Introduction

ClubsHR Software Solutions Pty Ltd (ClubsHR or we) regards customer privacy as an important part of our relationship with our customers. The following privacy policy applies to the collection of personal information by ClubsHR from its customers and users.

ClubsHR is committed to protecting customer’s personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).

We make our privacy policy available on our website located at ClubsHR Privacy Policy and we can also provide a hard copy version upon request. If you would like more information or a hard copy of this privacy policy, please contact us by:

• Email: help@clubshr.com; or
• Phone: 1300 353 000

Collection of Information

The personal information we collect in relation to you depends on the dealings you have with ClubsHR.

Personal information means information or an opinion about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion. The personal information which we collect, store, use and disclose may include:

• your name;
• your contact details;
• your banking details and/or credit card details;
• your age or date of birth;
• your employment history;
• your pay rate;
• your tax file number and superannuation information;
• educational qualifications;
• your current occupation; and
• any other person information provided by you during the course of your interactions or correspondence with ClubsHR.

We only collect personal information by lawful and fair means where reasonably necessary for our functions or activities as a provider of services to assist in staff management, rostering, payroll integration, shift swapping and time and attendance.

When asking you to provide personal information, ClubsHR will inform you of the purpose of gathering such information, the nature of the third parties to whom we will provide that information, and our contact point.

We collect personal information which:

• you provide to us via correspondence from you - this may be via telephone, email or mail;
• you provide to us in the course of updating or changing your details;
• is contained in documents or correspondence you provide to us;
• you provide to us via our website;
• you provide to us upon signing up for a free or paid account with any of our online platforms including ClubsHR;
• is provided to us by third parties who have disclosed that information to us (and only if it would be unreasonable or impracticable to collect the information directly from you); or
• is collected through cookies. Usually, cookies are used to identify repeat users of websites and remember their particular user preferences or settings.

If you purchase a product or service from us, we may request certain personally identifiable information from you. You may be required to provide contact information (such as name, email, and postal address) and financial information (such as credit card number, expiration date). We use this information for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.

All correspondence may also be collected and stored, particularly in regard to sales, support and accounts, including email.

Subject to certain exceptions under the Privacy Act, we only collect sensitive information about you if you consent to the collection of the information and the information is reasonably necessary for one or more of ClubsHR's functions or activities. The provision of sensitive information to us on a voluntary basis will be taken to be consent for this purpose.

Collection of unsolicited personal information

From time to time, we may receive unsolicited personal information about you. Unsolicited personal information is information we may receive about you which is not in response to a request by us for that information.

Where we receive unsolicited personal information about you (either directly from you or from a third party), we will consider, within a reasonable period, whether we could have collected that personal information from you had the personal information been solicited.

Where we determine that we could have collected the unsolicited personal information had it been solicited, we will store, use and disclose that personal information in the manner set out in this privacy policy.

Where we determine that we could not have collected the unsolicited personal information had it been solicited, we will destroy or de-identify that unsolicited personal information as soon as practicable, provided it is lawful and reasonable to do so.

Use of Collection Information

We may collect, store (in hard copy or electronic form), use or disclose and otherwise process your personal information for the primary purpose of conducting and supporting our functions or activities as a provider of services to assist in staff management, rostering, payroll integration, shift swapping and time and attendance. Without limiting the foregoing, we may collect, store, use or disclose your personal information:

• to provide you or your company with products and services under any contract with ClubsHR, including with respect to the provision, operation and maintenance of the human resources software platforms that we own and/or manage (such as ClubsHR);
• to contact you should we need to;
• to address any enquiries, complaints or feedback from you;
• to provide you with useful information and various event information; and
• to do anything ClubsHR is required or authorised to do by law.

ClubsHR does not share any information with third parties for any unknown or unrelated uses. However, ClubsHR may at its discretion and in accordance with the APPs use other third parties to provide essential services for our business processes. We may share your details as necessary for the third party to provide those services. Further, ClubsHR may provide personal information about you to:

• related group companies;
• third parties where you have given your consent (express or implied);
• our professional advisors, contractors or other service providers whom we may engage from time to time to carry out, advise or assist with the carrying out of our functions or activities; and
• government agencies or other similar entities as required or permitted by law.

When providing third parties with your personal information you provided to us, we endeavour to ensure that those third parties handle your personal information in accordance with the Privacy Act and this privacy policy.

We will not use your personal information for a secondary purpose unless:

• you consent to the use or disclosure, or you would reasonably expect us to use it for a secondary purpose which is related to the primary purpose;
• the use or disclosure is required or authorised by law; or
• the use or disclosure is otherwise permitted by the Privacy Act (for example, as a necessary part of an investigation of suspected unlawful activity).

