1. Who are we and what do we do?
- a. MindNavigator Technologies Pty Ltd ACN 34 600 293 721 (“MindNavigator”) is the licensee of the technology platform known as “MindNavigator” which provides a program in leadership development. Authorised End Users* are permitted to use the MindNavigator Product in order to undertake subjects (“Modules”) in the development program (“the Program”).
- d. MindNavigator deals with personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles contained within Schedule 1 of the Privacy Act (“Australian Privacy Principles”).
2. What sort of information do we collect and how do we receive it?
- a. When you login to use the MindNavigator Product, MindNavigator collects and uses your personal information being your name, personal and work email addresses, telephone number, address, date of birth, your job title (if you work for a company or business) and the Modules and Program in which you are enrolled, as updated from time to time (“the Information”). Our third party service providers may collect billing information on our behalf to process orders.
- b. Non-personal information is all information that is not personal information or is information that was personal information but which we modify and/or aggregate with other data in order to make it Non-personal information. As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate, and anonymously generated device identifiers and administer the site.
- d. MindNavigator collects information through "cookies" and other similar tracking technologies to analyse trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. Cookies are text files saved by your browser when you log into our software or services. We may use both session cookies and persistent cookies to identify that you have logged in, to tell us how and when you interact with our software or services, and to check aggregate usage and web traffic. Unlike persistent cookies, session cookies are deleted when you log off and close your browser. If you prefer, you can always change your browser options to stop accepting cookies or to prompt you before accepting cookies. However, if you do not accept cookies you may not be able to access the entirety of our software and services.
3. Why do we need your information?
- a. We collect the Information for the purpose of allowing you access to the MindNavigator Product so that you can use the Product in order to undertake Modules in the Program. We collect the Information for product development, quality control and training purposes. We also collect the Information to enable us to inform you of other Modules which are available on the MindNavigator platform.
- b. When we no longer need the Information we will take all reasonable steps to de-identify or destroy the Information.
4. How do we store your information?
- a. The Information is stored by Amazon Web Services on secure cloud-based servers located in Sydney, Australia or in other global locations as part of negotiation and only at customer request. We have taken a number of steps to protect the Information from loss, misuse and unauthorised access, modification or disclosure. We use appropriate security technology to ensure that your Information is transmitted safely to us through the internet or other electronic means.
5. Who does MindNavigator disclose your information to?
a. The Information will be shared with the following:
Your employer; and
The agent of MindNavigator or the reseller of the Product through which you purchased or licensed the Product.
- Your employer; and
- b. Apart from the parties identified above, the Information is not provided to any third parties.
- c. A report will be provided to the employer (Purchaser) regarding the group of employee End Users who are undertaking the Program. The report is in the form of a numerical scoring system which provides feedback on the progress of the End Users. The MindNavigator 360 Feedback Program is accessible to the Purchaser’s human relations department. However, no access will be provided to the End User’s personal journals other than the individual End User (provided that the End User keeps their login details securely protected).
- d. MindNavigator may send the Information overseas if it relocates its server to an overseas jurisdiction.
- e. When you login to the MindNavigator Product and provide your consent, you will have the opportunity to consent to MindNavigator disclosing your Information to an overseas recipient. By consenting to this, MindNavigator will not be required to comply with sub-clause 8.1 of Australian Privacy Principle No. 8 which provides that an organisation or agency must not disclose the personal information to an overseas recipient unless it takes such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles (other than Australian Privacy Principle 1) in relation to the information.
- i. We may disclose personal information to government agencies, law enforcement officials, and private parties as we, in our sole discretion, believe necessary: (1) to satisfy or comply with any applicable law, regulation or legal process; (2) to respond to lawful requests, including subpoenas, warrants or court orders; (3) to protect our property, rights and safety and the rights, property and safety of third parties or the public in general; and (4) to prevent or stop activity we consider to be illegal or unethical.
- ii. In certain situations, MindNavigator may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- ii. We may share your personal information with third-party sites or platforms, such as social networking sites, but only if you have expressly requested that we do so.
- iii. Similarly, by posting profile, content, or other information, including personal information to a forum or blog, you indicate your consent to its public use. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We will list you in our publicly accessible member directory on the forum website.
- iv. We also display testimonials of satisfied customers on our websites in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at the address below
- a. The Information will be shared with the following:
6. What happens if you do not provide the Information?
- a. If you do not consent to us collecting, using and storing the Information we will be unable to provide you with access to the MindNavigator Product in order to for you to undertake the Modules in the Program. Due to the nature of the Information which is collected, it is not possible for you remain anonymous or provide a pseudonym. Please direct any queries about this to the Privacy Officer whose details are provided in clause 8.
7. How do you access your information?
- a. MindNavigator manages all personal information in accordance with the Australian Privacy Principles. And the General Data Protection Regulation (EU) 2016/679 ("GDPR") which is effective May 25, 2018. The GDPR requires that a valid legal basis be used to process personal data. In certain countries, there are different legal bases that we rely on to use your personal information.
- c. You may access, modify or delete (subject to applicable law) the personal information associated with your use of our services at any time by contacting the privacy officer.
- d. You can also correct and update the Information by writing to our Privacy Officer. All requests for changes will be effected as soon as reasonably possible.
- e. If you wish to make a complaint against MindNavigator for a breach of the Australian Privacy Principles or GPDR, you can raise the complaint with our Privacy Officer who will endeavour to respond to you within a reasonable period.
8. How to contact us
a. If you wish to access and/or correct the Information, or if you wish to make a complaint regarding a breach of the Privacy Act, please contact our Privacy Officer on the following details:
Title: Ms Ami Cook, Privacy Officer
Email Address: firstname.lastname@example.org
Phone Number: +61 406 590 585
Postal Address: Suite 1D, Level 23, Governor Phillip Tower, 1 Farrer Place, Sydney, New South Wales, Australia, 2000
Our Privacy Officer will endeavour to respond to you within a reasonable period.
- Title: Ms Ami Cook, Privacy Officer
- a. If you wish to access and/or correct the Information, or if you wish to make a complaint regarding a breach of the Privacy Act, please contact our Privacy Officer on the following details: