GenFuture Privacy Policy
Tower Human Capital Pty Ltd (ABN 15 130 476 247) trading as GenFuture (GenFuture) is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
In order to deliver our services, GenFuture may collect, use, store and disclose personal information. This Privacy Policy outlines and explains how and why we collect personal information, the purposes for which we use this information, who the information is disclosed to and what our handling process is for complaints (Policy).
You consent to us collecting, holding, using and disclosing your personal information in accordance with this Policy.
There are a few key terms that we use in this data policy that you should be aware. The key terms include:
- “We”, “us” and “our” means GenFuture.
- Sensitive data/information means information relating to racial or ethnic origins, political opinions, religious or philosophical believes, trade-union membership, genetic data, biometric data, health-related data and data in relation to sex or an individuals’ sexual orientation.
- Data Controller means GenFuture as we determine the purposes and the means by which personal information is collected and used.
- Consent means consent that is freely given, specific and informed and demonstrates an unambiguous indication of your wishes which by a statement or by a clear affirmative action signifies agreement to data processing. Consent must demonstrate a clear understanding of the reasons we are collecting the information and must at all times be able to be withdrawn without the user being disadvantaged.
- Processing means any and all action in relation to personal data including the collection, using, disclosing, storing, and transferring, deleting and otherwise handling personal data.
What is personal information?
Personal information means any information or an opinion about an individual who can be reasonably identified from that information or opinion, regardless of whether it is true. Types of personal information includes personal details (such as your name, address, telephone number, email address, employment details and bank account details).
What types of personal information do we collect?
We collect information about you and your interactions with us, for example on registration and when you use our website.
The information we collect from you when you register with us includes:
- Your Name
- Your Email
- How you heard about GenFuture.
The information we collect at your discretion following registration with us includes your Demographic details including:
- Your Age Bracket
- Your Education Level and History
- Your Gender
- Your Language
- Your State and Region of Residence
- Your Career Goals.
We may also collect information about how you access, use and interact with our website. We do this by using tools such as Google Analytics. This information may include:
- Google Analytics
- Web analysis tools that are built into the GenFuture website to measure and collect anonymous session information.
Thinkific Labs Inc. (Thinkific) collects information about how you interact online so that we can administer our GenFuture Program. This information may include:
- Your progress through the course
- Survey results
- Discussion or forum contributions; and
- Other student activities.
For what purpose do we collect, hold and use your personal information?
We will not disclose your private information other than for the purpose it was collected. Unless, you consent for the disclosure or you would reasonably expect the disclosure in the circumstances or when required by the law.
If you provide us with a testimonial, we will de-identify you and credit you as ‘anonymous’, unless you provide us with consent to use your personal details.
In general, we collect, use, and disclose your personal information so that we can do business together and for purposes connected with our business operations. Some of the specific purposes for which we collect, use, and disclose personal information are:
- provide and operate our services;
- provide you with ongoing assistance and technical support and manage our relationship with you;
- help us understand our program reach;
- contact you with general or personalised service-related notices and promotional messages;
- identify and tell you about other products or services that may be of interest to you; and
- comply with our legal obligations.
- for our internal administrative, research, planning, marketing and product development.
- to respond to you if you have requested information (including via our websites or via an email or other correspondence you send to us);
- to advertise or administer rewards, surveys, competitions, products, services or other promotional activities or events conducted, sponsored, provided or managed by us or our business partners;
- to enable you to use our apps and other applications that you download;
- to improve our goods and services;
- to verify your identity, address, and age or eligibility to participate in a marketing activity;
- to address any issues or complaints that we or you have regarding our relationship;
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner; and
- for research purposes.
If we do not have your personal information we may not be able to provide you with our full range of Services, communicate to you or provide assistance that you may require.
How do we collect your personal information?
We will collect your personal information directly from you whenever you interact with us. This may include:
- registering to use our Services.
- by using our website.
- by subscribing to our newsletters and events.
- by another clear affirmative action signifying your agreement for us to process and use your data.
How do we store and hold your personal information?
We store and hold your personal information using third-party providers.
Our Program is hosted by Thinkific. They provide us with the online course creation platform that allows us to sell our services to you. Your information is stored on our Thinkific platform for as long as it is relevant for the purpose of which it was collected. Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.
Our website is hosted on the WordPress.com platform. Your data may be stored through WordPress.com’s data storage, databases and the general WordPress.com applications. They store your data on secure servers behind a firewall.
Your personal information may also be stored on Dropbox, Gmail, Zoom, Calendly, Mailchimp (to send correspondence relating to the Services), Salesforce.com Inc. (our choice of Customer Relationship Management system), and The Paul Hertz Group for the purpose of providing you with your PRINT® Survey and Report.
We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.
You consent to your personal information being stored and held by third party platforms, which may include being stored overseas. You acknowledge that it is your responsibility to read the terms and conditions of use, and the privacy policy for each third party provider. We are not liable for any breach by a third party provider of any applicable privacy laws, including the Privacy Act.