Data collected from cookies may be used both anonymously and also in relation to ClubsHR’s user accounts. Additionally, cookie data may also be used via the website to track and collate usage and data. ClubsHR may use this data (including technical information about your computer, mobile device and system preferences) to assist in the creation of software updates, support and other matters related to ClubsHR’s services and website.

Direct Marketing

Unless you request otherwise, we may also use your personal information for marketing purposes to send you news, information about our activities and general promotional material which we believe may be useful or of interest to you. If you do not want us to use your personal information in this manner, please contact us using the contact details provided above and we will give effect to your request as soon as possible.

Storage of Collected Information

The security of your personal information is important to us. When you enter sensitive information (such as credit card numbers) on our website, we encrypt that information using secure socket layer technology (SSL). When credit card details are collected, we simply pass them on in order to be processed as required. We never permanently store complete credit card details.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

The length of time we keep your personal information depends on what it is and whether we have an ongoing business need to retain it, in accordance with our data retention policies and practices. We take reasonable steps to destroy or permanently de-identify personal information which is no longer needed for the purposes described in this privacy policy.

While we use our best endeavours to protect your personal information, we cannot guarantee the security of the information you disclosure and accordingly, you disclose that information at your own risk.

If you have any questions about security on our Website, you can email us at help@clubshr.com.

Access to Collected Information

Subject to any exceptions in the Privacy Act, if you have provided us with personal information, you have a right to request access to it. If you are of the belief that we hold personal information relating to you and you wish to obtain access to this information, please contact us on the details provided above. We may ask you to provide proof of your identity if you request access to or correction of your personal information.

In the event that a request for access is made, we will review our records to determine what personal information relating to you we hold and endeavour to respond to your request within a reasonable period after the request is made, but in any event, within 30 days.

Once we have notified you of the nature of the personal information relating to you which we hold, we will give you access to your personal information in the manner requested by you, if it is reasonable and practicable to do so.

We do not levy a charge in respect of the making of a request for access to personal information held by us. However, we may charge you for the reasonable costs incurred by us in providing you with access to the personal information held by us.

The Privacy Act provides instances where a holder of personal information may refuse to provide an individual with access to their personal information. If we refuse to give you access to your personal information, we will give you a written notice that sets out our reasons for the refusal and the mechanisms available to complain about our refusal.

If your personal information changes, or you believe there is an error in the personal information about you that we hold, you may correct and/or amend it by emailing us at help@clubshr.com.

We will take reasonable steps in accordance with the APPs to correct and/or amend that information. Please note that for security purposes we may ask you to verify your identity prior to processing any access or variation requests. If we refuse to correct your personal information, we will give you a written notice setting out our reasons for the refusal and the mechanisms available to complain about the refusal.

Cross Border Disclosure

ClubsHR may disclosure personal information to overseas recipients (depending on the nature of services those recipients provide to ClubsHR).

For example, customer data may be hosted via an overseas cloud service provider, or customer management systems may be hosted by an overseas server. Such disclosure will be managed in accordance with the APPs.

Specifically, if we disclose personal information to a third party in a country which does not have equivalent privacy laws to Australia, we will take reasonable steps in the circumstances to ensure that the overseas recipient does not breach the Privacy Act. In particular, we will not send your personal information overseas unless either:

• we reasonably believe that the recipient of the information is subject to a law or binding scheme that has the effect of protecting information in a way that, overall, is at least substantially similar to the way in which the Privacy Act protects personal information and there are mechanisms that you can access to take action to enforce that protection of the law or binding scheme; or
• you have consented to the transfer.

Links

Links on the ClubsHR site to external entities are provided for your convenience only and are not covered within this policy. The terms and conditions set out in this privacy statement only cover the domain names of www.clubshr.com and www.clubshr.com.

ClubsHR is not responsible for the privacy or security policies or practices of any third- party sites. Such third-party sites may have their own privacy or securities policies which you should read before providing any information to those third parties.

Complaints, questions or further information

If you wish to make a complaint about a breach of your privacy by us, you may contact us using the contact details provided above. All complaints will be investigated by an appropriately qualified representative. We will endeavour to resolve your complaint as quickly as possible and, in any event, within 30 days. We will notify you of the outcome of the investigation, including how we propose to resolve your complaint and what, if any, corrective measures we will implement.

If you are not satisfied with our handling of your complaint, you may lodge a complaint with the Office of the Australian Information Commissioner. For more information about doing so, visit https://www.oaic.gov.au/privacy/privacy-complaints/.

Changes to Privacy Policy

If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our homepage.