PRIVACY POLICY

By using the The Ministry of Talent Sites, products and/or services or submitting your contact details to receive communications from us, you agree to the terms of this Privacy Policy. The Ministry of Talent Sites include but are not limited to, www.theministryoftalent.com and www.roxysbootcamp.com. Products and services may include The Ministry of Talent branded offerings as well as partner branded offerings promoted in association with these the The Ministry of Talent Sites. 


1. Your Privacy


The Ministry of Talent PTY LTD (ACN 163 256 853) ( “we”, “us”, “our”) recognises that your privacy is very important to you and believes that information received by us that can be used to identify an individual user (“you”, “your”, “User”) should be treated with respect. We are serious about adhering to the Australian Privacy Principles and other applicable privacy legislation. Before providing us with any information, you should read through this policy so that you understand and are comfortable with exactly how we will collect and what we will do with any information you share with Us. This Privacy Policy will also tell you how to access your information and/or seek correction of your information if desired. By using the The Ministry of Talent Sites, products and/or services covered by this Policy and providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information and usage. Please refer to the “Enforcement” Section (Section 11) at the end of this Privacy Policy for our contact details should you wish to contact us about this Privacy Policy or our privacy practices. 



2. What We Collect


Personal and Non-Personally Identifiable Information

We collect “Personal Information”, as well as non-personally identifiable information on The Ministry of Talent Sites and/or services. “Personal Information,” as used in this Policy, is personally identifiable information, such as your first and last name, mailing address, email address, billing information, IP addresses, demographics, passwords, telephone numbers and/or other online contact information. “Personal Information” can also include data that is usually non-personally identifiable (such as location data, data about personal attributes or online identifiers) but that, taken together with other collected data, identifies a natural person, either directly or indirectly. 


Sensitive Information 

The Ministry of Talent does not collect Sensitive Information from users for marketing purposes. “Sensitive Information” includes information about a person’s racial or ethnic origin, religious beliefs or affiliations, political opinions, philosophical beliefs, health or genetic information, sexual preference or information about whether an individual is a member of a professional or trade association or union. Sensitive information might be collected during the course of surveys or competitions administered by The Ministry of Talent or its affiliated third parties, but only if volunteered by Users with their consent. You can choose not to actively volunteer information to The Ministry of Talent. However if you do provide information to The Ministry of Talent when asked or prompted, including Sensitive Information, you are also providing consent for The Ministry of Talent to collect, store and use that information as necessary for the purpose of collecting it. 



3. How We Collect Information


We collect information in three ways. 


(1) Voluntarily


(2) Automatically


(3) Via Third Party Sources


Voluntarily 

We collect information you provide to us in optional, voluntary submissions, including but not limited to: 


(1) registration forms or user profiles, when you provide your name, email address or other information to us voluntarily; 


(2) subscriptions, when you sign up to our courses or newsletters by providing your name and email address; 


(3) entries to promotions, sweepstakes, competitions or contest, by providing your name and email address and other Personal Information depending on the entry requirements; 


(4) feedback communications or customer service requests, where you may supply or we may ask for your name and contact details; 


(5) software and mobile application downloads, where you may provide your name and contact details and other information for the purposes of signing up to the application and obtaining its services; 


(6) curriculum vitae submissions, where you provide your Personal Information to us; and


(7) business submissions, ideas, plans and other information relating to your business strategy and/or activities. 


Automatically 

We create and record information automatically when you visit our Site. We use cookies (or files sent directly to your computer or device) and other similar technology to collect information such as your IP address, the site you visited immediately prior to our Site and the frequency and duration of your visit to our Site. 

We may track activity relating to your interaction with our email communications and with links contained within our email communications and our Site.

We may also collect, use, and share, with The Ministry of Talent’ partners, service providers and licensees, precise location data, including the real-time location of your mobile or fixed location device. Some cookies may be associated with Personal Information about you and some may not. This information is generally collected, used and stored to deliver relevant messaging and enhance your experience when visiting our Site. Wherever possible, we anonymise and pseudonymise your Personal Information. For more information about how Personal Information and non-personally identifiable information is used in relation to marketing and advertising go to “How We Use Your Information – Marketing & Advertising” and “Your Choices – Marketing & Advertising”. 


