Privacy Policy

Our Commitment to Privacy

Inclusee Ltd its subsidiaries and affiliates are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act).

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, “we” and “us” refers to Inclusee Ltd and “you” refers to any individual about whom we collect personal information.

About us

Inclusee operates a number of connection-based programs aimed at reducing isolation and loneliness for Australians, using volunteers to provide companionship to those in need.

What information do we collect about you?

We obtain personal information about you when you visit our website, when you contact us or when you use our services and programs.

You may provide us with basic information such as your name, date of birth, phone number, postal address and email address.

If you sign up for one of our programs, we will collect the information that you provide to us via our onboarding process, information about the programs that you participate in, the frequency of your attendance, and any other information that may be identified by our volunteers, communicated by you or by third parties relating to your general care or wellbeing.

In order to help us to run our programs more effectively we may collect personal health information about you including whether have you a disability or any other information that you provide to us that may be relevant to the way we provide you with our service.

If you sign up with us as a volunteer or are an employee, we may collect additional information about you including your criminal history via criminal checks, information disclosed by your referees and any other information that you provide to us or we discover as part of the interview and on-boarding process.

We may also collect additional personal information that you provide to us, or authorise us to collect, as part of your interactions with us.

How do we collect your personal information?

Direct interactions: We collect information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website, interact on our social media pages, apply for a job, use a “Request for Services” form, apply for a role as a volunteer, telephone us or send us an email and when we provide our services and programs to you. We may also collect personal information about you from other sources, such as third parties or persons or organisations who have referred program participants to our services.

Automated technologies or interactions: We use cookies, web analytics tools (including Google Analytics) and similar tracking technologies to track the activity on our website, for better targeting advertisements and for marketing purposes. Cookies are digital identifiers that are stored on your computer. We may collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and third-party websites as well as accessing cookies stored on your computer that were created by third parties. It is possible that you may be either directly or indirectly identifiable from this information. To find out how Google Analytics processes your data please refer to their privacy policy here: www.google.com/policies/privacy/partners/.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.

Why do we collect and use your personal information?

We collect personal information as reasonably necessary to carry out our business and to provide our programs, which may include (but is not limited to);

• delivery of our social connection services and programs;
• to recruit and manage our volunteers;
• meeting our reporting obligations to government bodies;
• contacting and communicating with you including responding to queries, complaints and feedback from you;
• to ensure the proper functioning of our website, our business and operations;
• to assist us with marketing, product and service development and research requirements;
• to manage our employment or business relationship with you; or
• advertising and marketing our products and services.

Who do we disclose your personal information to?

• We may disclose the personal information of program participants to government bodies but only to the extent that is required to comply with our funding obligations.
• We may disclose personal information to third party service providers who host data on our behalf or provide CRM services.
• We may disclose information to third parties we engage in order to run our business or as necessary to provide the programs to program participants.
• We disclose personal information of participants to our volunteers. Our volunteers are required to sign confidentiality agreements as part of their on-boarding process with us. If we disclose participant health information to our volunteers (for example, disability or vision issues) it will only be for the purposes of helping the volunteers to better tailor their visits and meetings with the participant.
• We may disclose the information of participants to that participant’s representative or other third parties involved in the participants direct care, where we, or our volunteers have concerns or identify issues with the participants care or wellbeing;
• We may from time to time need to disclose personal information where we believe it is necessary to comply with a legal requirement or law.
• If we or one of our volunteers forms the view that there is an imminent risk to a participant’s health and safety we may need to share their personal information with emergency services or health professionals.
• We may disclose a participant’s personal information to third parties, where we form the view that the participant would benefit from the services of the third parties, for example, free counselling services. We will always obtain the consent of the participant in these circumstances.
• If there is a change of control in our business (for example a sale of the business) your personal information could be disclosed to a potential purchaser under a confidentiality agreement.
• We may share your personal information with related and affiliated companies located in Australia and overseas.
• We may use and disclose your personal information for other purposes explained at the time of collection with your consent.

Do we use or disclose your personal information for direct marketing?

When you provide us with your contact details, you give your consent to us using your personal information to provide you with information and to tell you about things which we consider may be of interest to you, including by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).

If at any time you do not wish to receive any further Direct Marketing Communications you may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us at the details set out at the end of this document.

If you opt-out of receiving our Direct Marketing Communications, we may still contact you in relation to our ongoing relationship with you.

Do we disclose your personal information overseas?

Any personal information collected and held by us may be disclosed to, and held at, a destination outside Australia including the United States of America. 

By submitting your personal information to us, you expressly consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. We take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia are bound by privacy principles equivalent to those contained within the Privacy Act or agree to meet the requirements of the Privacy Act. 

If you do not agree to the transfer of your personal information outside of Australia, please either do not provide us with your personal information or contact us via the details set out at the end of this document.

Can you deal with us anonymously?

Providing us with your personal information is optional and you may be able to remain anonymous or use a pseudonym when interacting with us. However, it may not always be possible for this to occur especially when you are a participant in our connection programs. We will inform you if you are unable to remain anonymous or use a pseudonym when dealing with us.

How do we hold your information?

We maintain physical, electronic and managerial security to safeguard and secure your personal information.

To the extent permitted by law, we take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.

Links

Our website may contain links to third-party websites. We do not have any control over and are not responsible for the content or privacy practices of websites that are linked to our website. You access and use any linked website at your own risk. You should read the privacy policies on any linked website and only access and use the linked websites if you agree to the terms of those privacy policies.

How can you access or seek correction of your personal information?

Please let us know if there are any errors in your personal information and keep us up-to-date with changes to your personal information (such as your name or address). You can request access to any personal information relating to you which we hold. You can also request that we correct information if it is inaccurate or incomplete.

Please contact us via the details set out at the end of this document if you wish to access or correct any personal information we have about you.

What if you have a complaint?

You may contact us at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled using the contact details at the end of this document.

If you are not satisfied with our response to your complaint, you may contact the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

How are changes made to this Privacy Policy?

We will review this policy regularly and we may update it from time to time. We recommend that you visit our website regularly to keep up to date with any changes.

How can you contact us?

Please contact us through our contact form.

This Privacy Policy was last updated on 19 July 2022