of information in certain circumstances such as if you make repeated requests for information or where the information is held by a third party provider.

Storage & Security of Your Personal Data

The Change Playbook Service is hosted by third party services whose servers are located in Australia. All data is stored in Australia.

Change Playbook is committed to protecting the security of your Personal Data. We take all reasonable steps to protect Personal Data, including through internal and external security, restricting access to Personal Data to those who have a need to know, maintaining technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security. We choose technology partners based on their security and privacy policies and practices.

Personal Data stored in our system is protected by electronic and procedural safeguards. We take reasonable precautions to protect Personal Data (and other content) from accidental loss and theft by storing it in secure data centres with off-site backups.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, while Change Playbook uses reasonable efforts to protect your Personal Data, Change Playbook cannot guarantee its absolute security.

International Transfer and Disclosure of Personal Data

Where we transfer Personal Data outside of the European Union or EFTA States, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws.

We may disclose Personal Data to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your Personal Data do not breach the privacy obligations relating to your Personal Data.

We may disclose your Personal Data to entities located outside of Australia, including the following:

• our related bodies corporate; and
• our data hosting and other IT service providers; and
• other third parties.

Third parties located overseas are not permitted to (and are contractually obligated to not) access or use the Personal Data provided except for those limited purposes. We only choose reputable service providers and have agreements with such third parties that prevent them from using or disclosing to others the Personal Data we share with them, other than as is necessary to assist us. We may disclose your Personal Data to entities who may store or process your data overseas.

Notifiable Data Breaches

We take data breaches very seriously. Depending on where you reside our policy is:

• If you reside in Australia:

  In the event that there is a data breach and we are required to comply with the notification of eligible data breaches provisions in Part IIIC of the Privacy Act 1988 (Cth) or any other subsequent sections or legislation which supersede this Part IIIC, we will take all reasonable steps to contain the suspected or known breach where possible and follow our notifiable data breach policies.

• If you reside in the European Union of EFTA States:

  We will endeavour to meet the 72 hour deadline as imposed by the GDPR, to report any data breach to the supervisory authority where a data breach occurs that will likely be a risk to you.

  Further, where there is likely to be a high risk to your rights we will endeavour to contact you without undue delay.

  We will review every incident and take action to prevent future breaches.

Automated individual decision-making, including profiling

If you reside in the European Union or EFTA States, you shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between us, or is not authorised by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or is not based on your explicit consent. If you wish to exercise your rights please contact us.

Retention of Data

We keep Personal Data as long as it is reasonably needed for our operations and to fulfill the purposes set out herein.

We take steps to regularly destroy Personal Data, however we may:

• in some cases, retain a copy of your Personal Data to comply with our legal obligations, resolve disputes, enforce our agreements and to comply with our trust and safety obligations. Personal Data retained for this purposes will be archived and stored in a secure manner, and will not be accessed unless required for any of these reasons; and
• retain Personal Data in an aggregated, de-identified or otherwise anonymous form, such that there is no reliable way of identifying you from the information.

Contact Information

Change Playbook welcomes your comments or questions regarding this Privacy Policy.

If you have a question regarding this Privacy Policy or you would like to make a complaint, please contact us by email by using our contact details on the Service or below.

If you reside in Australia:

You can confidentially contact our Privacy Officer at:

The Privacy Officer
Change Playbook
Submit a contact us form on our Website, changeplaybook.com.au
If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commission at

Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Office Address: Level 3, 175 Pitt Street, Sydney NSW 2000
Postal Address: GPO Box 5218, Sydney NSW 2001
Site: www.oaic.gov.au

If you reside in the European Union or EFTA States:

The data controller that is responsible for your Personal Data is:

The Privacy Officer
Change Playbook
Submit a contact us form on our Website, changeplaybook.com.au
If you wish to raise a concern about our use of your information you have the right to do so with your local supervisory authority. Please see https://edpb.europa.eu/about-edpb/board/members_en for a list of local supervisory authorities.

Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision and Change Playbook reserves the right, at its sole discretion, to modify or replace any part of this Agreement. It is your responsibility to check this Agreement periodically for changes. Continued use of the Service shall indicate your acknowledgement of that it is your responsibility to review the Privacy Policy periodically and become aware of any modifications.