Via Third Party Sources 

We may also obtain information, including Personal Information, from third party sources. This may include soliciting third parties to collect non-personally identifiable and personally identifiable information on our behalf. In such cases we instruct those third parties to comply with this Policy and require confirmation of their compliance with applicable privacy laws and regulations. We may use analytics tools and other third party technologies, to collect non-personally identifiable information in the form of various usage and user metrics when you use our Sites and/or services. These third party analytics companies may combine the information collected for us with other information they have independently collected across their network of websites, products and services. Many of these companies collect and use information under their own privacy policies. At the moment we only use these tools to collect non-personally identifiable information. We will only use these tools to collect personally identifiable information with your express, informed consent. We do not identify users or merge non-personally identifiable information that we collect with other information to make it personally identifiable. 



4. Security and Integrity


We take measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all Personal Information that we collect. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We will destroy or de-identify your information if we no longer require the information to provide you with access to our Site/s or services and if the information is not required to be saved under Australian law or other Commonwealth record. 



5. Storage


We store your information on networks in Australia and the US and take steps to protect your Personal Information from misuse, loss or unauthorized access. These reasonable steps include password access, firewalls, and secure servers. 



6. How We Use Information


Generally, we use Personal Information to establish and enhance our relationship with our Users through four main categories:


(1) Communication


(2) Optimization


(3)Marketing & Advertising; and


(4)Sharing Features.


Below, we provide some specific examples of how we use the information we collect. 


Communication and Responding to Requests 

To provide you with customer support, share communications such as newsletters, process transactions, respond to users’ requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and connect users to The Ministry of Talent Sites and/or services and to products and services of our partners and licensees. 


Optimisation 

To provide, improve, and maintain our Sites and services, to develop new products and services, to prevent abuse and fraud, to personalise and display advertisements and other content for you, and for other administrative and internal business purposes. 


Marketing & Advertising 

To personalise and display advertisements and other content for you, we may drop a cookie on your browser linked to data that is known about you so that third party advertisers can show you more relevant ads. We may also use various measurement services and companies to analyse collected data about your engagement with our Sites and services. Unless you have provided us with express, informed consent to collect your personal information for targeted marketing and advertising purposes, the information that is collected is not personally identifiable, and is pseudonymous or aggregated data that does not identify any individual user. The third party analytics companies that we use may share the User information they collect from our Sites with other measurement companies, who gather data from various sources, analyse and report on it for their clients. The reported information will cover various 

elements, for example it may summarise how many people have viewed a certain webpage within a certain age bracket. In some instances, the non-personally identifiable information collected from our Site and/or services may be linked with information collected by a third party source, such as Google Analytics, to become personally identifiable. We will not link or merge non-personally identifiable information collected by Us with personally-identifiable information collected by a third party organisation, such as Google Analytics, without your informed, express consent. Google may merge or link your information with the non-personally identifiable information collected from our Site and/or services if You have expressly provided your consent for them to do that. By using our Sites and services, you consent to the collection of data by The Ministry of Talent’ ad servers or third party affiliates, or the transfer of information to them, wherever necessary, for the Network’s performance optimisation and in order to tailor the content and advertising that appears on our Sites. You are entitled to opt out of personalised marketing and advertising at any time. Please refer to Point 8, Marketing and Advertising for opt out options. 


European Union and European Economic Area 

This section is relevant to users that are based in or that access the Sites and services from the European Union and the European Economic Area (“EU Users”). In accordance with the General Data Protection Regulations, which came into force on 25 May 2018, we do not direct personalised advertising and marketing to users in the European Union. This includes tracking EU Users’ activity or targeting EU Users with advertising that uses Personal Information. As explained in the section above, we may use cookies and other tags to display advertisements to EU Users based on non-personally indefinable information, anonymous data, or aggregated data that we have collected in connection with an EU Users’ interaction with our Sites and services. 

We will not track your activity or target you using your Personal Information without your express, informed consent. When requesting your consent, we will provide clear information about the ways that we use your Personal Information. Consent may include requesting that you opt in to particular activities or that you expressly provide your preferences in relation to particular activities. 


Sharing Features 

To provide you with various ways to connect and share content with third parties. By using any third party service to share links to our content, you permit us to access, use and disclose information relating to your account on each such third party service (such as your user name and profile information) if available to us through the third party service. 



7. When We Disclose Personal Information


The Ministry of Talent will not sell, license or otherwise disclose your Personal Information to third parties unless such disclosure is for the purposes set out in this Privacy Policy. 


Between The Ministry of Talent’ Networks 

In order to ensure that our various Sites and services work together optimally, as described above, we share information (including your information) between our multiple online networks. 


Service Providers 

We may provide Personal Information to our third party service providers for their use in performing internal business functions or collecting information on our behalf. Whenever possible, we require such third-parties to only collect and use Personal Information in accordance with this Policy, and for no purpose other than providing us with our requested services. 