Direct marketing
Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you and to provide you with special offers. Direct marketing can be delivered by a range of methods including mail, telephone, email, or SMS. We may use your information, for the purposes of direct marketing and you consent to us using your personal information for this purpose. You can unsubscribe from our direct marketing, or change your contact preferences, by contacting us on our details below.
Who do we disclose personal information to and why?
We may disclose your personal information to third parties in connection with the purposes described in this Privacy Policy.
This may include disclosing your personal information to the following types of third parties:
- our employees and related bodies corporate; our contractors and other third parties that provide goods and services to us (including website and data hosting providers, and other suppliers);
- our accountants, insurers, lawyers, auditors, and other professional advisers and agents; payment system operators;
- if you are an individual contractor to us or a prospective employee, to our related companies and HR-related service providers (e.g. for outsourced payroll processing);
- any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
- in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors;
- third parties that require the information for law enforcement or to prevent a serious threat to public safety;
- you may have expressly consented to the disclosure; and
- otherwise as permitted or required by law.
Where we disclose your personal information to third parties we will use reasonable efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Australian Privacy Principles under the Privacy Act.
If you post information to public parts of our websites or to our social media pages, you acknowledge that such information (including your personal information) may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.
Do we disclose personal information to overseas recipients?
Except for our authorised third party suppliers who may be based overseas, we do not disclose your personal information to recipients which are located outside Australia. For the avoidance of doubt, we have taken reasonable steps to ensure that our third party suppliers have secure systems in place and will not act in breach of any applicable privacy laws. You acknowledge that we will not be held accountable under the Privacy Act for any breach by our third party suppliers.
How do we protect personal information?
Personal information held and stored by third-party providers are stored according to their respective privacy policies. It is your responsibility to ensure that you have read and understood the third-party provider policies, and we will not be held accountable for any breach of a third-party provider.
We will take reasonable steps to keep any personal information we hold about you secure. We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure. We store any personal information about you on a secure server behind a firewall.
Except to the extent it cannot be lawfully excluded, we exclude all liability (including in negligence) for the consequences of any unauthorized access to, disclosure of, misuse of, or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).
Please notify us immediately if you become aware of any breach.
Access to and correction of your information
It is important to us that your information is accurate, up to date, and complete. We therefore encourage you to contact us if you would like:
- to update, amend or correct inaccurate, incomplete or out of date data in our possession;
- to access, review or request a copy of your personal data;
- to remove, erase or delete your personal data;
- to limit or restrict the processing rights;
- to find out more information in relation to how we process your information, this privacy policy or your rights under this privacy policy;
- to withdraw previously given consent;
- to use a pseudonym for your data;
- to raise a concern of complaint about the way we have used or handled your information; or
- to exercise another right under the applicable data protections laws.
We endeavour to assist with your request within a reasonable time frame (and at the latest within 1 month of your request) unless it is unlawful to do so, if there are ongoing legal proceedings or if the request is deemed frivolous or vexatious.
There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material)
Where you have raised a concern or complaint about the way we have used your personal information and you are not satisfied after consulting and raising your concerns with us, you can notify your applicable national data protection authority.
You have the right to request to update or correct your details and to access to your personal information. You may do so by contacting us using the details provided at the end of this Privacy Policy.
Cookies
We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.
Notifiable data breaches
In the event of a serious data breach involving personal information that is likely to result in serious risk of harm to an individual, we will promptly contain the breach and take remedial action including, where appropriate, an assessment of the suspected data breach. Where an eligible data breach has been identified we will,
- a) notify all individuals of the breach; or if that is not practicable
- b) notify only the individuals whose personal information is at risk of serious harm (together, Notified Users).
We will provide Notified Users the details of the data breach, the kinds of information concerned in the data breach, the best way to contact us and our recommended steps in response to the data breach.
As soon as practicable after we become aware of the breach we will report a statement of the breach to the Australian Information Commissioner through the online platform.
If we deem (a) or (b) above not to be practicable, we will publish a copy of the statement prepared for the Australian Information Commissioner on our website.
External Sites
We may provide you with external links and resources. Please be aware that we are not responsible for the privacy policies of other Sites. This Policy only applies to private information collected by us.
Merger, Restructure or Sale of our Business
In the event that part or all of our business is merged, restructured or sold, we may transfer your personal information, as part of that merger, restructure or sale.
Changes to this policy
From time to time, we may review and update this Policy without notification to you. Any changes to our policy will be published on our website.
At any time, our latest version of our privacy policy is available from our website at: https://genfuture.com.au/privacy-policy/.
Disclaimer
You acknowledge and agree that no transmission of information or data on the internet is completely secure. We do not guarantee or warrant the security of any information that you provide to us, and that you transmit such information at your own risk.
Complaints
If you believe there has been a breach of the Privacy Act 1988 (Cth) you may contact us directly, using the details provided at the end of this privacy policy and we will aim to resolve your complaint.
If you do not consider our response acceptable, you may direct the complaint to the Australian Privacy Commissioner by telephone 1300 363 992 or at their website https://www.oaic.gov.au/.
Contact us
If you have any questions, comments, requests or concerns, please contact us at:
GenFuture
+61 8 9226 4256
[email protected]
This Privacy Policy was last updated 31 January 2024.