- Think HQ Pty Ltd ACN 143 646 664;
- Lumin Lessons Pty Ltd ACN 616 316 833; and
- Culture HQ Pty Ltd ACN 634 920 013 (trading as CultureVerse),
and each of their Related Bodies Corporate, as that term is defined in the Corporations Act 2001 (Cth) (together and separately (as appropriate), Think HQ Group, we, us, our).
The Think HQ Group is bound by the Privacy Act 1988 (Cth) (Privacy Act) and must comply with the Australian Privacy Principles (APPs). You can find out more information about the Privacy Act and the APPs at the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.
- How we collect your personal information
Personal information has the meaning given to that term in the Privacy Act and includes information or an opinion (whether true or not) about an identified individual, or an individual who is reasonably identifiable.
In general, the Think HQ Group collects personal information about its clients, suppliers, contractors, attendees at events conducted on behalf of our clients, members of the media, and prospective interns or employees. We aim to collect personal information only if it is reasonably necessary to provide the service, product or information you have requested from us or our client.
In the course of providing you with services, we collect personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your personal information from you directly. In some cases, however, we will collect information about you from a third party.
For example, if you attend an event that we conduct for our client, we may collect personal information about you from our client. If you are an employee of a client, supplier or contractor, we may also collect your personal information from your colleagues or employer. We may also collect your personal information from your talent agency if you are a person we use, or may use, in a campaign for a client.
At the time of collection, or as soon as practicable after we have collected it, we will take such steps as are reasonable in the circumstances to notify or make you aware of the collection and of any matters relevant to the collection, unless it is obvious from the circumstances that you would know or would expect us to have the information.
The Think HQ Group may collect personal information about you when you:
- engage with any of the Think HQ Group’s businesses and their employees (including individuals from the media) in the course of receiving services from the Think HQ Group;
- attend, or register to attend, an event that we are conducting on behalf of a client;
- visit any of our websites https://think-hq.com.au/, https://luminlessons.com or http://cultureverse.com.au (Websites);
- make an enquiry about our services;
- subscribe to receive newsletters or information from us;
- apply as a candidate for a position of employment with us; and
- apply for an internship program at with us in conjunction with a university; and
- supply goods or services to us.
- What personal information we collect about you
We may collect the following information about you:
- address, email address, telephone number and other contact details;
- details of the products or services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries; and
- details about you to assist in managing our relationship with you.
If you are a prospective employee or intern, we may collect details about your employment history and other details about you to assist with the recruitment process. We may collect this information from you directly, or from a recruiter or your university.
In connection with some client engagements, we may collect sensitive information about individuals (this may include information about racial or ethnic origin, disability or illness). We will obtain your consent before collecting sensitive information about you. We may also collect information about a client or its employee’s memberships of trade associations or union memberships if it is relevant to the event that we are conducting for that client.
For each visitor to our Websites, we may also collect the following non-personally identifiable information using third party website analytics providers:
- browser type, version and language;
- operating system;
- pages viewed while browsing the relevant website; and
- page access times and referring website address.
- Purpose of collection
We collect your personal information primarily to:
- provide you or our clients with the services and information that you or our client requests from us;
- provide you with information about the Think HQ Group’s services;
- suggest Think HQ Group’s services to you; and
- otherwise, manage our relationship with you.
- are a candidate for employment or internship, we may also collect your personal information primarily to contact you throughout the recruitment process; and
- employee or director of a client, contractor or supplier, we may also collect your personal information primarily to contact you for business purposes and manage our relationship with you or your organisation.
If it is reasonable to expect that we would use or disclose your personal information for purposes which are related to the above primary purposes, we may also use or disclose your personal information to:
- assist you with enquiries or complaints;
- develop and improve our client service and relationships;
- promote, advertise and market any of our products and services, including to invite you to events or activities hosted by the Think HQ Group or inform you of promotions;
- comply with our legal obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority), resolve any disputes that we may have with any of our clients and enforce our agreements with third parties such as your employer;
- inform you of developments at the Think HQ Group and other services that we can provide.