Legal Requirements 

We may disclose your information if we are legally bound to do so or if, in our reasonable opinion, such disclosure is necessary to prevent harm to ourselves, other users or any other third party. We will notify you of such disclosure in all such instances. 


Change of Ownership

In the event that there is a change of control at The Ministry of Talent such that we transfer part or all of our assets to a third party, then that third party will obtain access to any information we have collected either automatically or directly from you. We will make reasonable efforts to notify you by posting a notice on our Sites and/or services and, sending you an email if we have your email address. 


Interactive Features 

Any Personal Information that you submit, display, or publish on a forum, blog, channel, bulletin board, chat room, user commenting feature or other interactive sharing or social feature offered through our Sites and/or services, is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us and other third parties without restriction, except to the extent limited access features are available. 



8. Your Choices


Users have a general right to access, edit and manage the collection, processing and use of their Personal Information. Users may opt out of any activity that involves collecting or processing their information for direct marketing purposes. To exercise this right, please refer to the sections below, including the opt out options offered by us and our third party service providers. 


Submitting Personal Information 

Please note that if you do not wish to submit Personal Information, you may not be able to access and/or participate in certain Sites and/or services that require your Personal Information. For example, you will not be able to register for an account with Us, participate in certain contests or promotions, purchase products or access and/or use certain product features or online services. In addition, your refusal to submit Personal Information may limit our ability to respond to your customer support inquiry in a timely fashion. 


Unsubscribing 

You can opt out of receiving The Ministry of Talent communications at any time by clicking the “unsubscribe” link in communications you receive from us. By opting out of one particular electronic communication received from us, you will be removed from the subscriber list in connection with that particular communication category or “newsletter”. However, you will continue to receive communications in relation to other newsletters to which you subscribed, and have not opted out. Please note that if you unsubscribe from The Ministry of Talent communications, we may still send you relevant administrative or security notices from time to time. 


Accessing Personal Information 

You may request access to any Personal Information we hold about you by contacting us as per the details under the Enforcement section in this Policy. Whenever you are entitled to access such information, we will provide such information to you via email or post without charging you for such access. 


Editing Personal Information

You may, at any time, update, correct, or delete certain Personal Information that you have provided to us by contacting us as per the details under the Enforcement section in this Policy. You are entitled to request that your Personal Information is dealt with by us either anonymously or under a pseudonym. 

If we are not able to remove your Personal Information for any reason, we will notify you of this with an accompanying explanation. 


Cookies and Similar Technology 

You can change your browser’s privacy settings to delete or control cookies or other similar technology as you wish. 

Please note that updating these settings may prevent you from using various functionality features, products or services of our Site. 



9.Third Party Websites


When Your Information Leaves Australia 

We may disclose your Personal Information to third party suppliers or partners located outside of Australia. These third party suppliers are located globally. In the event that we are required to disclose your Personal Information to overseas third parties, we will take reasonable steps to ensure that such disclosures are subject to reasonable confidentiality terms, that the overseas third party is subject to a law or binding scheme that protects your information in a way that, overall, is at least substantially similar to the way in which the Australian Privacy Principles protect your information or that the overseas third party takes steps to prevent a breach of the Australian Privacy Principles in relation to your information. 


Third Party Services and Links 

Occasionally we will include links to third party websites on our Site or Communications with you. Whenever you choose to follow such links to any other websites you should be aware that our privacy policy no longer applies and that each third party website’s privacy 

policy will govern their collection, storage and use of any of your Personal Information from the moment you leave our Site. 



10. Changes and Updates to This Policy


The Ministry of Talent regularly reviews its compliance with this Privacy Policy. This Privacy Policy was last updated on 8/8/2019 and may be updated by us, from time to time, in our sole discretion. The current version of the Privacy Policy will be available on our Sites. We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Information. Your continued use of our Sites and/or services or any other content, products or services covered by this Policy constitutes your agreement to this Policy and any updates. 



11. Enforcement


Please feel free to direct any questions concerns or complaints regarding our Privacy Policy or The Ministry of Talent’ treatment of Personal Information by contacting us at info@roxysbootcamp.com or by writing to us at The Ministry of Talent, 7-13 Elizabeth St, Paddington, NSW 2021The Ministry of Talent will contact the complaining party regarding his or her concerns and will cooperate with the appropriate regulatory authorities, to resolve any complaints regarding Personal Information that cannot be resolved internally. Further information can be found at the Government Privacy web site: www.privacy.gov.au. Users in the European Union and European Economic Area have the right to lodge a complaint with the relevant supervisory authority in their member state. We encourage you to contact us first so that we can respond to your concerns. We will do our best to resolve them promptly in accordance with relevant laws and policies.