We may use information collected through our Websites for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at one of our Websites.
We may use your name, email address, organisation details and your position within your organisation for direct marketing purposes. Where possible, we will provide you with a choice to unsubscribe from any of our marketing communications. We will respect your request to decline to receive these marketing communications.
- Sharing of your personal information
We may disclose your personal information to:
- external providers of services that we may use to operate our business and manage our business systems (for example, this may include online booking services, online survey services, file storage service providers, database and mailing service providers (including email mailing service providers), marketing and e-commerce service providers, couriers and/or freight and transport service providers, printers, call centres providers of payment processing services, IT technicians who may need access when providing support (although it is our practice for them to work under supervision) and other professional service providers as required from time to time;
- if you are an employee of one of our clients, contractors, agents or suppliers to your employer;
- our client, if we have collected your personal information in connection with a client engagement; and
- our professional advisors and agents.
We may disclose your personal information to these third parties so that they can assist us in providing the best possible service to you.
Those third parties will be permitted to access only the personal information they need to deliver the service to the Think HQ Group or to you.
Each entity in the Think HQ Group may also disclose your personal information to other companies within the Think HQ Group (which are listed above). We are not likely to disclose information to overseas recipients unless it is with your consent, or the disclosure is required or authorised by law.
The privacy and collection practices of entities to which we disclose personal information are governed by their own privacy policies and collection notices.
We will not otherwise disclose information about you unless the disclosure:
- is required or authorised by law; or
- you have consented to our disclosing the information about you.
- Quality of your personal information
The Think HQ Group aims to ensure that your personal information is accurate, complete and up to date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested and properly update the information to us to keep it true, accurate, current and complete.
If you believe that the information we hold is inaccurate or incomplete, please contact us and we will use all reasonable efforts to correct the information.
If we do not believe the information to be incorrect, we will take reasonable steps to add a statement to the information claiming that you believe the information is inaccurate, incomplete, out of date.
- Securing your personal information
We may hold your personal information in electronic or hard copy form. We take reasonable precautions to protect your personal information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure. We use a number of physical, administrative, personnel and technical measures to protect your personal information.
We will retain your personal information as required by law, and then take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.
- Accessing and correcting your personal information
Subject to exceptions allowed by law, you can request access to or correction of your own personal information by contacting us. If the information held by the Think HQ Group is inaccurate, incomplete or not up to date you may request that we correct the information. You may be required to put your request in writing for security reasons.
We will give you access to, or correct, your personal information unless there is a lawful reason for refusing your request for access or correction. If We refuse your request we will give you a written notice explaining our reasons for that refusal and how you may complain about that refusal.
- Change in control of the Think HQ Group
If we sell or otherwise transfer part or the whole of the Think HQ Group or our business (or any entity in the Think HQ Group) to another organisation (including in the course of a transaction like a sale, merger or acquisition or as part of a dissolution, liquidation, administration, receivership or other form of insolvency), you agree that your personal information that is collected by the Think HQ Group may be disclosed to a third party, prospective buyer, transferee or insolvency practitioner and that this is reasonable to enable that party to continue or manage the business.
If you have a complaint about our collection, use or disclosure of your personal information, or you wish to make a complaint about a breach of the APPs, please contact us at the details set out below.
In your complaint, please set out the details of your complaint and your contact details. Our Privacy Officer will contact you to acknowledge your request and ask for any other applicable information. Our Privacy Officer will then investigate the issue and advise you in writing of the outcome.
You can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at www.oaic.gov.au.
- Contacting us
Our contact details in respect of any issues in relation to privacy are:
Telephone: 61 3 9682 0259
Post: Attn: Privacy Officer - Level 2,16-20 Thistlethwaite Street, South Melbourne VIC 3205